A composed workstation policy shaped by your device posture, plus a per-asset check on whether every workstation, tablet, and phone has a current physical-safeguards attestation.
The rule was written for desks in offices. Your workstations include a tablet in a family’s living room and a phone an RBT texts parents from, and the definition does not care which picture came to mind first.
Your workstation policy is generated against your recorded facts and covers what counts as a device, proper use, where devices may be used, screen privacy, auto-lock and per-person login, network rules including public wifi, prohibited uses like personal cloud storage and pasting PHI into consumer AI tools, and lost or stolen device reporting.
Which devices may be used renders directly from your recorded device ownership posture, so the policy states your actual position rather than a generic one. Mobile and field activity pulls in clauses on securing devices away from the clinic. Shared workstations pull in a clause on per-account sign-in at shared machines.
Six requirements:
The second and third requirements work per device, not per clinic. Add a tablet without recording its safeguards and the control drops. Let an attestation age past a year and it drops for staleness, so the answer cannot quietly become a document from three years ago.
The attestation is a record you enter about a device, not a reading of the device. The system does not check whether a screen actually locks, whether a login is actually unique to one person, or whether encryption is switched on. It tracks whether you have said so, per device, recently.
What that gives you is a per-device answer instead of a blanket claim, and a clock on how stale that answer is allowed to get.
A dated, adopted policy naming your real device classes, including the ones that leave the building. A per-device record of physical safeguards, each with a date. Evidence that the field tablet was considered, which is the class most policies never mention.
The regulation: read the rule behind this control.
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