Workstation Security: Workstation security where patients can see screens

45 CFR 164.310(c) sets the expectation for workstation security. The text is brief; the evidence it implies is not, and the difference between the two is where most remediation time goes.

What the rule says

Standard: Workstation security. Implement physical safeguards for all workstations that access electronic protected health information, to restrict access to authorized users.

That is the text of 45 CFR 164.310(c). Read it closely: it describes an outcome to achieve, not a product to buy, which is why two practices of the same size can satisfy it in different ways and both be right.

This is a standard, and a standard is met in full: 45 CFR 164.306(c) requires a covered entity or business associate to comply with the applicable standards.

What this looks like in practice

In an assessment, 45 CFR 164.310(c) is not one question. It resolves into several, and each one is really asking for different evidence. These are among the questions asked about it:

• Does the organization physically secure workstations that access sensitive data so they are protected from unauthorized access and observation?
• Does the organization require workforce members to lock or obscure screens, and secure electronic media, that can display or hold ePHI when a workstation is left unattended?
• Does the organization place and protect the equipment that holds or accesses ePHI to protect it against reasonably anticipated environmental hazards and unauthorized physical access?

Ownership usually sits with whoever controls building access, though the evidence is often produced by someone else, which is where the trail breaks. A control that works but has no owner tends to stop working the month the person who quietly maintained it changes roles.

Who this applies to

Every covered entity and every business associate, at any size. 45 CFR 164.306(b) allows flexibility of approach, so a two-provider practice and a hospital system may implement this differently and both comply. What flexibility does not allow is skipping the decision: the smaller the organization, the more the written reasoning carries the weight, because there is no scale of operation to make the control self-evident.

Building it, in order

These steps are one way to meet it, drawn from our question bank. Unless a step names a provision, the Security Rule does not require that particular measure: 45 CFR 164.306(b)(1) lets you use any security measures that allow you to reasonably and appropriately implement the standards and implementation specifications, chosen with the factors in 45 CFR 164.306(b)(2).

The sequence below is the order that produces evidence as a by-product rather than as a separate documentation exercise:

1. Identify all workstations that can access sensitive data and their physical locations.
2. Position workstations and screens away from public or unauthorized view (for example, not facing waiting or public areas).
3. Place workstations in access-controlled areas or apply physical restraints where appropriate.
4. Apply privacy filters or repositioning where screens cannot be shielded by location.
5. Establish a policy requiring screens that display ePHI to be locked or obscured, and electronic media holding ePHI to be secured, when a workstation is left unattended.
6. Enforce an automatic session lock after a short period of inactivity.

Where else this maps

The questions behind 45 CFR 164.310(c) also map to NIST SP 800-66 Rev. 2 5.2.1, 5.2.2, 5.2.3, which is voluntary guidance rather than law; following it does not by itself establish compliance with any law. That matters for scoping: the same evidence can be written once and referenced from each, rather than rewritten per framework.

Evidence an assessor asks for

For this requirement the evidence type that satisfies it is a policy. The distinction matters more than it looks: a policy states what you intend to do, a procedure states how, and a record proves it happened on a date. Auditors ask for all three, and a practice that has written the first two often has nothing for the third.

Date every document and keep the superseded versions. 45 CFR 164.316(b)(2)(i) requires the documentation 164.316(b)(1) calls for (the Security Rule policies and procedures, and the written record of any action, activity or assessment the Security Rule requires to be documented) to be retained for six years from the date of its creation or the date when it last was in effect, whichever is later, so a policy you replaced two years ago is still part of the record.

Where this usually goes wrong

The usual gap is a control that exists in practice and nowhere in writing. Someone does the work, reliably, and it has never been written down, so the organization cannot demonstrate it and cannot notice when it stops. The fix is not more control, it is a dated record and a named owner.

What to do about it

• Produce the evidence, not the intention. For 45 CFR 164.310(c) that means a signed, dated policy with a named owner and a review date. If the only evidence is that someone knows how this works, you have a practice and not a record.
• Put a name on it. Whoever controls building access should be recorded as the owner. Where the work is done by someone else, say so in the document: the split between who owns it and who performs it is where the trail usually breaks. A control with no owner stops working the month the person who quietly maintained it changes roles, and nobody notices.
• Set a review cadence and keep the evidence of each review. An annual date with a dated output is a common floor; what fails an assessment is a control implemented once and never re-checked against a changed environment.
• There is no documented-alternative route for the requirement itself. It is required (45 CFR 164.306(d)(2) for a specification, 164.306(c) for a standard), so a risk-based decision not to meet it is not available. How you meet it is yours to choose under 45 CFR 164.306(b); the measures in this post are examples, not the rule's text.

Work backward from the evidence. Decide what evidence would prove workstation security to someone who does not already trust you, then build the control that produces it. Programs built in that order tend to stay current, because the evidence goes stale visibly.

Related requirements

• Workstation Use: Workstation use rules for shared clinical machines
• Device and Media Controls: Tracking devices and media that hold ePHI
• Maintenance Records: Maintenance records for security-relevant repairs

References

• 45 CFR 164.310(c), in 45 CFR 164.310 on eCFR. Quoted text verified against the eCFR text current as of 2026-10-06.
• The Required and Addressable designations are defined at 45 CFR 164.306(d).
• Crosswalk references in this post are the mappings in our question bank, and are not verified against the published text of those standards.
• This post describes what a requirement asks for and what evidence documents it. It is not legal advice, and your counsel owns the conclusion. State law may impose additional obligations; HIPAA preempts a State law only where it is contrary to HIPAA (45 CFR 160.202, 160.203).