Posts Tagged ‘personal information’
Wednesday, December 11th, 2013
In the past week I got the third question in a one month time-frame about the same topic. My unwritten, loosely followed rule is that if three different organizations ask me pretty much the same question in a month, then it is something worth writing about; why are so many (well, a handful) of the same questions occurring in such a short period of time? Is some vendor out there spreading horribly bad advice? Let’s consider the topic… (more…)
Tags:awareness, BA, BA Agreement, BA contract, BAA, business associate, CE, compliance, covered entity, data protection, disclosure, HHS, HIPAA, HITECH, IBM, incidental, Information Security, infosec, midmarket, non-compliance, OCR, personal information, personal information identifier, personal information item, PHI, PII, policies, privacy, privacy laws, privacy professor, privacyprof, protected health information, Rebecca Herold, risk assessment, risk management, security, subcontractor, training
Posted in BA, BA and Vendor Management, HIPAA, Privacy and Compliance | No Comments »
Tuesday, December 3rd, 2013
Encryption has been talked about a lot lately. I’ve gotten at least a couple dozen questions from my Compliance Helper clients in the past month. They can pretty much be boiled down to this question:
What encryption solution should we use?
Many of the small and mid-size businesses I help, and many start-ups of any size, are under the assumption that if they get one encryption solution, it will (more…)
Tags:awareness, breach, cloud, compliance, cryptography, data protection, encrypt, encryption, HTTPS, IBM, information management, Information Security, information technology, infosec, IT security, midmarket, non-compliance, personal information, personal information identifier, personal information item, PHI, PII, policies, privacy, privacy breach, privacy laws, privacy professor, privacyprof, Rebecca Herold, risk assessment, risk management, security, SSL, systems security, TLS, training
Posted in Information Security | No Comments »
Wednesday, November 20th, 2013
One of the things I love about helping all my Compliance Helper (CH) clients with their information security and privacy compliance activities is that they often ask questions that most other small and mid-size organizations also have. So, I then have a great opportunity to share advice! One of my recent conversations dealt with the challenges my mid-size client was having in trying to appropriately customize the data and records retention policy and procedure I provide through the CH service to fit his organization’s unique type of business associate service, while also meet compliance with the HIPAA retention requirements. The paraphrased questions below started our conversation after I advised that there are many types of documents that must be retained for at least 6 years to meet compliance: (more…)
Tags:21 CFR Part 11, awareness, BA, BAA, breach, business associate, CE, compliance, covered entity, data management, data protection, data retention, GLBA, HIPAA, HITECH, IBM, information management, information retention, Information Security, information technology, infosec, IT security, midmarket, non-compliance, Omnibus, personal information, personal information identifier, personal information item, PHI, PII, policies, privacy, privacy breach, privacy laws, privacy professor, privacyprof, Rebecca Herold, retain, retention, risk assessment, risk management, security, SSA, systems security, training, USA PATRIOT Act
Posted in HIPAA, Laws & Regulations | No Comments »
Monday, October 28th, 2013
“What’s the minimum shred size?”
Recently I got a great question from one of my Compliance Helper clients:
“This may seem like a silly question, but is there any type of HIPAA compliance requirements for shredder types? For example, minimum shred size?”
Not a silly question at all! Of the organizations that shred their paper documents (there are still way too many that don’t), a large portion of them are not shredding their documents to a point that they are actually doing so effectively. Here are some points and tips (more…)
Tags:awareness, BA, BAA, breach, business associate, CE, compliance, covered entity, data protection, disposal, dispose, HIPAA, HITECH, IBM, Information Security, information technology, infosec, IT security, midmarket, non-compliance, Omnibus, personal information, personal information identifier, personal information item, PHI, PII, policies, privacy, privacy breach, privacy laws, privacy professor, privacyprof, reassemble, Rebecca Herold, risk assessment, risk management, security, shred, shredder, systems security, training, unshred
Posted in Information Security | No Comments »
Friday, July 12th, 2013
Someone recently commented that I write a lot of blog posts based on my work and what my clients, students and others I meet at conferences and training classes have said or done. Well, that’s because such interactions often create some very good teaching moments that many others could benefit from! And so, yes, now I have another such experience to share. One of my new Compliance Helper clients recently told me, “I still don’t know what I need to do for HIPAA/HITECH compliance that is not covered under the compliance activities of my business clients. How can I do anything more beyond what they are already doing?” (more…)
Tags:awareness, BA, breach, business associate, CE, compliance, covered entity, data protection, HIPAA, HITECH, IBM, Information Security, information technology, infosec, IT security, midmarket, monitoring, non-compliance, personal information, personal information identifier, personal information item, personally identifiable information, PHI, PII, policies, privacy, privacy breach, privacy laws, privacy practice, privacy professor, privacyprof, Rebecca Herold, risk assessment, risk management, security, sensitive personal information, social network, SPI, surveillance, systems security, training
Posted in BA, BA and Vendor Management, CE, HIPAA, HITECH | 1 Comment »
Tuesday, July 2nd, 2013
I’ve been getting the following question and comment increasingly more often in the past several months:
1) “If someone’s name (more…)
Tags:awareness, breach, compliance, data protection, Information Security, information technology, infosec, IT security, midmarket, monitoring, non-compliance, personal information, personal information identifier, personal information item, personally identifiable information, PHI, PII, policies, privacy, privacy breach, privacy laws, privacy practice, privacy professor, privacyprof, Rebecca Herold, risk assessment, risk management, security, sensitive personal information, social network, SPI, surveillance, systems security, training
Posted in HIPAA, privacy, Privacy and Compliance | 1 Comment »
Monday, June 17th, 2013
“We Can’t Afford Security and Privacy!”
