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Subject:
From:
Larry Medina <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Wed, 30 Nov 2011 13:53:04 -0500
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Okay so this is a weird one and it doesn't leave me with a very warm and
fuzzy feeling.

"Iron Mountain today announced a secure cloud-based archive service for
medical data based on NetApp's grid-architecture, object-based, storage
software." 

First cloud-based < secure , check?

I think this has clearly been demonstrated in a few key cases and if I was a
healthcare provider putting HIPAA impacted data into this cauldron, I'd be
DAMN SURE I had a Business Associates Agreement for third party indemnity in
place and would SCOUR the T&C to make sure you know what makes this
"secure".  If they say it is, are they accepting 100% of the liability, with
NO limits? Do you have that in WRITING?

"...with two Iron Mountain medical data archiving services: the Digital
Record Center for Medical Images and its vendor neutral archive offering."

Second Digital records =/= Iron Mountain 

Just this past April, IM announced it was ABANDONING the use of cloud based
services http://goo.gl/mZK78 and NOW they are touting the offering AND
calling it secure?  What did I miss?  Cloud BAD... NO!! Cloud GOOD!!! ???

Third required policy is met through a contract?

"Iron Mountain said that a cloud-based archive allows organizations to meet
current HIPAA compliance standards that require a disaster recovery plan and
policies for protecting that data."

HIPAA requires that a COVERED ENTITY must meet the compliance requirements
for protection and disaster recovery- and I get that you can have a
contractual arrangement to assist you in meeting those, but THE ENTITY is
the one on the hook, so again I refer you to #1.  

""Iron Mountain's medical image archiving offerings deliver the best of all
worlds..."

Fourth how can you offer what you've shut down?

This article clearly states that IM is discontinuing the "Archive Storage
Platform" http://goo.gl/IV5tb  again I ask, did I miss something?

I dunno this seems like a rather questionable offering to me- if you have a
medical provider that is considering a move into the EMR/EHR arena OR if you
work for one that is, you may want to give them a heads up and suggest they
find out which IM Digital they're talking to- the one who bowed out of this
service arena in April 2011 or the one that's selling themselves as the best
thing since bottled beer in Nov 2011.

Larry
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