PHYSICIAN OFFICE IT SECURITY GUIDE 2015 The CMPA supports the advice and recommendations contained in this guide and encourages their consideration by BC’s physicians. Disclaimer: Best practices for IT security depend on the sensitivity of the data and the individual situation, and change regularly with changes in technology. The individual physician must determine the degree to which each best practice applies to their particular situation. This document is provided for use by physicians as a general guide. It is strongly recommended that you retain a knowledgeable and qualified IT professional to assess and maintain your network on a regular basis. In using this guide, you agree that Doctors of BC accepts no liability whatsoever for any IT or security problems you may experience or for any claims, demands, losses, damages, costs and expenses made against or incurred, suffered or sustained by you as a result of those problems, nor any costs you may incur in resolving any gaps or issues in your IT infrastructure. 2 Physician Office IT Security Guide 2015 Following is a list of IT security practices relevant to medical clinics. This list may not be complete, but highlights previously observed gaps and issues. It is recommended that physicians use this list as a checklist to generally assess their IT infrastructure. Each topic is described in more detail in the reference section, with suggestions on ways to address gaps related to that topic. • Device Security (includes in-office and remote access devices) m All confidential patient information on any computer or portable device is encrypted m Operating systems and all plug-in software (e.g. Java, Flash and other plug- ins) are up to date – preferably using automatic updates m Computers and portable devices automatically lock out after a pre-defined period of inactivity (e.g. five minutes) m All computer equipment is appropriately disposed of m Anti-virus detection programs are up to date – with automatic updates m Computer devices (e.g. printers, monitors) are physically located to minimize unauthorized access and viewing m Personal firewall technology is employed with high security settings m Website cookie installation is restricted to trusted sites m Auto-complete password storage for website access is disabled • Local Network Security m m m m m m • Network ports (wall sockets) in public areas (e.g. waiting rooms) are disabled Wireless networks are hardened according to industry best practices Wi-Fi access to clinical local network is not granted to patients and others Networking equipment is located in a secure area (e.g. locked wiring closet) Private Physician Network (PPN) is not interconnected to any commercial Internet services without appropriate security measures PPN service is cancelled prior to moving Local Server Security m m m m Servers are hardened according to industry best practices Server equipment is located in a secure area (e.g. locked wiring closet) All requirements under Device Security are also applied to local servers All server back-ups are transferred and stored securely with both physical security and encryption 3 • User Account Management m m m m m • Acceptable Use m m m m m Usernames and passwords are not shared between users Passwords are required and robust (upper/lowercase characters, length, etc.) Inactive user accounts are disabled immediately User access is controlled by appropriate roles-based access profiles One or more employees is assigned to manage user accounts Users do not record passwords insecurely (e.g. sticky notes, notebooks) Users do not download or install files/programs from unknown or suspicious sources into the network Users do not e-mail or otherwise transfer confidential patient information over unsecure networks, such as the Internet, unless the information is encrypted Users do not visit untrusted or potentially unsafe websites Users do not open unknown email attachments •Audit m m m Audit trail is turned on Random audits are conducted regularly Access to VIP records are audited •Personnel m Physicians and staff attend regular privacy and security training (e.g. annual) m Confidentiality agreements are in place with staff and contractors m A Privacy Officer is appointed as required by PIPA m Appropriate written policies and procedures are in place (PIPA sections (5a) and (5b)) • Remote Access m m Any devices or network used for remote access meets the requirements above for Device Security and Local Network Security Remote access uses a secure connectivity solution (e.g. VPN, SSL) that offers high grade encryption 4 Physician Office IT Security Guide 2015 REFERENCE SECTION Note: Many of these recommendations require the skills of a knowledgeable and qualified professional IT support person. It is strongly recommended to retain a qualified local IT professional with solid experience in security who can become familiar with your clinic and infrastructure. DEVICE SECURITY (includes in-office and remote access devices) All confidential patient information on any computer or portable device is encrypted Any confidential patient information stored on computers (desktops and laptops), mobile devices (e.g. laptops, smartphones and iPods), and removable media (e.g. USB drives) should be password protected and encrypted. When confidential patient information is stored on these devices without encryption there is risk that these devices could be stolen or lost, and the data on these devices could be accessed by unauthorized users. There are a couple of different approaches to secure these devices. One approach is to purchase devices such as desktops or laptops with built-in hard drive encryption or utilizing the built-in encryption software found in various operating systems (e.g. Microsoft’s Windows 7 Ultimate version BitLocker). This