Trusting the Cloud: HIPAA Risk Assessment for Cloud-Based Files

Cloud-based computing and storage is increasingly popular—to the extent that some companies are cutting hard drive space to encourage users to shift toward the cloud. And while the cloud is convenient, allowing your files to travel easily and across devices, that kind of convenience isn’t exactly what you want when it comes to protecting medical files. Is your cloud use secure enough to meet Health Insurance Portability and Accountability Act (HIPAA) standards? Here are some factors to consider.

A Quick Overview
There are a lot of cloud systems available these days, but the first thing you should do when choosing one is compare baseline HIPAA compatibility. Amazon S3, Dropbox and iCloud are not compatible with HIPAA practices out of the box. Most other major systems, including Box, Egnyte, Google apps, and CrashPlan Pro are HIPAA compliant. Identifying the outsiders reduces your choice of cloud systems, allowing you to focus in on the details of compliant plans.

EHR or HIPAA
In addition to cloud computing, many physicians are shifting to digital recordkeeping, using what are known as electronic health records (EHR) systems. These systems are great for centralizing patient data and encouraging collaboration across different medical practices that share the same EHR vendor. However, EHR requirements and HIPAA privacy standards aren’t exactly the same.

The first rule of managing EHR in accordance with HIPAA standards is that you should never trust an EHR vendor that says you don’t need to worry about their HIPAA compliance. Although your specific files may be HIPAA compliant, other practices used by external vendors may not be; for instance, their cloud storage security may be lacking. Additionally, although EHR systems have all the features needed to be fully HIPAA compliant, you’ll need to check to make sure they are properly configured. If necessary safeguards are turned off, your patients’ data may be at risk.

Don’t Play Hide and Seek
Rather than establishing thorough HIPAA compliant practices, some organizations still think that what is known as “security through obfuscation” is a valid system providing the necessary protections. Realistically, though, this is possibly the worst of all security practices. This kind of security focuses on hiding your computer network, but tends to disregard proper antivirus software.

Additionally, such practices tend to reveal other lacking security practices within the organization, such as indiscriminate file sharing (between virus-infected computers, no less). Simply hiding your network doesn’t count as securing your files – a skilled hacker can easily access even an invisible network.

BAAs Are Not Enough
Google has a great reputation in the cloud-computing world, and with health organizations with high security standards. This means that medical practices using Google apps often feel confident that their files are safe, as long as they’ve signed a Business Associate Agreement (BAA).

BAA agreements might keep your information safe on an internal level, but this agreement won’t help secure patient files when transferred to other digital environments. Instead, when transferring files, using end-to-end encryption is the safest bet. This system will keep your data HIPAA compliant, even when it leaves the Google cloud.

Consider Adoption Side Effects
It’s great to choose a new HIPAA-compliant cloud system for your business, but in our pursuit of better data management systems, we often forget to consider the human elements of adopting new systems. Before choosing a new system, then, it’s important to ask whether your employees will be able to effectively use the new system, and whether there are other options they may find more convenient.

This is a common problem for companies choosing between Office 365 and Google apps for their cloud computing activity. Both Microsoft and Google will sign BAAs that offer HIPAA compliance, but the two programs have different strengths. This is where considering use and convenience is important. If you work a lot with documents, you might think that Office 365 is the way to go—most of us came of age writing everything in Word, so why not? The main reason not to, it seems, is that Google Docs’ collaboration systems are helpful and the platform is more convenient. The reverse seems to hold for spreadsheets.

If you can’t get your team on board with a new computing system, no amount of security regulation in the world will help you. Be sure to clearly to tell your staff about organizations with which you have BAAs, the legal risks of using other systems, and their responsibility to patient privacy as health field employees.

Larry Alton
Writer
[ISACA Now Blog]

Healthcare Organizations: How to Get Ahead of Unapproved Cloud-Based File-Sharing Tools

Cloud-based file-sharing tools such as Box, Dropbox, SugarSync and Google Drive can cause major security issues for healthcare organizations. And as a former security lead for a hospital, I found that, even if you have an approved cloud file-sharing website, unless you block access to non-approved file-sharing sites, medical practitioners will use whatever they personally prefer to share protected health information (PHI) with colleagues. Your organization may be deploying Box for internal hospital use, for example, but some doctors will still prefer to use Dropbox to store and share PHI – it’s not enough to deploy one approved tool and then hope for the best.

