Facility Access Policy

Fox and Geese works with Subcontractors to ensure restrictions of physical access to systems used as part of the Fox and Geese Platform. Fox and Geese and its Subcontractors control access to the physical buildings/facilities that house these systems/applications, or in which Fox and Geese workforce members operate, in accordance with HIPAA Security Rule 164.310 and its implementation specifications. Physical Access to all of Fox and Geese facilities is limited to only those authorized in this policy. In an effort to safeguard PHI or PII from unauthorized access, tampering, and theft, access is allowed to areas only to those persons authorized to be in them and with escorts for unauthorized persons. All workforce members are responsible for reporting an incident of unauthorized visitor and/or unauthorized access to Fox and Geese's facility.

Of note, Fox and Geese does not have ready access to PHI or PII, it provides cloud-based, compliant infrastructure to covered entities and business associates. Fox and Geese does not physically house any systems used by its Platform in Fox and Geese facilities. Physical security of our Platform servers is outlined in Introduction.

Applicable Standards

Applicable Standards from the HITRUST Common Security Framework

• 08.b - Physical Entry Controls
• 08.d - Protecting Against External and Environmental Threats
• 08.j - Equipment Maintenance
• 08.l - Secure Disposal or Re-Use of Equipment
• 09.p - Disposal of Media

Applicable Standards from the HIPAA Security Rule

• 164.310(a)(2)(ii) Facility Security Plan
• 164.310(a)(2)(iii) Access Control & Validation Procedures
• 164.310(b-c) Workstation Use & Security

Fox and Geese-controlled Facility Access Policies

1. Visitor and third party support access is recorded and supervised. All visitors are escorted.
2. Repairs are documented and the documentation is retained.
3. Fire extinguishers and detectors are installed according to applicable laws and regulations.
4. Maintenance is controlled and conducted by authorized personnel in accordance with supplier-recommended intervals, insurance policies and the organization's maintenance program.
5. Electronic and physical media containing covered information is securely destroyed (or the information securely removed) prior to disposal.
6. The organization securely disposes media with sensitive information.
7. Physical access is restricted using smart locks that track all access.
   • Restricted areas and facilities are locked when unattended (where feasible).
   • Only authorized workforce members receive access to restricted areas (as determined by the Security Officer).
   • Access and keys are revoked upon termination of workforce members.
   • Workforce members must report a lost and/or stolen key(s) to the Security Officer.
   • The Security Officer facilitates the changing of the lock(s) within 7 days of a key being reported lost/stolen
8. Enforcement of Facility Access Policies
   • Report violations of this policy to the restricted area's department team leader, supervisor, manager, or director, or the Privacy Officer.
   • Workforce members in violation of this policy are subject to disciplinary action, up to and including termination.
   • Visitors in violation of this policy are subject to loss of vendor privileges and/or termination of services from Fox and Geese.
9. Workstation Security
   • Workstations may only be accessed and utilized by authorized workforce members to complete assigned job/contract responsibilities.
   • All workforce members are required to monitor workstations and report unauthorized users and/or unauthorized attempts to access systems/applications as per the System Access Policy.
   • All workstations purchased by Fox and Geese are the property of Fox and Geese and are distributed to users by the company.