Subsections of User Access and Identity Management
Chapter 1
Authentication Standards
Effective authentication is critical for protecting AccuCode AI’s systems, data, and user accounts. This section outlines the standards and requirements for implementing secure authentication mechanisms across the organization.
All employees and third-parties must adhere to these authentication policies. Questions or concerns should be directed to the InfoSec team at security@accucodeai.com.
Subsections of Authentication Standards
Password Construction Standards
Version1.0.3
Last Updated2024-03-28
APPROVED
1. Overview
Passwords are a critical component of information security. Passwords serve to
protect access to user accounts, data, and systems. However, a poorly
constructed or easily guessed password can compromise the strongest defenses.
This guideline provides best practices for creating strong passwords and using
additional security measures such as hardware-based two-factor authentication
(2FA) and password managers.
2. Purpose
The purpose of these guidelines is to provide best practices for the creation of
strong passwords and the use of additional security measures to protect user
accounts and sensitive data.
3. Scope
This guideline applies to employees, contractors, consultants, temporary and
other workers, including all personnel affiliated with third parties. This
guideline applies to all passwords including but not limited to user-level
accounts, system-level accounts, web accounts, e-mail accounts, screen saver
protection, voicemail, and local router logins.
4. Standards
4.1 Password Strength
- Passwords should be at least 16 characters long. The more characters a
password has, the stronger it is.
- Use passphrases, which are passwords made up of multiple words. Examples
include “cactus trace4 week303end” or “bl0ck-curious-suNNy-leaves”.
Passphrases are both easy to remember and type yet meet the strength
requirements.
- Passwords should include a mix of uppercase and lowercase letters, numbers,
and special characters.
- Avoid using easily guessable information such as personal information,
dictionary words, or common phrases.
4.2 Password Managers
- Use a reputable password manager to generate, store, and manage strong, unique
passwords for each account.
- Password managers should be protected with a strong master password with
hardware-based 2FA.
4.3 Two-Factor Authentication (2FA)
- Enable hardware-based 2FA, such as security keys or smart cards, for all
critical accounts, including but not limited to email, VPN, and remote access
systems.
- Where hardware-based 2FA is not available, use app-based 2FA or SMS-based 2FA
as a secondary option.
4.4 Password Auditing
- Password cracking or guessing may be performed on a periodic or random basis
by the InfoSec Team or its delegates.
- If a password is guessed or cracked during one of these scans, the user will
be required to change it.
5. Standards Compliance
5.1 Compliance Measurement
The Infosec team will verify compliance to this policy through various methods,
including but not limited to password cracking exercises, business tool reports,
internal and external audits, and feedback to the policy owner.
5.2 Exceptions
Any exception to the policy must be approved by the Infosec team in advance.
5.3 Non-Compliance
An employee found to have violated this policy may be subject to disciplinary
action, up to and including termination of employment.
Version1.0.3
Last Updated2023-10-16
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1. Purpose
This document outlines the policy for third-party organizations connecting to
AccuCode AI Inc. networks for the purpose of transacting business related to the
company.
2. Scope
This policy applies to all connections between third parties that require access
to non-public AccuCode AI Inc. resources, regardless of the technology used for
the connection (e.g., telco circuit or VPN). Connections to third parties such
as Internet Service Providers (ISPs) or the Public Switched Telephone Network do
not fall under this policy.
3. Policy
3.1 Security Review
All new extranet connectivity requests must undergo a security review conducted
by the InfoSec team. The review ensures that access aligns with business
requirements and adheres to the principle of least access.
3.2 Business Case
All production extranet connections must be accompanied by a valid written
business justification, approved by a project manager in the extranet group. Lab
connections must be approved by the team responsible for lab security.
The Sponsoring Organization must designate a Point of Contact (POC) responsible
for the portions of this policy and the Third Party Agreement that pertain to
them. The relevant extranet organization must be promptly informed of any
changes to the POC.
3.4 Modifying or Changing Connectivity and Access
All access changes must be accompanied by a valid business justification and are
subject to security review. Changes must be implemented via the corporate change
management process. The Sponsoring Organization is responsible for notifying the
extranet management group and/or InfoSec of any material changes to their
originally provided information.
3.5 Terminating Access
When access is no longer required, the Sponsoring Organization must notify the
responsible extranet team, which will terminate the access as appropriate. The
extranet and lab security teams must conduct annual audits of their respective
connections to ensure that all existing connections are still needed and that
the provided access meets the connection’s needs. Deprecated connections or
those no longer used to conduct business will be terminated immediately. InfoSec
and/or the extranet team will notify the POC or the Sponsoring Organization of
any changes prior to taking action.
4. Policy Compliance
4.1 Compliance Measurement
The InfoSec team will verify compliance to this policy through various methods,
including but not limited to, business tool reports, internal and external
audits, and feedback to the policy owner.
4.2 Exceptions
Any exception to the policy must be approved by the InfoSec team in advance.
4.3 Non-Compliance
Employees found to have violated this policy may be subject to disciplinary
action, up to and including termination of employment.
