Asset Tracking and Secure Disposal for PHI Devices

Asset Tracking and Secure Disposal for Devices That Touch PHI

If you cannot clearly say where every copier and printer is, what it stores, and how it will be destroyed, you have a gap in your HIPAA story. Asset tracking and secure disposal close that gap.

The lifecycle problem with print devices

Copiers and printers move around more than most people realize:

• A device is installed in radiology, then later moved to billing

• A small MFP is brought in as a “temporary” backup and never removed

• An older device is replaced, but no one is sure whether its hard drive was wiped

Any device that stores or processes PHI is part of your risk landscape from the day it arrives until the day it permanently leaves your control.

Asset tracking for PHI-bearing devices

A strong asset tracking process answers three questions at any point in time:

1. Where is the device?

2. Who uses it?

3. Does it store or process PHI?

To support HIPAA requirements, Novatech helps clients:

• Build and maintain a detailed inventory of copiers and printers

• Clearly identify which devices handle PHI and which do not

• Track device moves between departments and physical locations

• Record security-relevant configuration details, such as encrypted storage

This inventory is more than a simple list. It becomes the foundation for risk assessments, incident response, and planning for upgrades, replacements, or consolidations.

Secure disposal and end-of-life handling

When a device is retired or returned, the core question is simple: what happens to any PHI that may be stored on it?

Acceptable answers typically include:

• Cryptographic wiping of internal storage following manufacturer and industry guidance

• Physical destruction of hard drives when required by policy or risk level

• Removal and secure handling of memory components that may store images or job data

In many healthcare environments, these steps must be documented and supported with proof, such as a certificate of destruction or a signed chain of custody.

Lease swaps and returns

Leased devices introduce additional complexity. At lease end, equipment may be returned to the manufacturer or transferred to a third party.

Novatech supports this process by:

• Documenting which devices are leaving and the PHI risk they carry

• Applying approved wiping or destruction procedures before return

• Coordinating with vendors to confirm how returned devices are handled

• Maintaining records that support HIPAA documentation and audit needs

The goal is simple: no device that ever handled PHI leaves your control without a clear, documented process.

How this supports HIPAA

Strong asset tracking and disposal practices help your organization:

• Maintain visibility into where PHI-related devices are at all times

• Reduce the risk of PHI exposure through forgotten or unmanaged hard drives

• Demonstrate responsible device lifecycle management to regulators

• Respond faster and more confidently when devices are lost, stolen, or involved in an incident

A missing device with an unknown configuration creates far more risk than a tracked device with clear, verifiable records.

The shared responsibility model

Novatech:

• Designs asset tracking approaches specific to copiers and printers

• Helps tag and track PHI-bearing devices across departments and locations

• Manages drive wiping or destruction for devices we provide and service

• Provides documentation that supports audits and internal reviews

Your organization:

• Approves lifecycle policies and risk tolerance

• Determines which devices are permitted to handle PHI

• Ensures departments follow processes for moves, replacements, and removals

• Involves legal and compliance teams in final lifecycle decisions

This shared approach delivers control and visibility without overwhelming your internal teams.

Important note

This content is for general informational purposes only and does not constitute legal advice. Legal counsel and compliance teams should always be involved in HIPAA-related lifecycle and disposal decisions.