HIPAA Compliance Framework

Effective Date: August 27, 2025
Last Updated: August 27, 2025
Classification: Public

ARTICLE I. EXECUTIVE SUMMARY AND REGULATORY FOUNDATION

Section 1.01 HIPAA Compliance Commitment and Framework

Assivo, Inc., an Illinois corporation ("Assivo," "Company," "we," "us," or "our"), maintains a comprehensive Health Insurance Portability and Accountability Act ("HIPAA") Compliance Framework designed to ensure full adherence to federal healthcare privacy and security regulations when providing services to covered entities and handling protected health information across our global operations.

Section 1.02 Regulatory Scope and Application

This HIPAA Compliance Framework governs our obligations as a Business Associate under HIPAA and the Health Information Technology for Economic and Clinical Health Act ("HITECH Act") when processing, accessing, maintaining, or transmitting protected health information on behalf of covered entities including healthcare providers, health plans, and healthcare clearinghouses.

Section 1.03 Business Associate Role and Responsibilities

When engaged by covered entities to perform functions or activities involving protected health information, Assivo operates as a Business Associate with comprehensive compliance obligations including implementation of appropriate administrative, physical, and technical safeguards designed to meet or exceed HIPAA Security Rule requirements and industry standards for healthcare information protection.

ARTICLE II. PROTECTED HEALTH INFORMATION GOVERNANCE

Section 2.01 Protected Health Information Definition and Scope

Protected Health Information ("PHI") encompasses all individually identifiable health information held or transmitted by Assivo in any form or media, whether electronic, paper, or oral, including:

(a) Electronic Protected Health Information (ePHI): All PHI created, received, maintained, or transmitted electronically including healthcare records, billing information, treatment data, and any health-related information in electronic format.

(b) Physical Protected Health Information: Paper records, printed materials, written documentation, and any other physical media containing individually identifiable health information requiring protection under HIPAA regulations.

(c) Oral Protected Health Information: Spoken communications, verbal discussions, telephone conversations, and any other oral transmission of individually identifiable health information requiring confidentiality protection.

Section 2.02 Information Handling and Processing Principles

All PHI processing activities are governed by fundamental principles including:

(a) Minimum Necessary Standard: Access to and use of PHI is limited to the minimum necessary to accomplish the intended purpose with systematic evaluation of information needs and restriction of access to essential information only.

(b) Purpose Limitation and Authorized Use: PHI is used and disclosed only for purposes authorized by the covered entity, required by law, or necessary for proper administration of Business Associate functions as defined in executed Business Associate Agreements.

(c) Confidentiality and Security Protection: Comprehensive protection of PHI confidentiality, integrity, and availability through appropriate administrative, physical, and technical safeguards meeting or exceeding HIPAA Security Rule requirements.

(d) Individual Rights Protection: Respect for individual privacy rights including access, amendment, accounting of disclosures, and other rights established under HIPAA Privacy Rule with appropriate procedures for rights exercise and fulfillment.

ARTICLE III. ADMINISTRATIVE SAFEGUARDS AND GOVERNANCE

Section 3.01 HIPAA Compliance Program Structure

3.01.1 Security Officer and Compliance Leadership

(a) HIPAA Security Officer: Designated Technology Officer serves as HIPAA Security Officer with responsibility for developing, implementing, and maintaining HIPAA compliance programs including security policies, procedures, and control implementation across all business functions and operational locations.

(b) Privacy Officer: Designated General Counsel serves as Privacy Officer with responsibility for privacy policy development, individual rights implementation, complaint handling, and privacy compliance monitoring and enforcement throughout organizational operations.

(c) Workforce Training and Awareness: Comprehensive HIPAA training programs for all workforce members with access to PHI including initial training, annual refresher programs, role-specific training, and ongoing awareness initiatives ensuring competent and compliant PHI handling.