encryption software can also be used to encrypt a USB drive. If this is unavailable, users may purchase commercially available software, such as Folder Locker. The second approach is to purchase a USB drive with built-in encryption software. Operating systems and all plug-in software (e.g. Java, Flash and other plug-ins) are up to date – preferably using automatic updates Computer software manufacturers routinely provide security updates for their operating system and Internet browser plug-ins to ensure that security risks to their software are minimized. The end user can customize their operating system and Internet browser to receive these security updates automatically or manually. It is recommended to set up the computers to automatically install these updates so that important security updates are not missed, and to conduct the updates outside of normal business hours as they can take time to install and would impact system performance until the installation is complete. It is also recommended to leave your computer devices powered on and logged off at night so the updates can be automatically installed (scheduled updates will not happen if the computer is in hibernation mode). Computers and portable devices automatically lock out after a pre-defined period of inactivity (e.g. five minutes) When clinical staff members leave a computer or mobile device inactive for an extended period, the computer or mobile device automatically locks the device from unauthorized users accessing or viewing confidential patient information. Lock-outs can be enabled through either the EMR application or the operating system. Lock-out at the EMR level 5 is very good for EMR security; however, it still leaves the workstation open to access. Lock-out at the operating system level ensures the entire workstation is locked from unauthorized access, including access to the EMR application, non-EMR applications, documents and data. Lock-out using the operating system does have limitations as this feature can be easily turned off by any user; therefore, it is ideal to have both the EMR application and the operating system lock-out feature enabled. It is important to instruct end users not to alter these settings. The operating system’s lock-out feature can be configured by the end user, while enabling the EMR application lock-out typically requires the EMR vendor. All computer equipment is appropriately disposed of As computer equipment is replaced in the clinic (e.g. workstation, mobile devices, etc.), it is important to ensure old equipment does not contain confidential patient information. Conventional deletion techniques (e.g. using the delete key or formatting the drive) do not remove the data in its entirety from the equipment as this data can still be recovered by unauthorized users. It is important to use specialized computer software (e.g. Eraser, HDDErase, DBAN) to remove the data securely from the device before disposal. Another method to ensure the data cannot be access by unauthorized users after disposal is physical deformation of the storage platters (the physical media where data is stored) inside the hard drive through the use of tools, such as a hammer, to cause significant physical damage to the media. Anti-virus detection programs are up to date – with automatic updates Anti-virus software is a computer program that detects, prevents, and takes action to disarm or remove viruses. Computer viruses are programs that are deliberately designed to interfere with computer operation. They can corrupt, delete data, and spread themselves to other computers throughout the clinic or Internet. You can protect your computer against viruses by using antivirus software. To protect your computer against the most current viruses, you should update your anti-virus software regularly using its automatic update feature. Some anti-virus programs are configured by default to be manually updated, leaving the responsibility of the user to perform this task. This option increases the risk of obtaining a virus as this task can be easily missed. The end user can configure the antivirus software to automatically update by launching the application and selecting the “Update” menu. While the anti-virus software gives the user the option to run the updates daily, weekly or monthly, it is recommended to run the updates daily after normal business hours to ensure it does not interfere with the performance of other applications on the device (e.g. EMR application). Malware, also known as malicious software, includes computer viruses. Malware, in addition to viruses, includes programs such as keylogger, Trojan horses, worms, etc. Malware is less interested in attacking your computer, but more interested in stealing stored data, which can include personal information, user names and passwords. Malware has the ability to spread or infect other computers on a network. As this poses a larger security threat, it is recommended that users use malware detection software. 