Health Information Management

HIPAA Q&A: You’ve got questions. We’ve got answers!

HIM-HIPAA Insider, March 17, 2014

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Submit your HIPAA questions to Associate Editor Jaclyn Fitzgerald at and we will work with our experts to provide you with the information you need.

Q: As part of my covered entity’s regular information system review for HIPAA, we look for suspicious Windows events and suspicious logons to SQL by using aggregate reports. I know we have to retain these reports for six years. Are we required to retain the original Windows events and SQL compliance data that were used to create the reports for six years as well? Are we required to keep the original data source along with the reports prepared for the review?
A: It is not necessary to retain log records for six years following a documented review and any follow-up investigation. However, you need to retain the reports and documentation of any subsequent investigation for six years.
Adopt a policy that documents what your organization will retain and for how long. For example, if you decide to retain logs for 90 days following log review, you must document that information along with the rationale. In addition, you need to destroy those log files at the end of the retention period to avoid problems on the civil side such as a perceived violation of the Federal Rules of Civil Procedure.
Editor’s note: Chris Apgar, CISSP,president of Apgar & Associates, LLP, in Portland, Ore., answered this question for HCPro’sBriefings on HIPAA newsletter.

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