Once you upload PHI data to a popular cloud file-sharing sites, it’s very easy to (mistakenly) configure it to be accessible to everyone on the Internet. As you can see in this screenshot of the free version of Dropbox, users do not have the ability to restrict access to specific users. The only option for controlling view access to their file is to select “Anyone with the link” as shown below. This means that if the link is posted to a Reddit conversation or another public forum, anyone would be able to download the files.

Palo Alto Networks is often asked to perform free proof-of-concept exercises at hospitals and other healthcare organizations, and I have found that it is quite common to find web access is enabled to unapproved cloud file-sharing sites.

When I led the effort to disable access to cloud file-sharing sites in my former role, I knew that I couldn’t simply block all access without a careful plan. If I had done so, I would have been inundated with tickets from angry doctors wondering what was going on. The reality is that there are likely to be business processes that impact patient care that rely on access to these sites. For this reason I recommend the following high-level plan to decommission access to unapproved cloud file-sharing sites while making sure that clinical processes are not impacted:

  1. Confirm CISO/CIO support of your effort to block cloud file-sharing sites.
  2. Verify that you have approved alternatives to commonly used, but insecure cloud file-sharing sites. Users will need help to migrate their processes to the approved solution.
  3. Determine the users who are accessing cloud file-sharing sites (if you have the capability).
  4. Email users a warning that access to cloud file-sharing sites will be blocked on such and such a date.
  5. Instruct users to open a ticket with the IT Security team to understand approved file-sharing alternatives.
  6. Document a process for approving exceptions, and ensure that exceptions are revisited at least every six months. Require CISO approval for exceptions.

Healthcare organizations can safely enable access to sanctioned cloud file-sharing sites with careful planning and the right security tools, but any such website that is not explicitly approved by the organization should be blocked to avoid HIPAA-reportable incidents – as soon as possible.

Learn more about Palo Alto Networks solutions for sanctioned SaaS applications and next generation security in healthcare organizations.

[Palo Alto Networks Blog]

Palo Alto Networks Lauded for Outstanding Customer Support by TSIA and J.D. Power

The Technology Services Industry Association (TSIA) and J.D. Power have recognized us for our ability to deliver exceptional customer support to our customers. These prestigious industry awards include the TSIA Star Award in 2014 for Innovation in the Delivery of Support Services, TSIA Worldwide Rated Outstanding Assisted Certification and, most recently, Palo Alto Networks, North America Assisted Support, has been recognized by J.D. Power for providing outstanding customer service for its Assisted Technical Support.

Read on for details:

2015 J.D. Power Certified Assisted Technical Support Program

Palo Alto Networks is the first to have achieved the 2015 Certified Assisted Technology Support (CATS) Certification under this new program from J.D. Power for providing exceptional commitment and support to our customers.

Palo Alto Networks, Inc. North America Assisted Support has been recognized by J.D. Power for providing outstanding customer service for its Assisted Technical Support

J.D. Power 2015 Certified Assisted Technical Support Program, developed in conjunction with TSIA. Based on successful completion of an audit and exceeding a customer satisfaction benchmark for assisted support operations. For more information, visit www.jdpower.com orwww.tsia.com.

2015 TSIA Global Rated Outstanding Assisted Certification

TSIA certification recognizes that Palo Alto Networks has achieved Global Rated Outstanding Assisted Support. Customers can purchase Palo Alto Networks products with confidence knowing that Palo Alto Networks meets the highest industry support standards.

2014 TSIA Star Award for Innovation in the Delivery of Support Services

This award recognizes the company that has embraced innovation in people, process and technology to increase agent productivity, service levels or customer satisfaction; increase problem avoidance; or effectively handle more interactions using unassisted channels.

To read more about these accolades, please visit:

Palo Alto Networks takes great pride in delivering an exceptional customer experience, and we are very proud to receive recognition from both TSIA and J.D. Power. We will continue our commitment to delivering an exceptional support experience for our customers.

Please let me know if you have any comments or questions, or contact me via Twitter anytime at @CicconeScott.

[Palo Alto Networks Blog]

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