3rd Party

21. 3rd Party Policy

iDialogs makes every effort to assure all 3rd party organizations are compliant and do not compromise the integrity, security, and privacy of iDialogs or iDialogs Customer data. 3rd Parties include Customers, Partners, Subcontractors, and Contracted Developers.

21.1 Applicable Standards

21.1.1 Applicable Standards from the HITRUST Common Security Framework

  • 05.i - Identification of Risks Related to External Parties
  • 05.k - Addressing Security in Third Party Agreements
  • 09.e - Service Delivery
  • 09.f - Monitoring and Review of Third Party Services
  • 09.g - Managing Changes to Third Party Services
  • 10.1 - Outsourced Software Development

21.1.2 Applicable Standards from the HIPAA Security Rule

  • CFR ยง 164.314(a)(1)(i) - Business Associate Contracts or Other Arrangements

21.2 Policies to Assure 3rd Parties Support iDialogs Compliance

  1. iDialogs does not allow outbound 3rd party access to production systems containing ePHI.
  2. All connections and data in transit between the iDialogs Platform and 3rd parties are encrypted end to end.
  3. A standard business associate agreement with Customers and Partners is defined and includes the required security controls in accordance with the organization's security policies. Additionally, responsibility is assigned in these agreements.
  4. iDialogs has Service Level Agreements (SLAs) with Subcontractors with an agreed service arrangement addressing liability, service definitions, security controls, and aspects of services management.
    1. Subcontractors must coordinate, manage, and communicate any changes to services provided to iDialogs.
    2. Changes to 3rd party services are classified as configuration management changes and thus are subject to the policies and procedures described in iDialogs Policy #9; substantial changes to services provided by 3rd parties will invoke a Risk Assessment as described in iDialogs Policy #4.
    3. iDialogs utilizes monitoring tools to regularly evaluate Subcontractors against relevant SLAs.
  5. No iDialogs Customers or Partners have access outside of their own environment, meaning they cannot access, modify, or delete anything related to other 3rd parties.
  6. iDialogs does not outsource software development.
  7. iDialogs maintains and annually reviews a list all current Partners and Subcontractors.
    1. The list of current Partners and Subcontractors is maintained by the iDialogs Privacy Officer, includes details on all provided services (along with contact information), and is recorded in iDialogs Policy 1.4.
    2. The annual review of Partners and Subcontractors is conducted as a part of the security, compliance, and SLA review referenced below.
  8. iDialogs assesses security, compliance, and SLA requirements and considerations with all Partners and Subcontractors. This includes annual assessment of SOC2 Reports for all iDialogs infrastructure partners.
    1. iDialogs leverages recurring calendar invites to assure reviews of all 3rd party services are performed annually. These reviews are performed by the iDialogs Security Officer and Privacy Officer. The process for reviewing 3rd party services is outlined below:
      1. The Security Officer initiates the SLA review by creating an Issue in the JIRA Compliance Review Activity (CRA) Project.
      2. The Security Officer, or Privacy Officer, is assigned to review the SLA and performance of 3rd parties. The list of current 3rd parties, including contact information, is also reviewed to assure it is up to date and complete.
      3. SLA, security, and compliance performance is documented in the Issue.
      4. Once the review is completed and documented, the Security Officer approves or rejects the Issue. If the Issue is rejected, it goes back for further review and documentation.
  9. Regular review is conducted as required by SLAs to assure security and compliance. These reviews include reports, audit trails, security events, operational issues, failures and disruptions, and identified issues are investigated and resolved in a reasonable and timely manner.
  10. Any changes to Partner and Subcontractor services and systems are reviewed before implementation.
  11. For all partners, iDialogs reviews activity annually to assure partners are in line with SLAs in contracts with iDialogs.
  12. SLA review is monitored on a quarterly basis using JIRA reporting to assess compliance with above policy.