Recently I was speaking to a healthcare executive (a hospital Chief Financial Officer) at a conference where I had talked in one of the sessions about the needs for information security and privacy not only for compliance reasons, but also to mitigate risks to the business. He seemed a bit short with me when he approached.
Him: “I wish (more…)
Tags:audit, awareness, BAs, breach, budget, business associates, CEs, compliance, covered entities, customer service, data protection, employees, employment, exception management, HHS, HIPAA, hiring, HITECH, HR, human resources, IBM, Information Security, information technology, infosec, IT security, job applicants, midmarket, monitoring, non-compliance, OCR, Omnibus Rule, personal information, personally identifiable information, personnel, PHI, PII, policies, policy exception, policy management, privacy, privacy breach, privacy laws, privacy practice, privacy professor, privacyprof, Rebecca Herold, risk, risk assessment, risk management, security, sensitive personal information, social network, SPI, subcontractors, surveillance, systems security, third parties, training, vendor management, vendors, walk through
Posted in HIPAA, Information Security, Laws & Regulations, Privacy and Compliance | No Comments »
Friday, May 31st, 2013
Last week one of my Compliance Helper clients that is a health insurance company asked me the following question (slightly modified to protect their identity):
For the past two years, we have tried to get business associate (BA) Agreements from some of our BAs. They will not (more…)
Tags:audit, awareness, BA, BA Agreement, BA contract, breach, business associate, compliance, customer service, data protection, e-mail, electronic mail, email, employees, employment, exception management, facebook, FINRA, HIPAA, hiring, HITECH, HR, human resources, IBM, Information Security, information technology, infosec, insider threat, insider trading, IT security, job applicants, messaging, midmarket, monitoring, non-compliance, personal information, personally identifiable information, personnel, PHI, PII, policies, policy exception, policy management, privacy, privacy breach, privacy laws, privacy professor, privacyprof, Rebecca Herold, Red Flags, risk, risk assessment, risk management, security, sensitive personal information, social media, social network, SPI, surveillance, systems security, training, twitter, walk through
Posted in BA, BA and Vendor Management | No Comments »
Wednesday, May 29th, 2013
I’m getting a lot of déjà vu vibes lately with the old-ish Bruce Willis movie with the catch phrase “I see dead people.” (Remember that?) Only my twist on this phrase for the past few years is, “I see business associates.” A big problem is that (more…)
Tags:audit, awareness, BAs, breach, business associates, CEs, compliance, covered entities, customer service, data protection, employees, employment, exception management, HHS, HIPAA, hiring, HITECH, HR, human resources, IBM, Information Security, information technology, infosec, IT security, job applicants, midmarket, monitoring, non-compliance, OCR, Omnibus Rule, personal information, personally identifiable information, personnel, PHI, PII, policies, policy exception, policy management, privacy, privacy breach, privacy laws, privacy practice, privacy professor, privacyprof, Rebecca Herold, risk, risk assessment, risk management, security, sensitive personal information, social network, SPI, subcontractors, surveillance, systems security, third parties, training, vendor management, vendors, walk through
Posted in BA, BA and Vendor Management, HIPAA | No Comments »
Wednesday, May 1st, 2013
A new data breach research report is out, and it is a good read. This is the annual Experian/Ponemon Institute “Is Your Company Ready for a Big Data Breach?” report. I want to focus on one of the findings in that report; that most organizations are not willing to assist those affected by a breach of their personal information. (more…)
Tags:audit, awareness, breach, breach notice, breach study, compliance, customer service, data protection, e-mail, electronic mail, email, employees, employment, Experian, facebook, FINRA, HIPAA, hiring, HITECH, HR, human resources, IBM, Information Security, information technology, infosec, insider threat, insider trading, IT security, job applicants, messaging, midmarket, monitoring, non-compliance, personal information, personally identifiable information, personnel, PHI, PII, policies, policy management, ponemon, privacy, privacy breach, privacy laws, privacy practice, privacy professor, privacyprof, Rebecca Herold, Red Flags, risk, risk assessment, risk management, security, sensitive personal information, social media, social network, SPI, surveillance, systems security, training, twitter, walk through
Posted in Privacy and Compliance, Privacy Incidents | No Comments »
