Dermi Atlas Professional is an on-premises deployment: clinical photographs, clinical notes, and patient information stay on a computer the practice owns, under the practice's control.
This article gives an overview of how Dermi Atlas Professional is designed to support a practice's obligations under healthcare privacy law, including HIPAA (United States), PIPEDA (Canada), and the Privacy Act 1988 (Australia). A guide for each jurisdiction is linked at the end.
The On-Premises Model
Because the software runs on the practice network, patient health information is not sent to Dermi and Dermi does not store it. The software gives Dermi no remote access to the deployment.
Data stored on the host computer (practice responsibility):
- Patient photographs and clinical images
- Patient demographic information and clinical notes
- Consent records
- The audit log
- Team member accounts and their passwords
- Backups
Data processed by Dermi (vendor responsibility): license and account administration data, such as license checks, team membership, account emails with the requesting device's details, installation details, and diagnostics the operator chooses to send, none of which includes patient data. The complete list is in Data Security Architecture.
Dermi's role and the data it processes are set out in the Dermi Privacy Policy, the Dermi Atlas Professional EULA, and the Dermi Sub-Processors document. The practice's privacy officer or legal counsel makes the resulting determination under the law that applies to the practice.
Compliance Support Features
Dermi Atlas Professional provides technical controls that support the administrative, technical, and physical safeguards the practice puts in place.
Access Control
- Individual accounts: Each team member signs in under a named individual account, created only by claiming an invitation issued from Dermi Portal. Every action is recorded under the person who performed it.
- Account types: Clinical records belong to the practice team and are available to every member of it. Export, deletion, recovery, and patient identity edits are Clinician actions and are refused to Assistant accounts; the complete list is in Account Types and Permissions.
- Strong authentication: Password complexity is enforced, and two-factor authentication is available with recovery codes.
- Session management: Each member sees the devices their account is signed in on under Signed-In Devices, and can sign out one device or every device with Sign Out Everywhere. A session ends after seven days without activity.
- Immediate removal: An account is disabled at once from the Administration area of Dermi Atlas Manager, which is protected by an admin passphrase kept on the host computer.
Audit and Accountability
- Activity logging: Sign-in, account security, and administration events are always recorded. Under the Comprehensive level, the default, every access to and change of a patient record is recorded as well.
- Granular history: Each entry records the time, the acting account, the operation, the affected record, and the before and after values where applicable. Sign-in and account events also record the IP address, user agent, and timezone.
- Local storage: The audit log is stored on the host computer and is included in every backup.
Data Protection
- Encryption in transit: Connections on the HTTPS address are encrypted with TLS 1.2 or TLS 1.3, using a certificate the deployment generates for the host computer. The HTTP address is unencrypted; HTTPS is recommended wherever the network includes Wi-Fi or is shared.
- Deletion policy: The Data Deletion Policy (Recoverable, Standard, or Permanent) and the retention period decide how long deleted records remain recoverable and what happens to their activity logs. See Configuring Data Retention for Deleted Records.
- Deployment isolation: Each deployment holds exactly one practice team, and its clinical records are reachable only by the members of that team signing in on that deployment. Dermi Portal holds membership (name, username, email address, and account type) and no clinical data.
Consent Tools
- Consent enforcement level: A setting of each account, chosen in the Patient Consent for Clinical Photography card on the Preferences page: Disabled (the default), Advisory, or Required.
- Consent records: A digital signature from the patient, or a clinician's record of written or verbal consent obtained outside the software. See Clinical Image Consent.
Shared Responsibility Model
Dermi provides the software; compliance is a shared responsibility.
Dermi's responsibility:
- Maintaining the software and publishing updates, including security fixes, for delivery through Dermi Atlas Manager.
- Securing the administrative services it operates (billing, licensing, and account services).
The software is licensed under the Dermi Atlas Professional EULA.
Practice responsibility:
- Physical security: Securing the computer that runs Dermi Atlas Professional and enabling full-disk encryption on it.
- Network security: Configuring firewalls and securing the practice network, including Wi-Fi.
- Access management: Inviting team members from Dermi Portal with the correct account type, reviewing membership periodically, and removing a member when a staff member leaves.
- Backups: Creating backups regularly and keeping exported copies encrypted and off site, since backups are not encrypted by the software. See Backing Up and Restoring Dermi Atlas Professional.
- Policy and procedure: Establishing and enforcing the practice's own privacy policies, consent forms, and breach procedures.
Dermi Atlas Professional is designed to support compliance; compliance itself depends on how the practice configures the software, secures the host computer, and enforces its policies. This article is not legal advice.
Related Documentation