(d) Compliance Monitoring and Audit: Regular compliance assessments, internal audits, and monitoring programs validating HIPAA compliance implementation with systematic evaluation of policy adherence, control effectiveness, and continuous improvement opportunities.

3.01.2 Access Management and Workforce Controls

(a) Access Authorization and Management: Formal procedures for authorizing PHI access based on job responsibilities and minimum necessary requirements with systematic access provisioning, review, and termination procedures ensuring appropriate access control throughout employment lifecycle.

(b) Workforce Security and Background Verification: Comprehensive background verification procedures for personnel with PHI access including criminal background checks, reference verification, and ongoing suitability assessment ensuring workforce reliability and trustworthiness.

(c) Information Access Management: Systematic procedures for granting, modifying, and terminating information system access with role-based access controls, privilege management, and regular access certification ensuring PHI access remains appropriate and authorized.

(d) Security Awareness and Training: Ongoing security awareness programs including phishing prevention, social engineering recognition, incident reporting, and security best practices ensuring workforce competency in PHI protection and threat recognition.

Section 3.02 Business Associate Agreement Compliance

3.02.1 Contractual Obligations and Requirements

(a) Permitted Uses and Disclosures: Strict adherence to permitted uses and disclosures as defined in Business Associate Agreements with systematic controls ensuring PHI use remains within authorized parameters and contractual limitations.

(b) Safeguard Implementation: Implementation of appropriate administrative, physical, and technical safeguards as required by Business Associate Agreements and HIPAA regulations with ongoing monitoring and validation of safeguard effectiveness.

(c) Subcontractor Management: Comprehensive management of downstream Business Associates including appropriate Business Associate Agreements, compliance monitoring, and oversight ensuring HIPAA compliance throughout extended service relationships.

(d) Breach Notification and Reporting: Systematic breach identification, assessment, and notification procedures ensuring timely and accurate reporting to covered entities and regulatory authorities as required by HIPAA Breach Notification Rule.

3.02.2 Individual Rights Support and Implementation

(a) Access Request Support: Systematic procedures for supporting covered entity fulfillment of individual access rights including PHI retrieval, compilation, and provision in requested formats within required timeframes.

(b) Amendment Request Processing: Comprehensive procedures for processing amendment requests including PHI modification, documentation of changes, and notification of affected parties as directed by covered entities.

(c) Accounting of Disclosures: Detailed tracking and reporting of PHI disclosures as required for covered entity accounting of disclosures obligations with systematic documentation and retrieval capabilities.

(d) Restriction and Complaint Handling: Support for covered entity implementation of individual rights including restriction requests, complaint investigation, and other individual rights fulfillment as required by HIPAA regulations.

ARTICLE IV. PHYSICAL SAFEGUARDS AND FACILITY SECURITY

Section 4.01 Facility Access Controls and Physical Protection

4.01.1 Workstation and Facility Security

(a) Facility Access Controls: Multi-factor authentication systems for facility access including badge readers, biometric verification, and visitor management systems ensuring only authorized personnel access areas where PHI is processed, stored, or transmitted.

(b) Workstation Use Restrictions: Systematic controls limiting workstation access to authorized users with automatic screen locks, session timeouts, physical workstation security, and environmental controls preventing unauthorized PHI access or observation.

(c) Workstation Security Configuration: Standardized workstation configurations with appropriate security controls including endpoint protection, encryption, access controls, and monitoring systems ensuring PHI protection during processing and storage activities.

(d) Media Controls and Management: Comprehensive procedures for PHI-containing media including secure storage, handling procedures, disposal requirements, and tracking systems ensuring media protection throughout lifecycle and preventing unauthorized access or disclosure.

4.01.2 Device and Equipment Protection

(a) Mobile Device Security: Comprehensive mobile device management including encryption requirements, access controls, remote wipe capabilities, and usage policies ensuring PHI protection on portable devices and preventing unauthorized access during device loss or theft.

(b) Equipment Disposal and Reuse: Systematic procedures for secure disposal or reuse of equipment containing PHI including data destruction verification, certificate of destruction documentation, and asset tracking ensuring complete PHI elimination before disposal or redeployment.

