20 3rd Party Policy
EA makes every effort to assure all 3rd party organizations are compliant and do not compromise the integrity, security, and privacy of EA or EA Customer data. 3rd Parties include Customers, Partners, Subcontractors, and Contracted Developers.
20.1 Policies to Assure 3rd Parties Support EA Compliance
- EA does not allow 3rd party access to production systems containing ePHI.
- All connections and data in transit between the EA Platform and 3rd parties are encrypted end to end.
- A standard agreement with Customers and Partners is defined and includes the required security controls in accordance with the organization’s security policies. Additionally, responsibility is assigned in these agreements.
- EA has Service Level Agreements (SLAs) with Subcontractors with an agreed service arrangement addressing liability, service definitions, security controls, and aspects of services management.
- Subcontractors must coordinate, manage, and communicate any changes to services provided to EA.
- Changes to 3rd party services are classified as configuration management changes and thus are subject to the policies and procedures described in Section 8; substantial changes to services provided by 3rd parties will invoke a Risk Assessment as described in Section 3.2.1.
- EA utilizes monitoring tools to regularly evaluate Subcontractors against relevant SLAs.
- No EA Customers or Partners have access outside of their own environment, meaning they cannot access, modify, or delete anything related to other 3rd parties.
- EA does not outsource software development.
- EA maintains and annually reviews a list all current Partners and Subcontractors.
- The list of current Partners and Subcontractors is maintained by the EA Privacy Officer, includes details on all provided services (along with contact information).
- The annual review of Partners and Subcontractors is conducted as a part of the security, compliance, and SLA review referenced below.
- EA assesses security, compliance, and SLA requirements and considerations with all Partners and Subcontractors. This includes annual assessment of SOC2 Reports for all EA infrastructure partners.
- EA leverages recurring calendar invites to assure reviews of all 3rd party services are performed annually. These reviews are performed by the EA Security Officer and Privacy Officer. The process for reviewing 3rd party services is outlined below:
- The Security Officer initiates the SLA review by creating an Issue in the Asana Compliance Review Activity (CRA) Project.
- The Security Officer, or Privacy Officer, is assigned to review the SLA and performance of 3rd parties. The list of current 3rd parties, including contact information, is also reviewed to assure it is up to date and complete.
- SLA, security, and compliance performance is documented in the Issue.
- Once the review is completed and documented, the Security Officer approves or rejects the Issue. If the Issue is rejected, it goes back for further review and documentation.
- Regular review is conducted as required by SLAs to assure security and compliance. These reviews include reports, audit trails, security events, operational issues, failures and disruptions, and identified issues are investigated and resolved in a reasonable and timely manner.
- Any changes to Partner and Subcontractor services and systems are reviewed before implementation.
- For all partners, EA reviews activity annually to assure partners are in line with SLAs in contracts with EA.
- SLA review is monitored on a quarterly basis using Asana reporting to assess compliance with above policy.