Posts Tagged ‘encryption’

SWOT – Starting point for protected health information security

Sunday, September 27th, 2009

Wondering where to start your healthcare security projects? We recommend a SWOT analysis! You can obtain more information about SWOT from this Wikipedia article.  SWOT stands for Strengths, Weaknesses, Opportunities, and Threats!

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SWOT is typically used in  business planning processes but it could very well be applied to your healthcare security projects. Remember the four points of data security vulnerability: data at rest, data in motion, data in use, and data disposed. Determine the SWOT of all four points of vulnerabilities and create a plan for remediating the W (weaknesses) and the T (threats) portions of the SWOT. There are likely to be Strengths in your overall systems. The O (opportunity) could be looked as your ultimate goal of improving the security of your IT systems.

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Encryption has always been thought of as a complex technology that is difficult to implement. With a SWOT analysis and the right partner on your side implementing encryption is a snap! Choosing a partner that specializes in encryption and data security will help you get the protection you need quickly, without an extended learning curve.

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How Media Notification Works (and how to avoid it)

Wednesday, September 9th, 2009
Logo of the United States Department of Health...
Image via Wikipedia

Media notification is required when a breach of more than 500 records has occurred.  The Interim Final Rule preamble discusses how the U.S. Department of Health and Human Services (HHS) expects the media to be notified in case a breach of over 500 records occurs. Note that HHS considers media notification to be relative to where the residents live, not the location of the covered entity or business associate.

  • If the residents in the unsecured protected health information (PHI) live in a particular city the breach notification should be sent to  the prominent media outlet serving that city. A prominent media outlet could be a television station or newspaper (no preference is given).
  • If the residents in the unsecured protected health information (PHI) are spread across a state the prominent media outlet must serve the entire state.
  • If the total amount of records breached is over 500 but the residents live in multiple states and not more than 500 are in any one state then media notification is not required.  Although media notification is not required, notification to the individuals is still required.
  • If the total amount of records breached is over 500 in more than one state media notification is required to the prominent media outlet in each state.

The content in the media notification is identical to the content required for individual notification:

  • A brief description of what happened, including the date of the breach and the date of the discovery of the breach, if known.
  • A description of the types of unsecured protected health information that were involved in the breach (such as whether full name, social security number, date of birth, home address, account number, diagnosis, disability code, or other types of information were involved);
  • Any steps individuals should take to protect themselves from potential harm resulting from the breach.
  • A brief description of what the covered entity involved is doing to investigate the breach, to mitigate harm to individuals, and to protect against any further breaches.
  • Contact procedures for individuals to ask questions or learn additional information, which shall include a toll-free telephone number, an e-mail address, web address, or postal address.

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HHS expects the notification to the media to be in form of a press release.

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It should be noted that you can avoid media notification and notification to individuals by encrypting protected health information (PHI) .

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Breach notification goes into effect on September 23, 2009

Wednesday, September 2nd, 2009

The new breach notification guidelines go into effect on September 23rd, 2009. Even though breach notification goes into effect on 9/23/09, the Interim Rule states that civil penalties will not be imposed until February 18th, 2010. The government is aware of the ambiguity and clearly states that it has discretion on imposing sanctions for failure to provide notification in case of a breach notification for breaches occurring before 2/18/10.

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During the 180 period between 8/2009 and 2/2010 covered entities have the perfect opportunity to review the data stored on their IT systems. The Interim Rule is concerned specifically with Data in Motion, Data in Use, Data at Rest, and Data Disposed. Experior can help determine the best plan of action to implement encryption in your IT systems to protect your organization from breach notification requirements.



Getting started with encryption

Tuesday, August 25th, 2009

Encryption can be intidating. The technology is filled with technical security jargon like encryption keys, hash, key length, etc. In most organizations the least common denominators are often devices  used the most – laptops, tablet PCs, and desktop computers. These devices are used to work with patient data and store information that is the most vulnerable to theft, misuse, and unauthorized access. These devices are often serviced and replaced. How many times have you replaced a broken hard drive? How many computers have you replaced in the last 3 years?

Fortunately, the most vulnerable devices are the easiest secure. If you have serveral computers you would like to secure, or if you have a tablet or laptop that you use when you travel, installing Whole Disk Encryption (WDE) software such as PGP Whole Disk Encryption is an easy way to get started.

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WDE simply encrypts your entire hard drive. After installing the software you can encrypt your entire hard drive. The software operates in the background while you work and does not affect your computer’s performance. It may take several hours for your hard drive be become encrypted. After completion, you will need to enter a password every time your computer boots. If your computer is stolen the thief will not be able to access your computer because the password will not be known to him/her. More importantly, your hard drive will not be able to be analyzed by forensic or other hard drive reading software. All your data will essentially become “scrambled” to anyone trying to view the contents of your hard drive.

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It’s important that you understand technologies that WILL NOT protect your information:

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- File deletion – deleting files on your hard drive does not erase them permanently. When you “delete” a file on your computer you are simply removing the pointer to the data in the hard drive’s directory. Until your data is overwritten by new data the old data remains on the hard drive and is able to be retrieved by even the most rudimentary tools on the Internet.

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- Password protecting files – Using password protection features in Microsoft Word, Excel, and even Quickbooks does not protect your information. It simply forces you to enter a password before viewing the data. There are many tools that are available that can easily recover these passwords. In addition, passwords don’t encrypt data. They are a method of very basic access control. If you password protect your document it can easily be recovered by data recovery and simple forensics applications.

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- Screen saver passwords – Although these should be used and activated when you’re away from your powered-on computer, they do not protect your data. A simple restart of the computer will bypass screen saver passwords.

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- Computer passwords – Computer passwords should be set so that you are prompted to enter a password when you start up your computer. However, these can easily be recovered by many programs found on the Internet. They also don’t encrypt the contents of your hard drive.

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- BIOS passwords – Most PCs have an option to set BIOS passwords. BIOS is a small program in every computer that runs very briefly when you turn your computer on. BIOS tells the computer the most basic information about your computer such as the amount of memory in your computer, size of hard drive, number of hard drivers, etc. This information is used to load your operating system (Microsoft Windows, Apple MAC OS, etc). A setting in BIOS could be made to require a BIOS password before your computer even loads Windows. Although it may be deterent to the casual unauthorized user, such as a snooping co-worker, BIOS passwords are easily reset by anyone with rudimentary technical skills. Sometimes it may require that the computer be opened and certain buttons are pressed inside the computer. But it can easily be defeated. And BIOS passwords do not encrypt data.

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FileVault in the System Preferences under Security
Image via Wikipedia

- Apple FileVault, Windows EFS – These are useful options for encrypting data. In both cases (Apple

and Windows) these are only file-level encryption technologies. Apple’s FileVault is superior because it encrypts your entire user profile. Windows EFS is complex to maintain and restore in case you switch computers. However, these technologies encrypt only certain files or directories. If you accidentally move information out of the encrypted directories that information will not be encrypted. These also don’t prevent basic access to the operating system of the computer. For example, if your Mac is stolen and you enable FileVault the thief can still access your computer.

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Although installing whole disk encryption on a few computers is acceptable, deploying individual encryption applications on many computers is not efficient or recommended.  Installing software like PGP Whole Disk Encryption on many computers without a central management system could present administrative challenges of manually maintaining encryption keys and leaves open the possibility of not being able to access encrypted computers after an employee leaves. Vendors like PGP offer a management console that can take away the administrative burden  of maintaining many computers. Before deploying WDE refer to an expert that can set up your environment so you can properly manage your encrypted computers centrally.


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