CONS-02

Has the consultant received training on (sensitive, HIPAA, PCI, etc.) data handling?

Explanation

This question is asking whether consultants who may have access to sensitive data have received formal training on how to properly handle that data according to relevant regulations and standards. Specifically, it mentions HIPAA (Health Insurance Portability and Accountability Act), which governs protected health information, and PCI DSS (Payment Card Industry Data Security Standard), which governs payment card data. This question is important in a security assessment because consultants often have privileged access to systems and data but are not permanent employees. Without proper training, consultants might inadvertently mishandle sensitive data, leading to data breaches, compliance violations, and potential legal consequences. Organizations need to ensure that anyone handling sensitive data understands the specific requirements and restrictions that apply. To best answer this question, you should: 1. Clearly state whether consultants receive training on handling sensitive data 2. Specify what types of data handling training are provided (HIPAA, PCI, etc.) 3. Describe the training process (frequency, format, certification) 4. Mention how training completion is tracked and verified 5. Note any additional measures taken to ensure consultants understand their data handling responsibilities

Example Responses

Example Response 1

Yes, all consultants who may access sensitive data receive mandatory training before being granted system access Our training program includes modules specific to the type of data they will handle: HIPAA training for those accessing PHI, PCI DSS training for those handling payment card data, and general sensitive data handling for all consultants Training is delivered through our learning management system with knowledge checks throughout and a comprehensive assessment at the end Consultants must achieve a minimum score of 85% to pass Training is renewed annually, and completion records are maintained in our compliance tracking system Additionally, all consultants sign data handling agreements that outline their specific responsibilities based on the data types they will access.

Example Response 2

Yes, our consulting team undergoes a comprehensive onboarding process that includes specialized training on sensitive data handling protocols For consultants who will access regulated data, we provide role-specific training: HIPAA compliance training (4 hours) for those handling PHI, PCI DSS training (3 hours) for payment card data access, and GDPR training (2 hours) for those handling EU citizen data All training is conducted by our compliance team through instructor-led sessions, followed by scenario-based assessments Training is refreshed quarterly through micro-learning modules, and consultants must re-certify annually We maintain training logs that are reviewed during our quarterly compliance audits and can provide redacted training completion records upon request.

Example Response 3

No, we do not currently have a formal training program specifically for consultants on handling sensitive data like HIPAA or PCI information Our consultants are expected to follow our general security policies, and we include confidentiality clauses in our consulting agreements We do provide our standard security awareness training to all consultants, but this does not include specific modules on regulatory compliance for sensitive data handling We recognize this as a gap in our security program and are currently developing role-specific training modules for consultants who may access regulated data types We expect to implement this training within the next quarter and would be happy to provide updates on our progress.

Context

Tab: Case-Specific
Category: Consulting Services