Mobile Device Encryption Policy
Version1.0.5
Last Updated2024-01-23
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1. Overview
Mobile devices such as smartphones and tablets can create added risk and
potential targets for data loss, especially given the sensitive nature of the
healthcare documents processed by AccuCode AI. As such, their use must be in
alignment with appropriate standards, and encryption technology should be used
when possible to protect sensitive data.
2. Purpose
This document describes AccuCode AI’s Information Security requirements for
encrypting data at rest on mobile devices to ensure the confidentiality and
integrity of sensitive healthcare information.
3. Scope
This policy applies to any mobile device issued by or used for business which
contains stored data owned by AccuCode AI Inc.
4. Policy
All mobile devices containing stored data owned by AccuCode AI must use an
approved method of encryption to protect data at rest. Mobile devices are
defined to include laptops, smartphones, and tablets. Users are expressly
forbidden from storing data on devices that are not issued by AccuCode AI, such
as storing email or sensitive documents on a personal device.
4.1 Laptops
Laptops must employ full disk encryption with an approved software encryption
package that is FIPS 140-3 compliant. BitLocker (for Windows) and FileVault (for
macOS) are recommended encryption solutions.
4.2 Smartphones and Tablets
Any data stored on a smartphone or tablet must be saved to an encrypted file
system using AccuCode AI-approved software that is FIPS 140-3 compliant.
AccuCode AI shall also employ remote wipe technology to remotely disable and
delete any data stored on a smartphone or tablet which is reported lost or
stolen. Mobile Device Management (MDM) solutions should be used to enforce
encryption and remote wipe capabilities.
4.3 Keys
All encryption keys and passphrases must meet complexity requirements described
in AccuCode AI’s Password Protection Policy. Keys should be securely stored and
managed using a FIPS 140-3 compliant key management system.
4.4 Loss and Theft
The loss or theft of any mobile device containing AccuCode AI data must be
reported immediately to the Information Security team.
5. Policy Compliance
5.1 Compliance Measurement
The Information Security team will verify compliance to this policy through
various methods, including but not limited to, business tool reports, internal
and external audits, and feedback to the policy owner.
5.2 Exceptions
Any exception to the policy must be approved by the Information Security team in
advance.
5.3 Non-Compliance
An employee found to have violated this policy may be subject to disciplinary
action, up to and including termination of employment.
Password Protection Policy
Version1.0.3
Last Updated2023-12-25
APPROVED
1. Overview
Passwords are a critical aspect of computer security. A weak or compromised
password can result in unauthorized access to our most sensitive data and/or
exploitation of our resources. All staff, including contractors and vendors with
access to systems, are responsible for taking the appropriate steps, as outlined
below, to select and secure their passwords.
2. Purpose
The purpose of this policy is to establish a standard for the secure use and
protection of all work related passwords.
3. Scope
The scope of this policy includes all personnel who have or are responsible for
an account (or any form of access that supports or requires a password) on any
system that resides at any facility, has access to the network, or stores any
non-public information.
4. Policy
4.1 Password Creation and Use
4.1.1 All user-level and system-level passwords must conform to the Password
Construction Standards.
4.1.2 Users must use a separate, unique password for each of their work related
accounts. Users may not use any work related passwords for their own, personal
accounts.
4.1.3 Staff are required to use authorized, approved password managers to
securely store and manage all their work related passwords.
4.1.4 User accounts that have system-level privileges granted through group
memberships or programs such as sudo must have a unique password from all other
accounts held by that user to access system-level privileges. In addition,
hardware-based multi-factor authentication is required for any privileged
accounts.
4.2 Password Change
4.2.1 Passwords should be changed only when there is reason to believe a
password has been compromised or fails to meet our Password Creation
Requirements. We do not recommend the use or setting of regular password
expiration.
4.3 Password Protection
4.3.1 Passwords must not be shared with anyone, including supervisors and
coworkers. All passwords are to be treated as sensitive, Confidential
information.
4.3.2 Passwords must not be inserted into email/chat messages or other forms of
electronic communication, nor revealed over the phone to anyone.
4.3.3 Passwords may be stored only in password managers authorized by the
organization.
4.3.4 Do not use the “Remember Password” feature of applications (for example,
web browsers).
4.3.5 Any individual suspecting that their password may have been compromised
must report the incident and change all relevant passwords.
4.4 Application Development
Application developers must ensure that their programs contain the following
security precautions:
4.4.1 Applications must support authentication of individual users, not groups.
4.4.2 Applications must not store passwords in clear text or in any easily
reversible form.
4.4.3 Applications must not transmit passwords in clear text over the network.
4.4.4 Applications must provide for some sort of role management, such that one
user can take over the functions of another without having to know the other’s
password.
4.5 Multi-Factor Authentication
4.5.1 Hardware-based multi-factor authentication is required and must be used
whenever possible, not only for work related accounts but personal accounts
also.