(c) Backup and Storage Media Security: Secure storage and handling of backup media, archived data, and storage systems containing PHI with appropriate environmental controls, access restrictions, and monitoring systems preventing unauthorized access or environmental damage.

Section 4.02 Environmental and Infrastructure Protection

4.02.1 Environmental Controls and Monitoring

(a) Climate Control and Environmental Management: Advanced HVAC systems with temperature and humidity monitoring, environmental alerting, and automated backup systems protecting information systems and media from environmental damage and ensuring optimal operating conditions.

(b) Fire Suppression and Emergency Systems: Sophisticated fire detection and suppression systems specifically designed for information technology environments with early warning capabilities, automated suppression activation, and coordination with emergency response services.

(c) Power Protection and Continuity: Uninterruptible power supplies, backup generator systems, and power conditioning equipment ensuring continuous operation of PHI processing systems and preventing data loss or system compromise during power disruptions.

(d) Physical Monitoring and Surveillance: Comprehensive surveillance systems with video monitoring, motion detection, and access logging providing continuous facility security monitoring and incident detection capabilities supporting physical security and access control objectives.

ARTICLE V. TECHNICAL SAFEGUARDS AND CYBERSECURITY

Section 5.01 Access Control and Authentication Systems

5.01.1 Electronic Access Control Framework

(a) User Authentication and Verification: Multi-factor authentication systems requiring multiple verification factors for PHI system access including knowledge factors, possession factors, and biometric verification ensuring robust user identity verification and preventing unauthorized access.

(b) Role-Based Access Control Implementation: Systematic role-based access controls aligning system permissions with job responsibilities and minimum necessary requirements with automated provisioning, regular access review, and immediate termination procedures upon employment changes.

(c) Unique User Identification: Assignment of unique user identifiers to each workforce member with PHI access including systematic user account management, activity tracking, and accountability measures enabling comprehensive audit trail maintenance and user activity monitoring.

(d) Emergency Access and Break-Glass Procedures: Documented emergency access procedures for critical system access during emergencies with enhanced monitoring, approval processes, and post-emergency review ensuring appropriate emergency response while maintaining security controls.

5.01.2 Privileged Access Management

(a) Administrative Access Controls: Enhanced security controls for administrative access including privileged account management, session monitoring, approval workflows, and comprehensive audit trail maintenance for all elevated privilege activities and system modifications.

(b) Just-in-Time Access Provisioning: Temporary privilege elevation systems providing time-limited administrative access with automatic expiration, approval workflows, and comprehensive monitoring ensuring minimum necessary administrative access and enhanced security controls.

(c) Session Recording and Monitoring: Complete recording of privileged user sessions, administrative activities, and system modifications with secure storage, searchable audit logs, and comprehensive forensic capabilities supporting incident investigation and compliance validation.

Section 5.02 Audit Controls and Activity Monitoring

5.02.1 Comprehensive Audit Framework

(a) System Activity Logging: Comprehensive logging of all PHI system access, modification, and transmission activities including user identification, timestamps, actions performed, and system responses with secure log storage and retention meeting HIPAA requirements.

(b) Audit Log Review and Analysis: Systematic review of audit logs including automated monitoring, anomaly detection, and investigation procedures with regular log analysis and follow-up on suspicious activities or potential security incidents.

(c) Audit Trail Protection and Integrity: Secure storage and protection of audit logs including encryption, access controls, and integrity verification preventing unauthorized modification or deletion of audit evidence and ensuring comprehensive accountability.

(d) Reporting and Documentation: Regular audit reporting including compliance summaries, security metrics, incident analysis, and performance indicators with systematic documentation supporting compliance validation and continuous improvement initiatives.

5.02.2 Monitoring and Alerting Systems

(a) Real-Time Security Monitoring: Continuous monitoring of PHI systems including intrusion detection, behavioral analysis, and automated threat response with immediate alerting and response capabilities for potential security incidents or unauthorized access attempts.

