HIPAAlive FAQ (Security)
Questions
Answers
What is Cryptology?
Bruce Schneier describes this very well in Applied Cryptography,
Second Edition, Wiley & Sons, page 1:
"The art and science of keeping messages secure is cryptography,
and is practiced by cryptographers. Cryptanalysts are practitioners
of cryptanalysis, the art and science of breaking ciphertext;
that is, seeing through the disguise. The branch of mathematics
encompassing both cryptography and cryptanalysis is cryptology
and its practitioners are cryptologists."
What data do I need to encrypt?
You need to encrypt any Protected Healthcare Information (PHI)
that travels over an open network - the Internet is an open network.
All PHI must be encrypted between "safe havens." This
includes email that contains PHI, FTP file transfers, billing, telnet
communications - and basically anything that moves over an open
network.
You may also have to encrypt internally if your company has two
or more business components that share an intranet, and are Covered
Entities that would at times need to be careful about exchanging
PHI between each other. For instance, if one entity were a hospital
and another entity an insurance company, these two - if they shared
an intranet (called in this case an extranet) would probably have
to encrypt. VERY few companies will need to encrypt data inside
their intranets.
Phone calls - what's the security
picture with them?
Phone calls are considered secure under HIPAA. This includes voice,
modem and FAX communication.
Faxes - what's the security picture
with them?
While faxes that contain PHI should be carefully guarded within
the office, just as any other paper containing PHI should, Faxes
are excluded from the requirements for other forms of electronic
communication. Treat faxes as you would paper you sent by courier.
More on electronic communications.
PDA's (e.g., Palm Pilots) what's
the security picture with them?
PDA's do not specifically require encryption. Instead, either through
training or other measures, there must be a reasonable assurance
that the PDA will not be lost or otherwise accessed by unauthorized
personnel. While encrypting a PDA is perfectly okay under HIPAA,
it is not required if it is reasonable to assume that other methods
are being employed to protect the data.
More information on wireless
technology in healthcare.
What is an audit trail and what does
HIPAA require? Do we have to track everyone who ever saw any PHI?
The proposed security rule's administrative standards require an
internal audit process, defined as a review of the records of system
activity like logins, file accesses, and security incidents. The
technical sections of the rule require the mechanisms to gather
this audit data.
Most health care organizations already have the capability to capture
the kind of security data described above. Modern network operating
systems typically provide the means to collect log files containing
data about login failures and successes, and attempts to access
specific files (such as applications or data files of applications
that contain health information). Though many organizations have
chosen not to implement these features, believing them to be a resource
drain, inexpensive upgrades are readily available to offset such
problems. Further, most performance problems associated with auditing
are the result of auditing too much information. Selecting more
refined audit parameters resolves this issue.
Who should conduct the audits?
Ordinarily, IS staff conduct these reviews. Examining the login
failure log should be a daily task of one member of the security
administration team. Examining other logs can be done on a more
relaxed schedule, and in fact, many of the patterns to be examined
make more sense when viewed on a weekly basis. For larger institutions,
forensic software packages can be used to examine the data for patterns
and changes in patterns (such as a user who never works at night
suddenly logging-in at 2 AM).
The best value of the audit process comes with proactive auditing
- examining the logs before you are aware of a problem. Waiting
until a security breach to examine the logs is a high tech example
of locking the barn door after the horse has bolted. The purpose
of security is to prevent breaches, not to prosecute them after
the fact.
Read an overview of
the proposed security rule.
Learn more about the technical
aspects of security.
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