One page is enough if it covers seven things: scope, adoption rules, scanning, fix timelines, exceptions, ownership and review date. Write it in plain sentences you actually follow. Hospital reviewers read a short, true policy more favorably than a long one the team ignores.
Why one page
The Security Rule asks for reasonable and appropriate written policies and procedures, kept in written form, which may be electronic (45 CFR 164.316(a) and (b)). It does not ask for volume. A short policy gets read, gets followed and is easy to update when practice changes, which the rule also expects.
The seven sections
| Section | What to write | Example line |
|---|---|---|
| Scope | What the policy covers | Third party code in products that handle patient data, including build tools |
| Adoption | How new components get approved | A named reviewer checks maintenance, license, known flaws and data access before adding |
| Scanning | What runs and when | Inventory is scanned on every build and released versions are rescanned on a regular schedule |
| Fix timelines | Tiers by severity and exploitability | Exploited and reachable issues first, then critical, high, others |
| Exceptions | How to accept risk | Written acceptance with approver, controls and expiry date |
| Ownership | Who does what | Security lead owns the policy, engineering managers own fixes |
| Review | When it changes | Reviewed annually and after major incidents |
Fill in the blanks
Use these starting sentences and replace anything untrue.
- "We keep an inventory of direct and transitive components for each release."
- "No new component is added without review by [role]."
- "Components that send data outside our environment require approval from [role] and a recorded decision on agreements."
- "We prioritize issues that are exploited in the wild and reachable in our product."
- "A component past its support date requires a risk acceptance with a review date and a replacement plan."
- "Policy owner: [role]. Last review: [date]."
Make it enforceable
A policy nobody checks is decoration. Pick two or three rules a tool can enforce, such as blocking a pull request that adds a component with a known critical flaw, and run them in your pipeline. Record exceptions in the same place you record other decisions.
Common mistakes
- Copying a template with commitments you cannot meet.
- Naming specific tools in the policy, so the policy changes every time the tooling does.
- No exceptions path, which leads to silent exceptions.
- No date, so a reviewer cannot tell if it is current.
Try it yourself
Click through it at your own pace, or open it full screen. Watch a pull request get blocked by a rule, then compare that behavior with the adoption and fix lines in your policy.
Safeguard's policies, gates and guardrails can enforce rules like these, and its compliance and evidence automation records when they ran.
Quick check
Who should sign the policy?
The security or compliance owner, with the head of engineering. Signatures matter less than a visible owner and date.
Do we need a separate policy per product?
Usually one policy with product specific appendices is enough.
Sources
Last reviewed: 19 October 2026.
