Carewell Health information security policy
Author: Nadia Okoro · Date: 2026-09-01 · Policy owner: Nadia Okoro, Head of Security · Version: 1.0
This is a starting point, not legal or audit advice. Carewell adapted it to its own practice and had it reviewed by external counsel before the SOC 2 Type I audit.
1. Purpose
Carewell Health builds scheduling software used by 140 outpatient clinics. This policy protects the confidentiality, integrity and availability of Carewell's information and the patient scheduling data our customers entrust to us.
2. Scope
- People: all 46 employees and any contractor with access to Carewell systems
- Systems: the production platform on AWS, corporate SaaS tools, and company laptops
- Data: all customer, patient scheduling, employee and company data
- Out of scope: the marketing website, which holds no customer data and is hosted by a vendor
3. Roles and responsibilities
| Role | Held by | Responsibilities |
|---|---|---|
| Executive sponsor | Tom Ashby, CEO | Approves this policy, funds the security program |
| Security owner | Nadia Okoro | Maintains the policy, runs quarterly risk reviews, coordinates audits |
| System owners | Engineering leads | Apply controls and review access to their services |
| People / HR | Rosa Ventura | Onboarding, offboarding and training records |
| All personnel | Everyone | Follow this policy, report incidents |
4. Policy statements
4.1 Access control
- Access follows least privilege and is approved by the system owner in the access request tracker.
- Every person has a unique Okta account; shared accounts are prohibited.
- Multi-factor authentication is required for Okta, AWS and GitHub.
- Access is removed within one business day of departure.
- Production access is reviewed quarterly.
4.2 Data classification
| Level | Examples | Handling requirements |
|---|---|---|
| Public | Blog posts, pricing | None |
| Internal | Roadmaps, wiki | Approved systems only |
| Confidential | Customer contracts, employee records | Need-to-know access, encrypted at rest |
| Restricted | Patient scheduling data | Production only, never exported to laptops |
4.3 Encryption
- Confidential and Restricted data is encrypted at rest with AES-256 via AWS KMS.
- All external traffic uses TLS 1.2 or higher.
- KMS keys are managed by the platform team and rotated annually.
4.4 Vendor management
- Vendors processing Confidential data are assessed before signature; 18 vendors are currently in the inventory.
- The inventory is reviewed every six months.
4.5 Incident response
- Suspected incidents are reported in #security-incidents or to security@carewell.example.
- Nadia leads the response using the incident runbook; customers are notified within 72 hours of a confirmed breach.
4.6 Acceptable use
- Laptops are managed by Kandji with FileVault, screen lock and auto-updates enforced.
- Lost devices are reported within 24 hours.
5. Exceptions
| ID | Policy statement | Reason | Compensating control | Approved by | Expires |
|---|---|---|---|---|---|
| EX-1 | 4.1 unique accounts | Legacy SMS vendor allows one login | Password in vault, access logged | Nadia Okoro | 2026-12-31 |
6. Enforcement
Violations are handled under the employee handbook's conduct process and may lead to loss of access or disciplinary action.
7. Review cadence
- Next scheduled review: September 2027
- Triggers for an early review: a new hosting region, an acquisition, or a significant incident
8. Version history
| Version | Date | Author | Summary of changes |
|---|---|---|---|
| 0.1 | 2026-08-04 | Nadia Okoro | Initial draft |
| 1.0 | 2026-09-01 | Nadia Okoro | Counsel feedback, approved |
Review
Review by: 2026-08-29
| Reviewer | Role | Status |
|---|---|---|
| Nadia Okoro | Security owner | Approved |
| Tom Ashby | Executive sponsor | Approved |
| Hartwell LLP | External counsel | Approved with comments |
Decision record
| Decision | Date | Decided by | Notes |
|---|---|---|---|
| Approve version 1.0 | 2026-09-01 | Tom Ashby | Effective immediately; staff acknowledgment due Sept 15 |