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HIPAA, unlike many other compliance standards, cannot be "certified." This can lead to certain levels of open interpretation, but best practices are generally a
by david_shaw 13y ago
HIPAA, unlike many other compliance standards, cannot be "certified." This can lead to certain levels of open interpretation, but best practices are generally agreed upon.
Products like TrueVault provide excellent value, but security awareness training is the golden key to improve an organization's information security posture.
For an example of what I mean, consider the following scenario:
- Patient data (called Protected Health Information, or PHI) is stored securely in a TrueVault database. This database is accessible only from the hospital, and TrueVault has signed a BAA with the covered entity.
- A surgeon is prepping a kidney transplant for patient John Smith. The surgery is tomorrow morning, and Dr. Goofböl wants to make sure he's familiar with the patient's medical history.
- Dr. Goofböl, an authorized viewer of this patient's PHI, accesses the data and begins to take notes. A new batch of PHI is now being created, as it contains medical information as well as identifying information of the patient (say, his name).
- Dr. Goofböl emails this document to himself (whether his work or personal email address--it doesn't really matter), and goes home for the night.
- Dr. Goofböl stops at a nice coffee shop on his way home, and his personal laptop (without full-disk encryption) is stolen. The data is lost, and cannot be accounted for.
My company provides HIPAA Security Risk Assessments, and I've seen this exact scenario play out many times, albeit with other "HIPAA compliant storage" solutions, rather than TrueVault. There is absolutely a place for secure products like this, but security awareness training and the true gravity of identity theft and information loss needs to be ingrained in the medical industry.
"Security" for a hospital used to mean protecting doctors and patients from intruders (or mentally unstable patients). It used to involve burly men in white clothes; they're not used to thinking about where their information is traveling. Furthermore, the government is mandating that electronic health information be available to patients through web-based patient portals, which introduces a whole different level of potential vulnerabilities.
I truly believe that the healthcare technology industry is going to be one of the most booming sectors of the next decade, but there are major changes that need to occur to facilitate that. Hospitals need better IT infrastructures, more attention needs to be paid to security, and better tech personnel need to be brought into these environments. Only then can the next generation of healthcare technology truly succeed.
- jessaustin 13y agoI've been suspicious of the value of Data Loss Prevention systems in other contexts, but do you think "endpoint" DLP could help reduce the Dr. Goofböl issue you describe? The surgeon has likely been made aware of the dangers of sensitive data in email. For whatever reason, this user is unable to comply with proper procedure. Can such a user really complain when placed in a DLP jail?
- PeterisP 13y agoIMHO no technical solution can eliminate the proposed example of Dr. Goofböl, so it's pointless to attempt to do so - in any case he can scribble down the name+protected info+some notes on a paper napkin, lose it, and the result would be the same. So training / social solution is needed anyways, but that's a worry for other industries, not tech.
- jessaustin 13y ago...no technical solution can eliminate... so it's pointless to attempt to do so... The premise of this proposition is correct, but not the conclusion. If a technical solution can alleviate a problem (and isn't dominated by some other, better technical solution) then it should be implemented to whatever extent is cost-effective. I don't imagine that no one has a slim jim that can open locked car doors, so that isn't the reason I lock mine. I lock them because the vast majority of people either can't or don't open locked doors they don't own. On the other hand, I know more people (who) are happy to duck into an unlocked car for a moment to quickly rummage the various nooks and crannies for small valuable items. Most physicians want what's best for their patients, including Dr. Goofböl. It isn't the responsibility of a patient records system to regulate the tiny minority who don't. If the system can help physicians who are struggling in particular areas, by not making it easier to do the wrong thing than the right thing, that would be a benefit. ...some notes on a paper napkin, lose it, and the result would be the same. These results ain't even in the same ballpark. I'm not particularly worried about the threat posed by my physician's maid. As I said, however, I have yet to see DLP, especially endpoint DLP, be of particular value, so I'm genuinely curious as to David Shaw's opinion on this.
- 13y ago