164.310(d)(2)(iii) Accountability (Addressable)
Maintain a record of the movements of hardware and electronic media containing ePHI and any person responsible. NIST recommends asset tagging, custody logs, and reconciliation.
4
artefacts
1
held by a system
2
at each review
moderate
to go live
SIEM / log platform
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- Custody logs for moves · SIEM / log platform
periodic reviewEvidence produced at each review
- Annual reconciliation · Document repository
- Lost asset incident records · Document repository
governing documentDocuments that govern the control
- Asset register · Policy repository / GRC workspace
First move
Start with the 1 of 4 artefacts that already live in a system (SIEM / log platform); keep the periodic reviews but log each one as a dated record with a named reviewer.
Common gaps auditors find
- Asset register out of date
- No custody handover on moves
- Lost assets not tracked
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheet164.310(d)(2)(ii) Media Re-use (Required) · 164.310(d)(2)(iv) Data Backup and Storage (Addressable)