6 Physician Office IT Security Guide 2015 Computer devices (e.g. printers, monitors) are physically located to minimize unauthorized access and viewing Computer screens in patient areas (such as the reception desk) should be positioned so that they cannot be easily viewed by unauthorized users. If this cannot be avoided, consider purchasing privacy screens for the monitors. Printers should not be installed in public areas where unauthorized users can easily access the printouts. Personal firewall technology is employed with high security settings To prevent unauthorized remote access to desktops and laptops, and to increase the security of these devices, it is recommended to install and/or enable personal desktop firewall technology on all computers within the clinic. This software is typically part of the operating system but is turned off by default or set with a lower security threshold. By configuring this software to a higher security setting, it provides another layer of security protection against unauthorized access. Some operating systems (e.g. Windows 7) provide built-in firewall protection that allows the end user to customize to its highest security settings, or the clinic can purchase commercially available personal firewall software (e.g. Webroot, ZoneAlarm, Agnitum Outpost Pro Firewall) and configure to its highest security settings. Website cookie installation is restricted to trusted sites Website cookies can be altered by malicious users or software since they are stored on the local computer drive. Cookies can also be used to steal sensitive personal information of another user, which can lead to fraudulent acts such as identity theft. They can also be used for tracking the web browsing history of a user. This data can be sold to advertising agencies, which in turn results in junk emails and advertisements. To enhance security and protection from potential fraudulent acts, cookies should only be allowed for trusted sites. The cookies configuration options are typically found in the Internet browser’s option menu. Auto-complete password storage for website access is disabled When accessing a website that requires username and password authentication, some Internet browsers (e.g. Internet Explorer, Firefox, Chrome, etc.) offer the option to automatically store and pre-populate the username and password for the user. These Internet browsers store the username and password on the local computer to be retrieved whenever the website is accessed. This feature is called “auto complete password storage.” The risk with enabling auto complete password storage is the credentials grant anyone using that computer full access to those websites requiring personal login information. It defeats the purpose of having usernames and passwords if they are already automatically entered by the computer, especially if a user has the same login credentials across numerous applications. If the end user uses the same username and password to log on to the EMR application and to log on to a workstation, these same credentials can be compromised by an unauthorized user using the same workstation. This dangerous 7 practice could potentially allow unauthorized users to access confidential patient information and extract and retain the details electronically. It is recommended to disable auto complete password storage within the Internet browser application. The end user can disable the auto complete password storage functionality under the options menu within the Internet browser. LOCAL NETWORK SECURITY Network ports (wall sockets) in public areas (e.g. waiting rooms) are disabled There are situations where a clinic has local network plugs (wall sockets) installed in public areas that are still connected to the local network, but with no devices connected to the plug. This situation creates a potential security risk as unauthorized users could connect their laptop to this network plug and gain access to the clinic’s local network and possibly view confidential patient information. The clinic should ensure that all plugs with no devices connected to them, especially in public areas, are not active by verifying that the other end of the cable at the wiring closet is not connected to the local network (switch). Wireless networks are hardened according to industry best practices When wireless network solutions are purchased, their default security settings are not configured to industry best practices. If the clinic installs this network solution with default settings there is the potential for unauthorized users to connect to the wireless network to gain access to the clinic’s local network and possibly obtain confidential patient information. Unfortunately, some individuals use advanced tools and software to locate unsecured wireless networks. Once detected, they will connect to the unsecured wireless network to gain access to confidential information. Clinics should ensure their wireless solutions are not installed with the default setting, but, instead, are following industry best practices. The following examples are current industry best practices for wireless solutions. Please note this list is based on time of publication and therefore subject to change due to updates to technology: • Physically secure wireless access points; • Wi-Fi Protected Access II (WPA2) Enterprise; o Authentication: EAP-TLS; o Encryption: AES-CCMP (128-bit minimum); • Wi-Fi Protected Access II (WPA2) Personal; o Authentication pre-shared keys (PSK) with a minimum 13-character random passphrase; o PSK should be secured and changed on a regular basis; o PSK should be changed whenever an employee/contractor who had access to the network leaves the organization; and o Encryption: AES-CCMP (128-bit minimum). It is important the clinic hires a qualified IT support vendor with extensive knowledge and experience installing and supporting wireless solutions. 