(b) Anomaly Detection and Response: Advanced analytics and machine learning systems for identifying unusual access patterns, suspicious activities, and potential security threats with automated response capabilities and investigation procedures.

(c) Performance and Availability Monitoring: Comprehensive monitoring of system performance, availability, and capacity with proactive alerting and management ensuring PHI system reliability and preventing service disruptions affecting healthcare operations.

ARTICLE VI. ENCRYPTION AND DATA PROTECTION

Section 6.01 Encryption Standards and Implementation

6.01.1 Comprehensive Encryption Framework

(a) Data at Rest Encryption: Advanced Encryption Standard (AES-256) or equivalent cryptographic protection for all PHI stored on servers, databases, backup systems, and storage media with comprehensive key management and protection ensuring data confidentiality and integrity.

(b) Data in Transit Encryption: Transport Layer Security (TLS 1.3) or equivalent encryption protocols for all PHI transmission including web communications, API connections, file transfers, and remote access ensuring data protection during transmission and preventing interception.

(c) End-to-End Encryption: Implementation of end-to-end encryption for sensitive PHI communications and transfers with client-controlled encryption keys where appropriate ensuring maximum data protection and confidentiality throughout processing and transmission activities.

(d) Key Management and Protection: Comprehensive cryptographic key management including secure key generation, storage, rotation, and destruction with hardware security modules and appropriate key lifecycle management ensuring encryption effectiveness and security.

6.01.2 Data Loss Prevention and Protection

(a) Content Discovery and Classification: Systematic identification and classification of PHI across all systems and storage locations with automated discovery tools and classification procedures ensuring comprehensive data protection and appropriate security control application.

(b) Data Loss Prevention Systems: Advanced DLP solutions monitoring PHI movement, preventing unauthorized transmission, and enforcing data handling policies with real-time blocking capabilities and comprehensive reporting supporting data protection and compliance objectives.

(c) Email and Communication Security: Secure email systems with encryption, digital signatures, and content filtering ensuring PHI protection in email communications with appropriate controls for internal and external communication security.

Section 6.02 Backup and Recovery Systems

6.02.1 Data Backup and Protection

(a) Comprehensive Backup Strategy: Regular automated backups of all PHI systems and data with geographically distributed storage, encryption protection, and regular restoration testing ensuring data availability and recovery capability during system failures or disasters.

(b) Backup Security and Access Control: Secure backup storage with encryption, access controls, and monitoring systems preventing unauthorized access to backup data while ensuring legitimate recovery operations and business continuity capabilities.

(c) Recovery Testing and Validation: Regular testing of backup and recovery procedures including full system restoration tests, data integrity validation, and recovery time assessment ensuring reliable recovery capabilities and business continuity effectiveness.

(d) Disaster Recovery and Business Continuity: Comprehensive disaster recovery procedures including alternate processing sites, emergency operations procedures, and stakeholder communication ensuring continued PHI protection and healthcare service support during emergencies.

ARTICLE VII. BREACH PREVENTION AND INCIDENT RESPONSE

Section 7.01 Incident Response Framework

7.01.1 HIPAA Incident Classification and Response

(a) Breach Identification and Assessment: Systematic procedures for identifying potential HIPAA breaches including automated detection systems, employee reporting procedures, and comprehensive assessment criteria determining breach classification and response requirements under HIPAA Breach Notification Rule.

(b) Immediate Response and Containment: Rapid response protocols for containing PHI breaches including immediate system isolation, evidence preservation, impact assessment, and stakeholder notification ensuring prompt breach response and harm mitigation.

(c) Investigation and Documentation: Comprehensive breach investigation procedures including forensic analysis, impact assessment, root cause determination, and detailed documentation supporting regulatory reporting and corrective action development.

