A clean bill of health for data security

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.