8 Physician Office IT Security Guide 2015 Wi-Fi access to clinical local network is not granted to patients and others Due to security and privacy risks (e.g. users accessing confidential patient information) the clinic should not provide patients and others with Wi-Fi access to the network the clinic uses for clinical purposes. If the clinic wants to provide patients and others access to a Wi-Fi network, the clinic should set up a separate Wi-Fi network which is not connected to the clinic’s primary local network. Networking equipment is located in a secure area (e.g. locked wiring closet) It is important for the clinic to install all network equipment (e.g. TELUS’ PPN equipment, clinic’s switches) in a secure and locked area, preferably in a dedicated wiring closet. Only the clinic and authorized support vendors should have access to this secure area. If the networking equipment is not in a secure and locked area, unauthorized users can plug a laptop into the clinic’s local network and potentially gain access to confidential patient information. Private Physician Network (PPN) is not interconnected to any commercial Internet services without appropriate security measures There are situations where the clinic may require a second or third Internet connection in addition to their PPN service to access other services the PPN cannot provide (e.g. high speed Internet to view PACS images). In this situation, the clinic should ensure these services are not connected with each other without the appropriate security measures. When two or more such networks are connected together, hardened security measures are required to ensure information exchange only occurs between the proper networks. In other words, EMR information destined to the EMR vendor does not traverse the Internet portion of the network and vice versa, keeping EMR traffic and Internet traffic flow separate. The security design requires a highly skilled professional, as well as approval from Health Shared Services BC (HSSBC) vis-à-vis the PPN. PPN service is cancelled prior to moving If a clinic is moving or closing, it is important for the clinic to contact HSSBC and their EMR vendor to inform them they are cancelling their PPN service. If the clinic does not inform HSSBC and their EMR vendor, the PPN equipment will remain at the old location and the next tenant could use this service and gain unauthorized access to confidential patient information. It is important for the clinic to inform both parties at least one month prior to moving or closing so that the appropriate steps can be taken to remove the equipment. 9 LOCAL SERVER SECURITY Servers are hardened according to industry best practices If the clinic is planning to install a local server in their clinic that will store confidential patient information, these servers need to be configured to increase their level of security (i.e. hardening). Depending on the server’s functionality (e.g. delivering EMR application services, storing identifiable confidential patient information in documents, databases or spreadsheets), the server should be hardened according to the services provided. If an unauthorized user gains access to this server, it is important that they cannot gain access to confidential patient information stored on the server. The IT industry publishes recommendations on how to harden your servers based on the services the server is providing. It is important that the clinic follows these guidelines set by the vendors of their chosen server software company (e.g. Microsoft, VMware). Server equipment is located in a secure area (e.g. locked wiring closet) It is important for the clinic to install all server equipment in a physically secure and locked area, preferably in a dedicated wiring closet with the networking equipment. Only the clinic and authorized support vendors should have access to this secure area. If the server equipment is not in a secure and locked area, unauthorized users can gain physical access to the clinic’s server and potentially access confidential patient information. All server back-ups are transferred and stored securely with both physical security and encryption If the clinic stores confidential patient information on a local server (i.e. server located inside the clinic), all server back-ups should be stored off-site in a secure location, preferably managed by a qualified business that specializes in this type of service. Clinics should back up their server daily to ensure they have the most up to date backup in the event their server hardware fails, and the backup should be tested regularly (i.e. a full recovery from backup performed). To increase privacy and security of confidential patient information, all back-up medium, such as a USB or tape drives, should be encrypted and password protected. It is important to keep the back-up tapes away from magnetic sources to avoid erasure. Note: In addition, all requirements under “Device Security” apply to local servers USER ACCOUNT MANAGEMENT Usernames and passwords are not shared between users Sharing usernames and passwords between users is a security and privacy risk. Unique usernames are assigned to allow users to have a role-based profile (i.e. the level of access provided for each user matches the user’s need to know and provides the least privilege necessary based on the user’s job function.). When usernames are shared between users, the person using the shared username immediately has access to the other person’s role profile that was assigned specifically to that username. This process also circumvents the auditing process built into the EMR application as it makes it difficult to pinpoint who accessed information they were not allowed to view. This situation puts the person the 10 Physician Office IT Security Guide 2015 username and password was originally assigned to at risk as they could be liable for the actions of the person using their username and password. Passwords are required and robust (upper/lowercase characters, length, etc.) In order to increase the security of confidential patient data, it is important for users to have a robust password to prevent unauthorized users from easily guessing it or using automated password cracking software to decode the password. The more complex the password is, the harder it is to decrypt. Users should use a combination of upper and lowercase characters, along with numeric characters and special characters (e.g. $%_ ^). The password should be a minimum of eight characters in length and it should