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The biggest thing is that we can't run software with unencrypted PHI on physical hardware that is simultaneously running other people's code. In practical terms

by harryh 10y ago

The biggest thing is that we can't run software with unencrypted PHI on physical hardware that is simultaneously running other people's code. In practical terms this means that we have to pay AWS some $ to get dedicated instances and also we can't use ELBs in the standard (easy) way. There are some other things as well.

eropple 10y ago
> In practical terms this means that we have to pay AWS some $ to get dedicated instances This is a feature, not a bug. It also is neither HITECH nor HIPAA; it is instead AWS's requirement in order to sign your BAA. > we can't use ELBs in the standard (easy) way Also neither HITECH nor HIPAA. ELBs are used in a PHI-related scenario identically to any other scenario. Unless you are referring to using it as an SSL terminator, in which case I would say "the standard (easy) way is always wrong".
throwaway729 10y ago
That seems like a fairly reasonable thing given you're talking about encrypted PHI... it's some extra $ for a considerable reduction to overall attack surface when processing the most sensitive type of personal data. I don't think this meets OP's definition of "wrong".
- harryh 10y ago
  In practical terms I don't agree that the threat of someone doing all of the following things is worth worrying about (in comparison to many other more likely failures): 1) determine what physical hardware in aws the target is running code on 2) somehow get the aws virtual machine manager to let the attacker run their malicious code on the same hardware 3) somehow pierce the protections of the virtual machine to read memory being used by the target application 4) figure out how the data is stored in memory in order to make sense of anything that was read
  - dragonwriter 10y ago
    > In practical terms I don't agree that the threat of someone doing all of the following things is worth worrying about In AWS case, this is an AWS rule about when they will sign a HIPAA BAA, even though there is no HIPAA regulation that specifically prohibits the arrangement at issue. AWS clearly thinks it is worth worrying about. When you run your own public cloud, you can determine what risks are worth accepting potential liability for.
    - harryh 10y ago
      Yes, I agree that Amazon is behaving perfectly rationally given the legal environment. My point is that the legal environment has been designed in an un-optimal way from a technical perspective. Identifying such a situation was rayiner's request.
      - dragonwriter 10y ago
        > Yes, I agree that Amazon is behaving perfectly rationally given the legal environment. I'm not commenting on Amazon's rationality (I haven't actually evaluated the security concerns that would determine that.) > My point is that the legal environment has been designed in an un-optimal way from a technical perspective. And you haven't pointed to anything in the legal environment that is suboptimal from a technical perspective. You haven't even pointed to anything in the legal environment at all. Amazon (as a BAA) has certain administrative responsibilities for putting administrative and technical safeguards in place to prevent breaches, and certain obligations and liabilities in the case of breaches. HIPAA and related laws and regulations do not specify the specific administrative or technical safeguards, though they do specify areas that must be addressed. Amazon has decided that the particular technical arrangement you prefer is too high of a risk, but you haven't pointed out anything that indicates that this is the result of an outdated regulation that results in poor technical choices rather than technology-neutral regulation and a reasonable evaluation of the security concerns of the particular technical arrangement you would prefer.
  - Spooky23 10y ago
    People said the same thing about cold boot attavks against encryption keys. Yet today the police and others are using that and other NAND attacks regularly. HIPPA is a very easy compliance standard to meet. If it seems difficult to meet those requirements with your standard tool configurations, you should think about what that means with respect to the integrity of your data.
dragonwriter 10y ago
> The biggest thing is that we can't run software with unencrypted PHI on physical hardware that is simultaneously running other people's code. There is no, AFAICT, no regulation under HIPAA or related law that requires this. Certain service providers may have determined that they cannot provide guarantees of privacy/security without this technical restriction.

by harryh 10y ago

eropple 10y ago

> In practical terms this means that we have to pay AWS some $ to get dedicated instances This is a feature, not a bug. It also is neither HITECH nor HIPAA; it is instead AWS's requirement in order to sign your BAA. > we can't use ELBs in the standard (easy) way Also neither HITECH nor HIPAA. ELBs are used in a PHI-related scenario identically to any other scenario. Unless you are referring to using it as an SSL terminator, in which case I would say "the standard (easy) way is always wrong".

throwaway729 10y ago

That seems like a fairly reasonable thing given you're talking about encrypted PHI... it's some extra $ for a considerable reduction to overall attack surface when processing the most sensitive type of personal data. I don't think this meets OP's definition of "wrong".

harryh 10y ago
In practical terms I don't agree that the threat of someone doing all of the following things is worth worrying about (in comparison to many other more likely failures): 1) determine what physical hardware in aws the target is running code on 2) somehow get the aws virtual machine manager to let the attacker run their malicious code on the same hardware 3) somehow pierce the protections of the virtual machine to read memory being used by the target application 4) figure out how the data is stored in memory in order to make sense of anything that was read
- dragonwriter 10y ago
  > In practical terms I don't agree that the threat of someone doing all of the following things is worth worrying about In AWS case, this is an AWS rule about when they will sign a HIPAA BAA, even though there is no HIPAA regulation that specifically prohibits the arrangement at issue. AWS clearly thinks it is worth worrying about. When you run your own public cloud, you can determine what risks are worth accepting potential liability for.
  - harryh 10y ago
    Yes, I agree that Amazon is behaving perfectly rationally given the legal environment. My point is that the legal environment has been designed in an un-optimal way from a technical perspective. Identifying such a situation was rayiner's request.
    - dragonwriter 10y ago
      > Yes, I agree that Amazon is behaving perfectly rationally given the legal environment. I'm not commenting on Amazon's rationality (I haven't actually evaluated the security concerns that would determine that.) > My point is that the legal environment has been designed in an un-optimal way from a technical perspective. And you haven't pointed to anything in the legal environment that is suboptimal from a technical perspective. You haven't even pointed to anything in the legal environment at all. Amazon (as a BAA) has certain administrative responsibilities for putting administrative and technical safeguards in place to prevent breaches, and certain obligations and liabilities in the case of breaches. HIPAA and related laws and regulations do not specify the specific administrative or technical safeguards, though they do specify areas that must be addressed. Amazon has decided that the particular technical arrangement you prefer is too high of a risk, but you haven't pointed out anything that indicates that this is the result of an outdated regulation that results in poor technical choices rather than technology-neutral regulation and a reasonable evaluation of the security concerns of the particular technical arrangement you would prefer.
- Spooky23 10y ago
  People said the same thing about cold boot attavks against encryption keys. Yet today the police and others are using that and other NAND attacks regularly. HIPPA is a very easy compliance standard to meet. If it seems difficult to meet those requirements with your standard tool configurations, you should think about what that means with respect to the integrity of your data.

dragonwriter 10y ago

> The biggest thing is that we can't run software with unencrypted PHI on physical hardware that is simultaneously running other people's code. There is no, AFAICT, no regulation under HIPAA or related law that requires this. Certain service providers may have determined that they cannot provide guarantees of privacy/security without this technical restriction.