If your behavioral health practice has been the victim of a HIPAA breach, it’s important to take immediate steps to remediate the breach. The sooner you take action, the better you can mitigating the damage to your organization and your patients’ privacy.
If your practice’s data has been breached, here are the first steps you should take:
- Call your banks and credit card companies. They’ll put a lock on your accounts to prevent fraudulent transactions. This should be done IMMEDIATELY.
- Change all of your passwords. If your old passwords were fewer than 7 characters, make your new ones longer. To increase security, use a mix of capital letters, lowercase letters, numbers, and symbols. You can refer to the NIST Guide to Enterprise Password Management for more information.
- Notify credit bureaus that your personal identity or data has been compromised. The bureaus will put a fraud alert on your profile so that your credit isn’t damaged.
- Use a credit report service to obtain a copy of your credit report for documentation purposes.
- Enrolling in an Identity Theft Recovery program is highly advisable. You can begin working on a recovery plan almost immediately.
Once you’ve taken steps to immediately secure the situation, you’ll need to start on the path towards breach management.
- Immediately notify your IT department or provider. Create an action plan to deal with the breach and to identify its scope.
- Contact external companies. If you have Business Associates, vendors, or contractors whose data might have been involved in the breach, make sure to notify them immediately.
- Notify appropriate local, state, or federal authorities. If any protected health information (PHI) was breached, research applicable laws that your practice or organization is beholden to. Depending on the size and scope of the breach, you’ll need to take different steps toward notifying affected parties–refer to the HIPAA Breach Notification Rule for more information.
- If the HIPAA breach is severe, it may be necessary to file an FTC or police report.
- Make sure you fully document everything you do, including the date of the breach, when you were notified, and all the steps you’ve taken thereafter–this documentation will be essential if an investigation proceeds.