ISC2 Governance, Risk and Compliance (CGRC) Practice Question
A hospital is documenting handling requirements for a new telehealth platform that will store and transmit patients' laboratory results, diagnoses and billing information. To satisfy HIPAA requirements for protected health information, which statement about encryption must the security team include in the system documentation?
The Security Rule treats encryption as an addressable safeguard; the organization must either implement it or document and justify an alternative control if encryption is not reasonable and appropriate.
Encryption decisions for PHI are left entirely to individual patients; covered entities have no specific obligations under HIPAA.
Encryption of PHI in transit is required, but encryption at rest is optional and needs no justification if omitted.
AES-256 encryption of all PHI, both in transit and at rest, is a non-negotiable HIPAA mandate for covered entities.
The HIPAA Security Rule lists encryption for PHI as an addressable, not a required, implementation specification at 45 CFR 164.312(a)(2)(iv) and 164.312(e)(2)(ii). Covered entities must implement encryption if it is reasonable and appropriate for their environment; if they choose not to encrypt, they must formally document the decision and apply compensating controls that provide an equivalent level of protection. Stating encryption is categorically mandatory or wholly optional without analysis misrepresents the rule. Deferring the decision to patients or insisting on a specific algorithm such as AES-256 is also inaccurate because HIPAA is technology-neutral and leaves algorithm selection to the organization's risk analysis.
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ISC2 Governance, Risk and Compliance (CGRC)
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