Data Managers Interest Group Institute of Clinical and Translational - - PowerPoint PPT Presentation
Data Managers Interest Group Institute of Clinical and Translational - - PowerPoint PPT Presentation
Data Managers Interest Group Institute of Clinical and Translational Institute of Clinical and Translational Research April 17, 2012 Privacy & Security Contacts Privacy & Security Contacts hipaa@jhmi edu hipaa@jhmi.edu
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Privacy & Security Contacts Privacy & Security Contacts
- hipaa@jhmi edu
hipaa@jhmi.edu
- network.security@jhmi.edu
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- IT Help Desk – 410.735.4357
- Or you can call me
– Darren Lacey – Chief Information Security Officer – dll@jhu.edu – 410.735.4477
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Let’s start with some numbers Let s start with some numbers
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HIPAA Breaches >500 since 2009 HIPAA Breaches >500 since 2009
Breach Types Number % H ki /IT I id t 44 14 Hacking/IT Incident 44 14 Improper Disposal (Paper) 73 23 Lost /Stolen Computer/Server 41 13 Lost/stolen media or portable electronic devices 47 15 Lost/Stolen Laptops 77 25 Unauthorized access 8 3 Unauthorized access 8 3 Email 6 2 Other 18 6 TOTAL 314 100 http://www.hhs.gov/ocr/privacy/hipaa/administrative/breachnotification l / db h h l rule/postedbreaches.html
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Ways to think about the numbers Ways to think about the numbers
- Hacking incidents make up slightly more than
Hacking incidents make up slightly more than half of large incidents related to higher education education
- Across all industries hacking makes up ¼ of
incidents incidents
- There are many more incidents related
h i d b h i l f unauthorized access but these involve fewer than 500 patients
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HITECH Act Changes in HIPAA HITECH Act Changes in HIPAA
- Notification required for any breach not just
Notification required for any breach not just SSN or financial information
- Increased fines and penalties
- Increased fines and penalties
- 150 audits annually of covered entities
i starting next year
- Meaningful use requires security risk
assessment
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Things the HIPAA Cops Hate Things the HIPAA Cops Hate
- WEP – Wireless networks
WEP Wireless networks
- Unencrypted email and insecure transmissions
k f i i f b i i
- Lack of monitoring of business associates
- Failure to monitor unauthorized access to
patient records
- Lack of accurate inventory of devices,
y , applications and services
- Inadequate training and awareness
Inadequate training and awareness
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Risk areas at Hopkins Risk areas at Hopkins
- Application complexity
Application complexity
- Disclosure and use accounting
- Downstream data sets
- Downstream data sets
- Personally owned devices
C ll b ti lti it j t
- Collaborative multi‐site projects
- Kudzu‐like web presence
- Network proximity to defense‐oriented
research
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What can researchers do? What can researchers do?
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Encrypt your laptop, including the one you bring from home!!!
It’s cheap, usually easy
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Laptop Encryption Options Laptop Encryption Options
- Mac’s
Mac s
– Lion: use FileVault2, whole disk encryption Pre Lion: use FileVault or TrueCrypt folder – Pre‐Lion: use FileVault or TrueCrypt folder encryption
- Windows XP
Checkpoint encryption through
- Windows XP – Checkpoint encryption through
Hopkins (often pre‐installed) or TrueCrypt FDE Wi d 7 (E i Ul i ) MS
- Windows7 – (Enterprise or Ultimate) MS
Bitlocker or TrueCrypt FDE
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Do you have a project Web site? Do you have a project Web site?
No, good. Yes, prepare to do some work and Yes, prepare to do some work and lots of maintenance
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Web Security Threats Web Security Threats
- Check your server for sensitive files
C ec you se e
- se s t e
es
- Database access controls and monitoring
- Watch your forms and URL’s for potential attacks
Watch your forms and URLs for potential attacks
– SQL Injection – Cross‐site scripting
- Validate all input
- Test your error screens
y
- Monitor any platform vulnerabilities (e.g. PHP)
- Sound server management practicess
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Write up a short data management and sharing plan
For data security and quality. Think of it as version control
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Parts of the plan Parts of the plan
- Documented data extractions
Documented data extractions
- De‐identification and anonymization
d
- Downstream data use agreements
- Dynamic access control lists
- Data sharing approaches – lowest common
denominator
- Disposal and life cycle management
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Tools you can use Tools you can use
- Jshare for file sharing (internal and external)
Jshare for file sharing (internal and external)
- Sharepoint for internal file sharing and version
control (don’t recommend large PHI datasets) control (don t recommend large PHI datasets)
- Winzip/7zip – encrypted folders
- JIRA – for collaboration, but it should be
authenticated through SM (don’t recommend large PHI datasets)
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General security controls General security controls
- Access control for administrative access
Access control for administrative access
- Log management and monitoring of servers
- Symantec or Forefront Endpoint protection
- Symantec or Forefront Endpoint protection
- Be circumspect about cloud services – but
these are improving rapidly these are improving rapidly
- Policies against insecure storage –