Computer Security and the “H” word Glen Klinkhart, CEO Mike Messick, CTO • Founded 2005 • Alaskan Owned and Operated • Information Security Consulting • Consulting for Compliance and Best Practices • Information Risk Assessment and Network Testing • Security Research, Design & Testing • Incident Response & Investigations • Forensics & Network Investigations • Court-proven, Certified Investigators • Cutting-edge Online Investigative Techniques THE WORD Why should care about privacy in our business? “Because it’s the right thing to do. Nobody likes that feeling of violation when private information about them is no longer private. No one wants to visit a doctor who blabs about their health condition. Providers must protect electronic information as an extension of patient confidentiality.” - DigitalSecurus REDACTED This slide has been redacted due to its proprietary or copyrighted work product. REDACTED This slide has been redacted due to its proprietary or copyrighted work product. “PAST practices does not mean BEST practices” - Glen Klinkhart Top 10 Assessment Findings in Alaska 1. 2. 3. 4. 5. 6. 7. 8. 9. No risk analysis performed to date No electronic security management plan No physical security management plan Insufficient policies for security best practice and compliance Data at rest not encrypted, no compensating controls Data not encrypted on high-risk ePHI assets (laptops, etc.) Backups not encrypted No security training program No log collection, monitoring, alerting for appropriate usage and security events 10. No incident response or data breach reporting procedures Best Practices is HIPAA (in some cases it’s better!) Don’t assume compliance runs contrary to profitability. Risk Management Mitigating risk found in all three roles. The entire staff also plays a role. It is the culture of your business. Practitioner Manager Owner What do we see? “The EMR was supposed to solve our problems.” • • • • Fragmented implementation Theft Security assessments are misperceived Major implementations facilitated by office staff with a full time job description • Misconception that security is at the hands of your IT Administrator What do we see? • No proper policies and procedures in place • No security management plan • No security assessment • No proper logging • No log reviews • No proper encryption • Security is left up to the IT department REDACTED This slide has been redacted due to its proprietary or copyrighted work product. Security must be a culture It is NOT a check off list • It is not I.T.’s job • It is everyone’s responsibility, EVERY DAY • Training and education must be ongoing • Assessments must occur yearly • New equipment/upgrade risks must be mitigated • Vendors must be held to their “promises” • Always preparing for the “worse case scenarios” Bad stuff will happen You have fire insurance, don’t you? You have malpractice insurance, don’t you? How many of you have cyber insurance??? Areas of Planning • • • • • • • Policies and procedures Employee training Log monitoring, alerting Proper EMR administration and privileges Security of hardware, software Frequency of security assessments Misconception you are secure because you have a web based application • Incident response It all starts with policies Policies and procedures are the basis for EVERYTHING They are also the “low hanging fruit” Incident Response If you think meeting security requirements is expensive: • • • • • • Data loss is estimated at $210 per record Cost of lost patient confidence? Cost of bad publicity? Cost of incident response/investigation Legal costs Do you or your clients have cyber breach insurance? High Level Security Assessment 3 part entry level assessment • • • 250 question assessment External network scan Internal network analysis What about Law firms? Do you handle medical clients??? • • • • • Doctors Physicians assistants Nurses Administrators Hospitals or clinics What about Law firms? • Do you have any P.I.I. (Personally Identifiable Information ) at your practice??? • At least two identifying kinds of information • • • • Name Address DOB SSN Questions??? Mike Messick Glen Klinkhart (907) 334-9090 P.O. Box 242334, Anchorage, Alaska [email protected]
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