(d) Notification and Reporting: Systematic breach notification procedures including covered entity notification within required timeframes, regulatory reporting as applicable, and affected individual notification support ensuring compliance with HIPAA notification requirements.

7.01.2 Risk Assessment and Impact Analysis

(a) Breach Risk Assessment Framework: Comprehensive risk assessment methodology evaluating likelihood of PHI compromise, extent of disclosure, nature of compromised information, and potential for harm using established criteria and systematic evaluation procedures.

(b) Harm Assessment and Mitigation: Evaluation of potential harm to individuals including identity theft risk, embarrassment potential, discrimination possibilities, and other adverse consequences with development of appropriate mitigation measures and support services.

(c) Regulatory Impact Assessment: Assessment of regulatory implications including reporting requirements, potential enforcement actions, and compliance obligations with appropriate legal counsel involvement and regulatory relationship management.

Section 7.02 Corrective Action and Prevention Enhancement

7.02.1 Immediate Corrective Measures

(a) System Security Enhancement: Implementation of immediate security improvements addressing identified vulnerabilities including access control strengthening, monitoring enhancement, and technical control implementation preventing similar incidents.

(b) Process Improvement and Training: Enhanced policies, procedures, and training programs addressing human factors contributing to incidents with improved awareness, competency development, and behavior modification supporting breach prevention objectives.

(c) Workforce Management and Accountability: Appropriate workforce actions including additional training, disciplinary measures, and accountability enforcement ensuring individual responsibility for PHI protection and organizational compliance expectations.

7.02.2 Long-Term Prevention Enhancement

(a) Systematic Prevention Improvement: Comprehensive analysis of incident patterns, systemic vulnerabilities, and prevention opportunities with implementation of enhanced controls, monitoring systems, and prevention measures addressing underlying risk factors.

(b) Technology Enhancement and Investment: Strategic technology improvements including security system upgrades, monitoring capability enhancement, and prevention technology implementation supporting long-term breach prevention and security improvement objectives.

(c) Cultural Development and Awareness: Organizational culture development emphasizing privacy protection, security awareness, and individual accountability with comprehensive awareness programs and leadership demonstration supporting sustained compliance and protection objectives.

ARTICLE VIII. BUSINESS ASSOCIATE MANAGEMENT

Section 8.01 Downstream Business Associate Requirements

8.01.1 Subcontractor Due Diligence and Assessment

(a) HIPAA Compliance Assessment: Comprehensive evaluation of potential Business Associates including HIPAA compliance capabilities, security infrastructure, privacy policies, and demonstrated commitment to healthcare information protection through systematic due diligence procedures.

(b) Security and Privacy Evaluation: Technical assessment of security controls, privacy protection measures, incident response capabilities, and compliance monitoring systems ensuring adequate protection for PHI processing and handling activities.

(c) Financial Stability and Business Continuity: Assessment of financial health, business stability, and continuity planning ensuring reliable service delivery and sustained PHI protection throughout anticipated business relationship duration.

(d) Reference and Performance Validation: Verification of HIPAA compliance performance through client references, industry reputation, and demonstrated track record in healthcare information protection with validation of compliance capabilities and performance history.

8.01.2 Business Associate Agreement Management

(a) Comprehensive Contract Requirements: Implementation of Business Associate Agreements meeting HIPAA requirements including permitted uses and disclosures, safeguard implementation, breach notification, and return or destruction of PHI with appropriate legal protections and compliance obligations.

(b) Ongoing Compliance Monitoring: Systematic monitoring of Business Associate compliance including regular assessments, performance reviews, and validation of continued HIPAA compliance with prompt corrective action for identified deficiencies or non-compliance.

(c) Audit Rights and Oversight: Contractual audit rights and oversight capabilities enabling verification of Business Associate compliance with HIPAA requirements and contractual obligations through independent assessment and validation procedures.

(d) Termination and Transition Procedures: Clear procedures for Business Associate relationship termination including PHI return or destruction, transition planning, and continuing obligations ensuring appropriate PHI protection throughout relationship lifecycle.

