[BreachExchange] A clean bill of health for data security

[Audrey McNeil]

https://gcn.com/articles/2017/04/21/health-data-security.
aspx?admgarea=TC_SecCybersSec

Rarely a day goes by that we don’t hear about a data breach in an
organization -- and government entities are not immune.  Government health
care agencies and institutions should be particularly concerned because
their patient data is highly prized by cyber thieves and their staff
members need easy access to electronic health records. Not surprisingly,
the health care arena reports among the highest number of data breaches.

In 2016 the number of  breaches, hacking threats and financial settlements
due to Health Insurance Portability and Accountability Act (HIPAA)
violations all increased.  Given the growing risks and escalating costs,
government health care agencies, hospitals and medical centers should be
worried about the dangers they face from data breaches, both from outside
hackers and internal sources.

Whether a result of insider negligence (the leading cause of data
breaches), unencrypted medical devices, the absence of
bring-your-own-device policies, lost or stolen devices or inadequate
security defenses, government health care entities must acknowledge the
multitude of potential data leakage threats and ensure they are protecting
their organizations’ sensitive information.

Health care organizations can minimize risks, comply with security-related
regulations and protect confidential data by following these three best
practices:

Ensure strong authentication.  In a government health care institution or
agency, many people “touch” personal identifying information, from doctors
and nurses to technicians and administrative staff.  Adding to that mix,
employees likely use a variety of endpoint devices in their work, including
desktops, laptops, tablets and removable media.  Given this complexity,
establishing who has access to what kinds of information and being able to
track where and how that data is being used and shared is critical.
Implementing robust two-factor authentication  across users, devices and
the network  can bolster efforts to ensure that sensitive information is
not leaked.


Authentication is especially important in the government space, as the
Office of Management and Budget has mandatory safeguards for agencies that
are designed to ensure PII is collected, accessed, used, shared and
disposed of correctly. Two-factor authentication is required as part of OMB
Memorandum M-06-16, Protection of Sensitive Agency Information, for PII
being accessed remotely.

Encrypt health data.  There are a variety of ways to protect sensitive
data, but encryption of data at rest should be the basis of any security
initiative.  Government health care institutions should encrypt everything
sensitive and confidential to protect data not only from outside hackers
but also from the risk within, whether intentional or by accident.

HIPAA requires that covered entities determine if encryption is a
“reasonable and appropriate” security measure to implement in their
environment.  If the Office for Civil Rights has a different interpretation
of “reasonable and appropriate” than the facility, though, serious fines
could result for non-compliance.  Although the HIPAA Security Rule provides
flexibility with implementing technical safeguards, there is no flexibility
when it comes to the law’s Breach Notification Rule.  If stolen or lost
data is not encrypted, covered entities must notify the Department of
Health and Human Services, all affected individuals and even the state and
local media in some cases.  However, if lost or stolen data is encrypted
and the covered entity has proof (audit logs) of that protection, breach
notification is not necessary.

Establish and enforce security policies.  While the right technology
solutions are imperative for data security, having and following the proper
security policies and processes is just as important.  Policies should
cover adoption capabilities (easy to interpret, implement and follow),
employee education and training procedures (not just during new employee
orientation but on a regular basis and including explanation regarding why
staff need to do things a certain way, rather than just a list of rules)
and accountability actions.

Having a strong security policy with supporting processes and employee
training are key components of OMB Memorandum M-06-15, Safeguarding
Personally Identifiable Information. The memorandum highlights agency
responsibilities in properly protecting sensitive PII and requires that
agencies conduct a review of their policies and processes and take
corrective action as warranted to prevent the intentional, negligent misuse
of or unauthorized access to PII. The mandate also requires agencies to
train employees regarding their responsibilities for protecting privacy.

With attackers targeting the health care industry, it’s essential for
government health care entities to protect themselves  and their patients
 from becoming another breach statistic.  By establishing, incorporating
and following the aforementioned best practices around people, encryption
and policies, government health care institutions and agencies can
safeguard their confidential information and lower their risk of data
breaches.
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