Data Access Governance

Overview

Establish and enforce comprehensive data access governance for protected health information (PHI) across electronic systems by implementing role-based access control (RBAC), minimum necessary standards, audit logging, anomaly detection, and break-the-glass procedures. HIPAA's Security Rule (45 CFR 164.312(a)) requires access controls as a technical safeguard, and the Privacy Rule (45 CFR 164.502(b)) mandates minimum necessary use and disclosure. This skill operationalizes these requirements into a practical governance framework that balances robust PHI protection with the clinical workflow efficiency needed for patient care delivery.

When to Use

• Designing or reviewing role-based access control frameworks for EHR and clinical systems
• Conducting periodic user access reviews and recertification
• Investigating suspected unauthorized access to patient records (snooping)
• Implementing minimum necessary standards for PHI access
• Designing break-the-glass procedures for emergency access
• Responding to OCR audit findings related to access controls
• Managing access changes for new hires, role changes, and terminations
• Evaluating access control capabilities during system selection or implementation

Required Inputs