How access, records, and operations fit together.

What we do so the record holds: encryption, role separation, an append-only log — and an export a regulator accepts. Every control names the clause it implements.

Evidence export
Patient
PT-04182
Range
2024-01-01 → 2026-09-17
Users
All (7)
Rows
1,284
oipc-export-PT-04182.zip
SHA-256

Per patient, per user, per time range — with no spreadsheet in the middle.

Identity and access control.

Unique accounts, a second factor on every new device, timed sessions and roles the custodian configures without engineering.

Unique accounts

No shared logins, ever. Each user has one account, traceable to one person — and every action carries that name.

CCOA SP 5.5 #1–2 · AEHRR §6

Second factor on new devices

The first login from a new device requires a second factor before the device is trusted. Missing enrolments surface in the daily check.

CCOA SP 5.5 #4

Idle timeout and lockout

Idle sessions end automatically after a per-clinic configured period. Repeated failed logins lock the account and notify the custodian.

CCOA SP 5.5 #4

Role-based access

Permissions attach to roles, roles to people. The custodian configures them; every change is logged with before and after.

CCOA SP 5.5 #3

Role-scoped sensitivity

Clinical detail of flags, boundaries and fitness-to-practice records is visible to clinical or disclosure roles only. Reception sees the operational impact.

HIA §18 · least amount

Bound signatures

Every electronic signature is bound to identity, timestamp and content hash. A later edit requires a new signature and preserves the prior version.

CCOA SP 5.5 #6

Encrypted, backed up, restorable.

The controls that make every other privacy claim verifiable — with evidence producible on request.

Encryption in transit and at rest

No cleartext fallback on the wire; databases, file storage and backups encrypted, keys held separately and rotated on a schedule.

CCOA SP 5.5 #4, #7 · HIA §60

Backups that get restored

Backups are checksummed at write time and again at restore. A quarterly recovery test is logged with operator, recovery time and recovery point.

CCOA SP 5.5 #8–9

Integrity alert

Changes to stored records outside the application path are detected and reported; signed versions stay verifiable against their content.

CCOA SP 5.5 #10

Data residency per clinic

Storage and processing are pinned to a named region and documented in the clinic’s record. Moving it requires the custodian’s consent.

HIA · custodian duty

Disposal attestations

Every medium that held health information carries a disposal or secure-erase attestation; local offline caches become unreadable on sign-out.

CCOA SP 5.5 #12

Daily check

Key rotation due, backup failures, overdue restore drills and MFA gaps appear in the compliance hub every day — not at the next audit.

CCOA SP 5.5 #9

Records and evidence.

Append-only audit log, retention floor per chart, a disclosure log per patient — built into the platform, not bolted on.

Append-only audit log

Every authentication, authorisation, record access, export, print and administrative change is logged immutably. An attempt to tamper is itself recorded.

AEHRR §6 · CCOA SP 5.5 #5

Retention floor on the record

Computed from SP 5.4 and enforced at the record. Deletion before the floor is blocked; destruction after it leaves an attestation.

CCOA SP 5.4

Audit export

Regulator-ready exports per patient, per user, per time range. A patient can obtain the disclosure history of their own record on request.

HIA §41

Disclosure log

Every disclosure to a third party needs an authorisation with effective and expiry dates, purpose, recipient and revocability — and lands in the patient’s log.

CCOA SP 5.7 · HIA §34–36

Secured channels only

Health information leaves the chart through a secured path. No path exists to SMS, messenger apps or social media.

CCOA SP 5.6

Information Manager Agreement

Signed before the first record, verified against every Appendix 4 component, versioned, and renewed before expiry.

HIA §66 · Appendix 4

Operational integrity.

Resilient under network and vendor disruption, with the continuity protocol the standard requires — and proven on a schedule.

Read-only fallback

When the primary application is unreachable, the last-synced chart stays accessible in a clearly labelled read-only mode.

CCOA SP 5.5 #11

Offline capture with reconciliation

Clinical notes are captured offline and reconciled on reconnect. Conflicts are shown, never silently overwritten.

CCOA SP 5.5 #11

Monthly chaos test

An automated test proves the fallback path end to end every month, before a real outage needs it.

CCOA SP 5.5 #11

Status page and support reference

Public status with incident history; every error screen carries a unique reference and the assurance that the incident has been logged.

CCOA SP 5.5 #11

Availability objective

A published chart-load objective, measured in production. Components below the objective surface in the daily check.

CCOA SP 5.5 #11

Onboarding gates

No health information is ingested without a bound regulatory authority, a signed IMA, a designated HIA officer and an approved PIA.

HIA §62 · §66 · OIPC PIA