be changed regularly. Inactive user accounts are disabled immediately When an account becomes inactive (e.g. employee leaves the clinic), it is important that the account is disabled immediately by the physician or the assigned Security Officer (or their delegate) to ensure unauthorized users cannot access the EMR and view confidential patient information. Workstation logon accounts can be disabled using the operating system’s administrator tools and the EMR logon accounts can be disabled by the EMR application’s built-in administrator tools. If in any doubt, contact the EMR vendor helpdesk. User access is controlled by appropriate roles-based access profiles To enhance the level of security and privacy and protect confidential patient information, it is important to assign role-based profiles for each user requiring access to the EMR application. Role-based profiles allow the administrator to control what the end user can view and access – for example, a billing clerk does not typically need access to full patient medical charts. The roles are created using the administrator tools built into the EMR application. One or more individuals is assigned to manage user accounts It is important to designate one or more individuals (e.g. physician, Security Officer, MOA) to manage and govern the privacy and security of user accounts. This role ensures that: all inactive accounts are disabled in a timely manner; all users are assigned a unique username; all passwords are secure and robust; and role-based access profiles are properly configured. ACCEPTABLE USE Users do not record passwords insecurely (e.g. sticky notes, notebooks) To help remember passwords, some users write down their passwords on sticky note pads and/or in a paper notebook. This type of practice is a serious risk to the security of 11 confidential patient information as unauthorized users could find the password and log into the EMR application to view patients’ records. The clinic privacy and security policy and the clinic’s Security Officer should discourage this type of behaviour. Users do not download or install files/programs from unknown or suspicious sources into the network There are websites on the Internet designed with the purpose of luring users into downloading and installing malicious software onto the user’s computer. Such malicious software can capture the usernames and passwords and install viruses on the computer.. This software then allows unauthorized users to access the computer devices secretly and remotely gain access to confidential patient information. The clinic’s Security Officer should discourage users from accessing questionable websites and downloading and installing files or programs from unknown or suspicious sources. The computer’s operating system should be configured to prevent the downloading and installation of software by end users. Users do not e-mail or otherwise transfer confidential patient information over insecure networks, such as the Internet, unless the information is encrypted Email is not a secure method of transferring confidential patient information. If email is the only method to send confidential patient information, there are applications that can encrypt the email message with a combination of public and private passwords, better known as public/private certificates, or keys. The public key is shared with the email recipient and must be used in order to view the email message. OpenPGP.js + Mailvelope or GPG4win are recognized email encryption solutions the clinic can consider for encrypted emails. In the private medical practice setting B.C., governed by PIPA, if a patient has provided appropriately informed consent acknowledging the risks, a physician can choose to communicate with the patient via email without the protections of encryption, but should carefully consider the appropriateness and risks in each case prior to doing so. Users do not visit untrusted or potentially unsafe websites Similar to the guidelines under “Users must not download or install files/programs from unknown or suspicious sources into the network”, it is crucial that end users do not visit untrusted or potentially unsafe websites. There are numerous websites containing malicious software to be downloaded by unsuspecting end users. Users do not open unknown email attachments Email attachments, especially from unknown sources, can contain malware which, when opened or downloaded, causes malicious software to be installed on the unsuspecting user’s computer device. This creates the potential for unauthorized users to access confidential patient information or install viruses on the user’s computer device. Users should take the time to familiarize themselves with understanding e-mail scams, fraud, and phishing. To learn more about e-mail scams or frauds, or to report one, visit http://www.rcmp-grc.gc.ca and type “e-mail scams and frauds” in the search bar. 12 Physician Office IT Security Guide 2015 AUDIT Audit trail is turned on EMR applications have user-level access auditing features built in; however, this feature may not be turned on or if it is turned on the clinic may not be actively reviewing the audit log. The clinic should contact their EMR vendor to ensure this feature is turned on and verify by reviewing the audit log. At minimum, the audit log captures which users have logged onto to the EMR solution, the patient records they have reviewed and/or printed, and which files have be modified or deleted. The auditing feature within the EMR application should be turned on and actively reviewed by the clinic’s Security Officer or delegate to ensure the privacy and security of confidential patient information. The workstation also has an auditing feature to monitor printing and file access on the user’s computer device which can also be