5. Policy Compliance
5.1 Compliance Measurement
The Infosec team will verify compliance to this policy through various methods,
including but not limited to, business tool reports, internal and external
audits, and feedback to the policy owner.
5.2 Exceptions
Any exception to the policy must be approved by the Infosec team in advance.
5.3 Non-Compliance
An employee found to have violated this policy may be subject to disciplinary
action, up to and including termination of employment.
Remote Access Policy
Version1.0.2
Last Updated2024-01-16
APPROVED
1. Overview
Remote access to AccuCode AI’s corporate network is essential to maintain our
team’s productivity, especially with many employees working from home. However,
remote access often originates from networks with lower security postures that
may already be compromised. While these remote networks are beyond AccuCode AI’s
direct control, we must mitigate the risks to the best of our ability,
particularly given the sensitive protected health information (PHI) we handle.
2. Purpose
The purpose of this policy is to define rules and requirements for connecting to
AccuCode AI’s network from any remote host. These rules aim to minimize the
potential exposure to damages which may result from unauthorized access to PHI
and other sensitive data. Damages include the loss of PHI, damage to public
image, fines, and other financial liabilities.
3. Scope
This policy applies to all employees and contractors with an AccuCode AI-owned
or personally-owned computer used to connect to the corporate network to do work
on behalf of AccuCode AI. This covers any remote access connections, including
email and intranet access.
4. Policy
Employees and contractors with remote access privileges to AccuCode AI’s network
must ensure their remote access connection is as secure as an on-site
connection.
When accessing the network from a personal computer, authorized users are
responsible for preventing access by non-authorized users, including family
members. Performing illegal activities through the network is strictly
prohibited.
4.1 Requirements
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4.1.1 Secure remote access must use encryption (e.g. VPN) and strong
passphrases.
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4.1.2 Authorized users shall protect their login credentials, even from family
members.
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4.1.3 When connecting to AccuCode AI’s network, the remote host must not be
connected to any other network simultaneously, with the exception of personal
networks under the complete control of the authorized user.
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4.1.4 Use of external resources requires advance approval from InfoSec.
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4.1.5 All remote hosts must have up-to-date antivirus software.
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4.1.6 Personal equipment must not be used for remote access.
4.2 Protecting PHI When Working Remotely
- Ensure home workspace cannot be viewed by others, including family.
- Lock computer when not in use. Never leave it unattended and accessible.
- Do not print PHI at home.
- Do not store PHI on removable media.
- Only discuss PHI in private where conversations cannot be overheard.
- Report any potential PHI breaches immediately, even if unintentional.
5. Policy Compliance
The InfoSec team will verify compliance to this policy through various methods,
including audits and business tool reports. Any exceptions must be approved by
InfoSec in advance. Employees found to have violated this policy may face
disciplinary action, up to and including termination.
Version1.0.1
Last Updated2024-01-12
APPROVED
1. Overview
AccuCode AI Inc. processes sensitive healthcare documents containing protected
health information (PHI). Remote access tools provide a convenient way for users
and support staff to share screens and access systems remotely. However, if not
properly secured and controlled, these tools can also open backdoors into the
network that could lead to theft, unauthorized access or destruction of
sensitive data assets.
Therefore, only approved, monitored and strictly governed remote access tools
may be used on AccuCode AI’s computer systems. This policy defines the
requirements for using remote access tools.
2. Scope
This policy applies to all remote access connections where either end terminates
at an AccuCode AI owned or managed asset or system.
3. Policy Requirements
All remote access tools used to communicate with AccuCode AI assets and systems
must adhere to the following:
Only remote access tools on the approved software list maintained by the IT
department are permitted. The current approved tools are:
- SSH (with AD auth)
- Microsoft Remote Desktop (over VPN only)
- Citrix GoToMyPC (over VPN only)
Procedures for secure configuration of each approved tool are provided by IT and
must be followed. The list of approved tools is subject to change.
3.2 Authentication
- All remote access tools that allow communication from external networks must
require multi-factor authentication using methods such as hardware tokens,
smart cards, or additional PIN/password.
- Authentication must use Active Directory or LDAP as the user identity source.
- Authentication protocols must be resistant to replay attacks, such as OAuth
2.0.
- Both ends of remote access sessions must be mutually authenticated.
3.3 Access Control
- Remote access tools must be configured to use application layer proxies rather
than allowing direct connections through perimeter firewalls.
- Connections must be encrypted end-to-end using strong encryption protocols in
compliance with AccuCode AI’s network encryption policy.
Remote access tools must not interfere with, disable or circumvent antivirus,
DLP, or other security systems.
3.5 Procurement
All remote access tools must be purchased through and approved by the IT
department via the standard procurement process.
4. Policy Compliance
4.1 Compliance Measurement
The Information Security team will verify compliance to this policy through
various methods, including but not limited to:
- Reports from business tools
- Internal and external audits
- Feedback to the policy owner
4.2 Exceptions
Any exceptions to this policy must be approved in advance by the Information
Security team.
4.3 Non-Compliance
Employees found to have violated this policy may face disciplinary action up to
and including termination of employment.