ARTICLE IX. TRAINING AND WORKFORCE DEVELOPMENT

Section 9.01 Comprehensive HIPAA Training Program

9.01.1 General Workforce Training

(a) Initial HIPAA Training: Comprehensive training for all workforce members covering HIPAA Privacy and Security Rules, organizational policies and procedures, individual responsibilities, and consequences of non-compliance with appropriate competency assessment and certification.

(b) Annual Refresher Training: Regular training updates covering regulatory changes, policy updates, emerging threats, and lessons learned from incidents with ongoing competency development and awareness enhancement supporting sustained compliance and protection effectiveness.

(c) Role-Specific Training: Specialized training programs addressing specific job responsibilities, PHI access requirements, and functional obligations with tailored content, practical scenarios, and competency validation ensuring appropriate knowledge and skills for PHI handling.

(d) New Employee Onboarding: Comprehensive HIPAA training integration into new employee onboarding including policy review, competency assessment, and certification before PHI access authorization ensuring appropriate preparation and compliance understanding.

9.01.2 Specialized Training Programs

(a) IT and Security Personnel: Advanced training for technical personnel covering HIPAA Security Rule requirements, technical safeguard implementation, incident response procedures, and security technology management with specialized technical knowledge and competency development.

(b) Management and Leadership: Leadership training covering HIPAA compliance oversight responsibilities, workforce management obligations, incident response coordination, and accountability frameworks with management-specific knowledge and capability development.

(c) Business Associate Management: Specialized training for personnel managing Business Associate relationships covering contract requirements, compliance monitoring, oversight procedures, and relationship management with specific competency development for third-party management.

Section 9.02 Training Effectiveness and Continuous Improvement

9.02.1 Training Assessment and Validation

(a) Competency Testing and Certification: Systematic testing of HIPAA knowledge and competency with appropriate certification requirements and performance standards ensuring adequate understanding and capability for PHI handling and protection responsibilities.

(b) Practical Application and Scenario Training: Hands-on training using realistic scenarios, case studies, and practical exercises with competency demonstration and skill development ensuring effective application of HIPAA knowledge in operational situations.

(c) Performance Monitoring and Feedback: Ongoing monitoring of training effectiveness through performance observation, incident analysis, and competency assessment with feedback and additional training as necessary supporting continuous improvement and effectiveness enhancement.

9.02.2 Training Program Enhancement

(a) Regulatory Update Integration: Regular incorporation of regulatory changes, guidance updates, and industry developments into training programs ensuring current knowledge and compliance with evolving HIPAA requirements and expectations.

(b) Incident Learning Integration: Integration of lessons learned from HIPAA incidents, investigations, and corrective actions into training programs with practical examples and prevention strategies supporting improved awareness and incident prevention.

(c) Industry Best Practice Integration: Incorporation of industry best practices, emerging trends, and advanced protection techniques into training programs ensuring leading-edge knowledge and capability development supporting compliance excellence and competitive advantage.

ARTICLE X. PERFORMANCE MEASUREMENT AND CONTINUOUS IMPROVEMENT

Section 10.01 HIPAA Compliance Metrics and Monitoring

10.01.1 Compliance Performance Indicators

(a) Training Completion and Competency: Measurement of training completion rates, competency assessment results, and knowledge retention across all workforce categories with tracking of training effectiveness and continuous improvement in HIPAA awareness and capability.

(b) Access Control and Authentication: Monitoring of access control effectiveness, authentication success rates, unauthorized access attempts, and access review completion with assessment of access control system performance and security effectiveness.

(c) Incident Prevention and Response: Tracking of incident frequency, response times, resolution effectiveness, and prevention success with measurement of incident management capability and continuous improvement in breach prevention and response effectiveness.

(d) Audit and Monitoring Coverage: Assessment of audit coverage, monitoring system effectiveness, compliance validation results, and corrective action completion with evaluation of oversight capability and compliance assurance effectiveness.

