Skip to content

Security Awareness and Training

Last 1 Enterprises LLC / LastVet Safeguard category: Administrative HIPAA Security Rule citation: 45 CFR §164.308(a)(5) Status: Scaffold (Bucket 1c). Not approved for enforcement until Ryan review.


Document metadata

Field Value
Policy owner TODO (Ryan)
Version 0.1-scaffold
Effective date TODO (Ryan)
Review cadence Annual (TODO: Ryan confirm)
Approver TODO (Ryan)
Last reviewed 2026-08-26 (scaffold only)

1. Purpose

Implement a security awareness and training program for all workforce members.

2. Scope

All workforce with access to LastVet systems or ePHI.

3. Policy statements

  1. Workforce shall receive security awareness training at onboarding and periodically thereafter.
  2. Training shall cover phishing, password/credential hygiene, ePHI handling, incident reporting, and acceptable use.
  3. TODO (Ryan): Select training platform, frequency, and attestation storage.

4. Roles and responsibilities

Role Responsibility
Security Officer (Ryan) TODO (Ryan): assign formal Security Rule responsible person per §164.308(a)(2)
Workforce members TODO (Ryan): acknowledge policy when hired / annually
Contractors / BAs TODO (Ryan): flow-down via BAA and agreements

5. LastVet-specific context (from existing docs)

POSTURE.md notes social engineering as out-of-scope for purely technical controls. No formal training program documented yet.

7. Ryan TODO (substantive content deferred)

  • Define training content aligned with LastVet two-data-plane and consent model.
  • Document training records retention.
  • Provider-facing security expectations (separate from workforce?) — coordinate with WSGR provider agreement.