enabled. Random audits are conducted regularly To maintain the privacy and security of confidential patient information, the Security Officer and/or delegate should conduct random audits of the EMR application audit logs to ensure that users are not accessing confidential patient information or printing and deleting files not pertaining to their role (e.g. accessing the information of family members, other clinic staff/physicians, friends, neighbours, or random individuals). Access to VIP records are audited When clinics have VIP patients (e.g. political leaders, celebrities, etc.) it is recommended to audit accesses to these records to ensure they are not being viewed by unauthorized users. The Security Officer or their delegate should create a regularly scheduled process to audit VIP records. PERSONNEL Physicians and staff attend regular privacy and security training (e.g. annual) Physicians and staff should attend regular privacy and security training workshops. This training should focus on Personal Information Protection Act (PIPA) legislation and how to apply its policies in an EMR environment. The Ministry of Technology, Innovation and Citizens’ Services offers PIPA training sessions. For further details, including contact information, visit their webpage at http://www.cio.gov.bc.ca. Confidentiality agreements are in place with staff and contractors In keeping with the requirements of the BC Personal Information Protection Act (PIPA), the physician(s) (or designated Security Officer) should require internal staff and third party vendors exposed to confidential patient information to sign a confidentiality agreement. This approach helps to ensure that all staff and contractors are familiar with 13 the clinic’s privacy and security policies and guidelines when in contact with confidential patient information. Additional information and resources can be found at https://oipc.bc.ca and search for “BC Physician Privacy Toolkit.” Physicians working in clinics are not typically expected to sign confidentiality agreements due to their existing professional standards set by the College of Physicians and Surgeons; however, group clinics may choose to establish an additional commitment to privacy and security with a physician confidentiality agreement. A Privacy Officer is appointed as required by PIPA The appointment of a Privacy Officer is a requirement and legal obligation under PIPA. The Privacy Officer is an individual designated with the accountability to ensure organizational compliance with privacy legislation, industry standards, and professional and regulatory obligations. The Privacy Officer is responsible for policy development, compliance monitoring, privacy breach management, staff training, and managing complaints, questions and access to personal information requests. In a medical practice, it is recommended that the Privacy Officer is a physician. This means that if the office is a solo practice, the solo physician is the de facto Privacy Officer. In a group practice, one of the physicians or a senior staff person such as a Clinic Manager should be identified as being responsible for this role and its functions on behalf of the group. Appropriate written policies and procedures are in place (PIPA Sections (5a) and (5b)) According to PIPA, clinics must maintain appropriate privacy policies and procedures that meet the requirements of the Act: 5 An organization must (a) develop and follow policies and practices that are necessary for the organization to meet the obligations of the organization under this Act, (b) develop a process to respond to complaints that may arise respecting the application of this Act, and (c) make information available on request about (i) the policies and practices referred to in paragraph (a), and (ii) the complaint process referred to in paragraph (b). REMOTE ACCESS Any devices or network used for remote access meet the requirements above for Device Security and Local Network Security The clinic should ensure that any device or network used for remote access meets the requirements described in the “Device Security” and “Local Network Security” sections, above. 14 Physician Office IT Security Guide 2015 Remote access uses a secure connectivity solution (e.g. VPN, SSL) that offers highgrade encryption Physicians increasingly need to view confidential patient information remotely (outside of the clinic – such as from at home for on-call coverage). For clinics on the PPN, Remote access to EMR patient records from outside the clinic using computers with Internet connectivity is already provided through tokens issued by TELUS (with the exception of Med Access EMR, which uses web-based software with built-in remote access certificates). The tokens provided by TELUS use a SSL VPN Tunnel with two-factor authentication. Secure remote access to an individual desktop within a clinic on the PPN, from a public network such as the Internet, requires cloud-based third-party remote control software, such as TeamViewer or LogMeIn. To maintain the highest level of security for this type of access, two-factor authentication should be used to protect against compromising the security of usernames/passwords. Other methods may work for non-PPN clinics, but cloudbased products are necessary for the PPN due to the particular security configuration of the PPN. Unlike SSL-based browser encryption to secure data for web browser-based EMRs such as Med Access or OSCAR EMR, secure remote access to an individual clinic network for other LAN-based (non-ASP, local server) EMRs from a remote location requires Virtual Private Network (VPN) technology or Cloud-based third-party remote access software. 15 115 - 1665 West Broadway Vancouver BC V6J 5A4 doctorsofbc.ca @doctorsofbc
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