Unique User Identification Policy (UBIT HIPAA)

Category: HIPAA Security
Responsible Office: UBIT HIPAA Compliance
Responsible Executive: Vice President and Chief Information Officer (VPCIO)
Approved By (Name/Title): J. Brice Bible, VPCIO

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CATEGORY: Technical Safeguards
TYPE: Standard
45 CFR 164.312(a)(2)(i)

The University at Buffalo Information Technology (UBIT) operates as a covered entity as defined by the U.S. Department of Health and Human Services Office of Civil Rights. HIPAA Regulation Text 45 CFR Part 164.312(a)(2) requires a covered entity to implement technical policies and procedures for electronic information systems that maintain electronic protected health information to allow access to those persons or software programs that have been granted access rights as specified in 164.308 (a)(4) Information Access Management.


UBIT assigns unique user identifiers (user IDs) that identify workforce members, enable activities performed on ePHI Systems with user identifiers to be traced to an individual workforce member, and provide access to ePHI Systems.


This policy applies to all UBIT workforce members.


Workforce members: Adhere to all policies and procedures as written.

HIPAA Security and Privacy Officer: Ensures that whenever possible, a unique name and/or number for identifying and tracking user identity is used in ePHI systems.

Compliance Officer: Participates in ensuring the security of ePHI is effective and enforced, in conjunction with the HIPAA Security and Privacy Officer.

Contact Information

HIPAA Security and Privacy Officer
Website: http://www.buffalo.edu/ubit.html

Vice President and Chief Information Officer
J. Brice Bible
517 Capen Hall
Buffalo, NY 14260
Phone: 716-645-7979
Email: vpcio@buffalo.edu
Website: http://www.buffalo.edu/ubit.html

Date Approved: 12/4/2017