This overview describes Blackstar’s principles for retaining, returning, deleting, and securely disposing of PHI and related records. It avoids publishing storage locations, deletion functions, backup mechanics, or technical disposal sequences.
This public overview summarizes Blackstar’s approach and does not replace Blackstar’s internal policies, procedures, contractual obligations, or client-specific requirements.
Our Commitment
Blackstar’s retention program requires information to be retained only for documented service, customer, security, support, legal, contractual, or compliance purposes. Retention and disposal requirements are defined by data class and account for customer instructions, legal holds, record integrity, recovery needs, vendor limitations, and applicable law.
How We Approach This Area
- Data-class decisions. Retention is defined according to the type of information, purpose, source, trigger, applicable obligation, and approved disposition method.
- Compliance documentation. HIPAA’s six-year documentation rule applies to specified policies, procedures, and required compliance records; PHI and medical-record retention is determined under the requirements applicable to the relevant data and record owner.
- Customer and legal alignment. PHI-retention periods depend on applicable agreements, covered-entity instructions, service needs, and other law.
- Legal holds. Ordinary deletion is suspended when litigation, investigation, audit, incident, or other preservation duties apply.
- Secure disposal. Active data, temporary artifacts, devices, and media are disposed of using methods appropriate to sensitivity and technology, with verification where appropriate.
- Backup-aware deletion. Deletion commitments account for backup architecture, immutable records, vendor-managed systems, technical feasibility, and systems outside Blackstar’s control.
- Continued protection. When return or destruction is technically infeasible, safeguards and restrictions on further use and disclosure continue as required.
- Offboarding coordination. Return, export, deletion, access revocation, vendor requests, and any data that remains are addressed under applicable customer and contractual requirements.
Customer-specific retention and deletion commitments are defined through the applicable agreement, data classification, legal requirements, and verified service capabilities.
Roles and Responsibilities
Company responsibilities assign PHI and compliance-record retention decisions to privacy and security governance; deletion and media controls to engineering and security operations; and customer instructions, provider coordination, legal holds, and record administration to workforce and vendor governance. Workforce requirements prohibit unapproved copies and require disposition of authorized temporary information when its purpose ends.
Review and Continuous Improvement
The program calls for periodic and event-driven review of retention classifications, legal and contractual requirements, vendor behavior, recovery dependencies, deletion methods, and offboarding practices. New data, vendors, features, customer requirements, incidents, or legal changes may prompt reassessment.
Working With Covered Entities
Applicable agreements and onboarding decisions define retention, return, destruction, source-of-truth, legal-hold, and offboarding responsibilities. Where a covered entity or its practice-management provider controls authoritative records or backups, responsibilities and technical limits are addressed in the applicable arrangement.
Additional Information
Additional information may be made available to customers and qualified prospective customers through an appropriate security, legal, or procurement review. Certain implementation details are restricted to protect Blackstar’s systems, customers, and security operations.