In order to review an app for internal distribution, a mobile app must first be distributed to the internal Emory reviewers using the Emory Mobile App Catalog. Complete the Internal Mobile App Distribution Request Form to start the process. A mobile app can usually be distributed internally to a restricted group in two or three days from the time of the request. Distribution to a large internal audience usually take two to three weeks to complete the internal review process, and distribution on public marketplaces may take several weeks to several months depending on the complexity of the app and the compliance and commercial implications of the app.
Emory Library and Information Technology (LITS) performs a high-level technical review of the application to determine if there is a need for any detailed security and compliance reviews of the application. For example, if the application collects and stores ePHI, credit card information, or other compliance related data, Emory LITS will inform the owners of the application of relevant policies and any practices required by those policies. See the template for this cursory review. LITS will create a copy of the review template specifically for the requested application review and ensure the application owners have access to the template to complete the information. LITS staff will help complete this template as needed.
Emory University and Emory Healthcare compliance officers review the mobile application to determine whether or not Emory's HIPAA compliance or other appropriate compliance policies apply. Emory's compliance officers provide the following general guidance in determining whether or not HIPAA applies to a mobile application:
Using the answers to the mobile app security questions, Emory LITS performs a high-level technical review of the application to determine if there is a need for any detailed security and compliance reviews of the application. For example, if the application collects and stores ePHI, credit card information, or other compliance related data, Emory LITS will inform the owners of the application of relevant policies and any practices required by those policies. Additional materials may be required, depending on the type of review specified. The organizer of the technical review team will contact application developers and help them prepare any additional materials.
If an in-depth security review is required, a meeting is scheduled with representatives of Emory Information Security to walk through a mobile app security checklist based on the security, compliance, and regulatory requirements that are relevant to the particular application.
For subsequent application updates, application owners should update the technical review template and if there are substantial changes, request another review. For example, if the nature of the data being collected or stored by the application has changed and now ePHI is being collected when it was not before, then a new review should be scheduled. Application owners should also update the internal submission forms relevant to their applications for each subsequent submission.
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