Security Officer

164.308(a)(1) Administrative Safeguards High Risk Moderate

A covered entity must designate a security official who is responsible for developing and implementing its security policies and procedures.

Implementation Guidance

Designate a qualified individual as the Security Officer with clear responsibilities including:
• Developing and implementing security policies and procedures
• Conducting regular security risk assessments
• Managing security incidents and breaches
• Ensuring workforce training on security policies
• Monitoring compliance with security requirements
• Coordinating with other departments on security matters

The Security Officer should have appropriate authority, resources, and reporting structure to effectively carry out these responsibilities.

NIST References

NIST SP 800-66 Rev. 2: Section 3.1.1
NIST Cybersecurity Framework: ID.AM-6, PR.IP-1
NIST SP 800-53: AC-2, AC-3, AC-5, AC-6, AC-7, AC-8, AC-9, AC-10, AC-11, AC-12, AC-13, AC-14, AC-15, AC-16, AC-17, AC-18, AC-19, AC-20, AC-21, AC-22

Best Practices

• Ensure Security Officer has appropriate technical and administrative background
• Establish clear reporting structure to senior management
• Provide ongoing training and professional development
• Document all security-related decisions and actions
• Regular communication with workforce about security matters
• Coordinate with Privacy Officer and other compliance personnel

Testing Procedures

• Verify Security Officer designation is documented
• Review Security Officer job description and responsibilities
• Confirm Security Officer has appropriate authority and resources
• Test Security Officer knowledge through interviews or assessments
• Review documentation of security policy development and implementation
• Verify regular review and update of security policies

Frequently Asked Questions

Q: Can the Security Officer also be the Privacy Officer?
A: Yes, the same person can serve as both Security Officer and Privacy Officer, but they must have appropriate qualifications for both roles.

Q: What qualifications should a Security Officer have?
A: The Security Officer should have appropriate technical knowledge, administrative skills, and understanding of HIPAA requirements. Formal security certifications are recommended.

Q: How often should security policies be reviewed?
A: Security policies should be reviewed at least annually, or more frequently if there are significant changes in technology, threats, or business operations.

Control Information

Control ID:
164.308(a)(1)
Category:
Administrative Safeguards
Subcategory:
Security Management Process
Risk Level:
High
Implementation Difficulty:
Moderate
Estimated Cost:
Medium
Implementation Timeframe:
1-3 months
Views:
16
Last Updated:
Sep 28, 2025

Related Controls

Additional Resources

• NIST SP 800-66 Rev. 2: An Introductory Resource Guide for Implementing the HIPAA Security Rule
• HHS Security Rule Guidance: https://www.hhs.gov/hipaa/for-professionals/security/index.html
• Security Officer Training Programs
• HIPAA Security Rule Compliance Checklist
• Sample Security Officer Job Description