10.01.2 Security and Privacy Performance

(a) System Security and Availability: Monitoring of system uptime, security incident frequency, vulnerability management effectiveness, and security control performance with assessment of technical safeguard effectiveness and system reliability.

(b) Data Protection and Encryption: Evaluation of encryption coverage, data loss prevention effectiveness, backup system reliability, and data protection measure performance with assessment of data security and protection capability.

(c) Privacy Protection and Individual Rights: Monitoring of privacy request processing, individual rights fulfillment, complaint resolution, and privacy protection effectiveness with assessment of privacy program performance and individual protection capability.

Section 10.02 Regular Assessment and Audit Programs

10.02.1 Internal Compliance Assessment

(a) Self-Assessment and Internal Audit: Regular internal assessment of HIPAA compliance including policy adherence, control effectiveness, and performance against requirements with systematic evaluation and improvement opportunity identification.

(b) Management Review and Oversight: Regular management review of HIPAA compliance program performance including metrics analysis, trend identification, and strategic direction with appropriate resource allocation and enhancement decision-making.

(c) Risk Assessment and Management: Periodic assessment of HIPAA compliance risks including vulnerability identification, threat analysis, and risk mitigation effectiveness with continuous improvement in risk management and protection capabilities.

10.02.2 External Validation and Assessment

(a) Independent HIPAA Assessment: Engagement of qualified external assessors for independent evaluation of HIPAA compliance including control testing, policy review, and compliance validation with objective assessment and improvement recommendations.

(b) Penetration Testing and Vulnerability Assessment: Regular security testing including penetration testing, vulnerability scanning, and security control validation with identification of security gaps and improvement requirements.

(c) Compliance Audit and Certification: Formal compliance audits by qualified auditors with appropriate documentation, evidence collection, and compliance validation supporting regulatory compliance and stakeholder assurance.

Section 10.03 Continuous Improvement and Enhancement

10.03.1 Performance Enhancement Initiatives

(a) Process Improvement and Optimization: Systematic improvement of HIPAA compliance processes including efficiency enhancement, effectiveness improvement, and resource optimization with continuous refinement and enhancement of compliance capabilities.

(b) Technology Enhancement and Innovation: Strategic investment in technology improvements including security system upgrades, automation enhancement, and innovative solutions supporting compliance effectiveness and operational efficiency.

(c) Workforce Development and Capability Building: Ongoing investment in workforce development including training enhancement, competency development, and career advancement supporting sustained compliance capability and organizational excellence.

ARTICLE XI. CONTACT INFORMATION AND COMPLIANCE SUPPORT

Section 11.01 HIPAA Compliance Leadership

HIPAA Security Officer
Technology Officer
Assivo, Inc.
444 West Lake Street, Suite 1700
Chicago, Illinois 60606
Telephone: (312) 416-8649
Email: security@assivo.com

HIPAA Privacy Officer
General Counsel
Email: privacy@assivo.com
Telephone: (312) 416-8649

Section 11.02 HIPAA Incident Reporting and Response

HIPAA Incident Response Team
24/7 Incident Response: (312) 416-8649
Email: security@assivo.com
Privacy Incidents: privacy@assivo.com

Section 11.03 Regional HIPAA Coordination

Regional HIPAA Compliance Support:

Americas Operations: americas@assivo.com
Mexico Operations: mexico@assivo.com
India Operations: india@assivo.com

Section 11.04 Business Associate Services and Support

For Business Associate Agreement inquiries, compliance verification, and healthcare service delivery coordination, please contact our HIPAA Compliance team through the primary contact information provided above.

This HIPAA Compliance Framework represents our comprehensive commitment to protecting healthcare information and maintaining the highest standards of privacy and security in healthcare service delivery. It serves as the foundation for our healthcare compliance program and should be implemented alongside applicable healthcare regulations, industry standards, and contractual requirements to ensure comprehensive healthcare information protection and regulatory compliance excellence.