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3rd_party_policy.md

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3rd Party Policy

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

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

Applicable Standards from the HIPAA Security Rule

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

Policies to Assure 3rd Parties Support Pact Compliance

  1. The following steps are required before 3rd parties are granted access to any Pact systems:
    • Due diligence with the 3rd party;
    • Controls implemented to maintain compliance;
    • Written agreements, with appropriate security requirements, are executed.
  2. All connections and data in transit between the Pact System and 3rd parties are encrypted end to end.
  3. Access granted to external parties is limited to the minimum necessary and granted only for the duration required.
  4. 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.
  5. Pact has Service Level Agreements (SLAs) with Subcontractors with an agreed service arrangement addressing liability, service definitions, security controls, and aspects of services management.
    • Pact utilizes monitoring tools to regularly evaluate Subcontractors against relevant SLAs.
  6. Third parties are unable to make changes to any Pact infrastructure without explicit permission from Pact. Additionally, no Pact Customers or Partners have access outside of their own environment, meaning they cannot access, modify, or delete anything related to other 3rd parties.
  7. Whenever outsourced development is utilized by Pact, all changes to production systems will be approved and implemented by Pact workforce members only. All outsourced development requires a formal contract with Pact.
  8. Pact maintains and annually reviews a list all current Partners and Subcontractors.
  9. Pact assesses security requirements and compliance considerations with all Partners and Subcontracts.
  10. 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.
  11. Any changes to Partner and Subcontractor services and systems are reviewed before implementation.
  12. For all partners, Pact reviews activity annually to assure partners are in line with SLAs in contracts with Pact.