Compliance
Nulla Tertia, LLC
Innovation in healthcare requires trust. Assuring the privacy and security of patient data is at the core of our mission. Nulla Tertia, LLC is fully compliant with the HIPAA/HITECH regulations, as updated by the Omnibus Rule, and is also fully PCI Compliant.
HIPAA/HITECH
Nulla Tertia, LLC has instituted safeguards, policies, and procedures to protect patients’ health information, in compliance with the final rule issued by the United States Department of Health and Human Services regarding the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health Act (HITECH). These steps include:
Ongoing assessments of risks to the confidentiality, integrity, and availability of patient data.
Implementation of policies and procedures that dictate acceptable work practices and map directly to the HIPAA Security Rule’s Administrative, Physical, and Technical Safeguards.
Implementation of procedural and technical safeguards to prevent Nulla Tertia, LLC employees from improperly accessing PHI.
Designation of a Chief Security Officer responsible for information system monitoring and information security policy oversight.
Mandatory HIPAA privacy and security training for all workforce members.
Encryption of patient data at rest and in transit according to industry-best security standards.
Implementation of audit trail and record retention capabilities.
Execution of Business Associate Agreements with customers, vendors, and subcontractors, where appropriate.
Regular reassessment of all policies and procedures to ensure that HIPAA/HITECH rules continue to be addressed.
PCI-DSS
Our partner Stripe has been audited by a PCI-certified auditor, and is certified to PCI Service Provider Level 1. This is the most stringent level of certification available.
Stripe forces HTTPS for all services, including through the Nulla Tertia service and they regularly audit the details of our implementation.
All card numbers are encrypted on disk with AES-256. Decryption keys are stored on separate machines. None of Stripe's internal servers and daemons are able to obtain plaintext card numbers; instead, they can just request that cards be sent to a service provider on a static whitelist. Stripe's infrastructure for storing, decrypting, and transmitting card numbers runs in separate hosting infrastructure, and doesn't share any credentials with Stripe's primary services (API, website, etc.).
Confidentiality assurance
We approach compliance and security as a continuous cycle. Our NIST SP 800-30 Rev 1 risk assessment drives our organizational policies and procedures, which in turn drive our training cycle. We use operational feedback to continuously refine and improve our risk posture. All of our operational security metrics are monitored continuously and our compliance status is available in real time, 24/7.
Updated 1 June, 2020.