XENA Health

Data Security

Xena takes your data security very seriously. Your PHI data is held encrypted using your encryption keys and neither Xena nor hosting company employees can decrypt this data without getting the keys from you first, even if thieves stole the database servers they would not be able to get to the PHI data.

Xena has also implemented audit logs on all PHI data so that you can trace who last changed the data, as well as timeouts on screen use when users leave a terminal unused.

Xena backups up your data securely encrypting the FULL backup thus encrypting the PHI data twice, all data is stored on hard disks for faster recovery rather than tape or removable media and store the backup files in 2 separate locations for extra security.

What is PHI Data?

The 18 identifiers are as follows:

  • names
  • all geographical subdivisions smaller than a State, including street address, city, county, precinct, zip code, and their equivalent geocodes, except for the initial three digits of a zip code, if according to the current publicly available data from the Bureau of the Census: (1) The geographic unit formed by combining all zip codes with the same three initial digits contains more than 20,000 people; and (2) The initial three digits of a zip code for all such geographic units containing 20,000 or fewer people is changed to 000.
  • all elements of dates (except year) for dates directly related to an individual, including birth date, admission date, discharge date, date of death; and all ages over 89 and all elements of dates (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older
  • phone numbers
  • fax numbers
  • email addresses
  • social Security numbers
  • medical record numbers
  • health plan beneficiary numbers
  • account numbers
  • certificate/license numbers
  • vehicle identifiers and serial numbers, including license plate numbers
  • device identifiers and serial numbers
  • web Universal Resource Locators (URLs)
  • internet Protocol (IP) address numbers
  • biometric identifiers, including finger and voice prints
  • full face photographic images and any comparable images
  • any other unique identifying number, characteristic, or code (note this does not mean the unique code assigned by the investigator to code the data)

There are also additional standards and criteria to protect individual's privacy from re-identification. Any code used to replace the identifiers in datasets cannot be derived from any information related to the individual and the master codes, nor can the method to derive the codes be disclosed. For example, a subject's initials cannot be used to code their data because the initials are derived from their name. Additionally, 3rd party's must not have actual knowledge that the patient could be re-identified from the remaining identifiers in the data used. In other words, the information would still be considered identifiable is there was a way to identify the individual even though all of the 18 identifiers were removed.

What is PHI?

Protected health information (PHI) is any information in the medical record or designated record set that can be used to identify an individual and that was created, used, or disclosed in the course of providing a health care service such as diagnosis or treatment. HIPAA regulations allow researchers to access and use PHI when necessary to conduct research. However, HIPAA only affects research that uses, creates, or discloses PHI that will be entered in to the medical record or will be used for healthcare services, such as treatment, payment or operations.

Xena does not need nor any Xena supplier access to any PHI data, if in the future we have any requests for information from research or government agencies we will forward these to you our users.

What is not PHI?

Also note, health information by itself without the 18 identifiers is not considered to be PHI. For example, a dataset of vital signs by themselves do not constitute protected health information. However, if the vital signs dataset includes medical record numbers, then the entire dataset must be protected since it contains an identifier. PHI is anything that can be used to identify an individual such as private information, facial images, fingerprints, and voiceprints. These can be associated with medical records, biological specimens, biometrics, data sets, as well as direct identifiers of the research subjects in clinical trials.

Xena encrypts all PHI data including any interchanges with clearing houses, providers or patients that we store in order to ensure that only you our clients can decrypt and read such data.

Where is your data?

Your data is held on Amazon Cloud Servers on the east coast of America. The data is held securely and all PHI is encrypted with the keys you generated on signing up and which you have the primary copy. Hosting companies can not decrypt the data, all backups are also encrypted, only you and the Xena security officer have access to your keys