Archive for the ‘Information Security’ Category
Thursday, February 28th, 2013
Over the past few months I’ve been in increasingly more discussions, online and at in-person group meetings, about information security policies and exceptions; often more like venting sessions. A common theme is that the information security folks were complaining about how their companies’ managers are granting exceptions to their information security policies, or that they are always getting (more…)
Tags:audit, awareness, breach, compliance, customers, data protection, e-mail, electronic mail, email, employees, employment, exception management, hiring, HR, human resources, IBM, Information Security, information technology, infosec, IT security, job applicants, laws, messaging, midmarket, non-compliance, patients, personal information, personally identifiable information, personnel, PII, policies, policy exception, policy management, privacy, privacy breach, privacy professor, privacyprof, Rebecca Herold, risk, risk assessment, risk management, security, sensitive personal information, SPI, systems security, training, walk through
Posted in Information Security | 1 Comment »
Thursday, January 24th, 2013
A Tale of Two Viewpoints
When I was responsible for information security and privacy at a large financial and healthcare organization throughout the 1990’s I had literally hundreds of business partner organizations to which we outsourced various types of activities that required some type of access to our client and customer information. Add to that several hundred agents and, scarier still because they were not exclusively selling our products, brokers, and you can probably imagine the angst I felt when thinking about the ways in which all those other organizations were putting our information at risk. The contracts with them had a very brief requirement to “provide appropriate security controls” for the information, but that did not alleviate my worries. But, since at that time there were no data protection regulations in effect, the lawyers said this simple clause was enough. And then one of the outsourced entities had an incident resulting from lack of controls which allowed a hacker to enter our network. (more…)
Tags:audit, awareness, BA, BA Agreement, BA contract, breach, business associate, compliance, customers, data protection, due diligence, e-mail, electronic mail, email, employees, employment, Final Rule, HIPAA, hiring, HR, human resources, IBM, Information Security, information technology, infosec, IT security, job applicants, laws, Mega Rule, messaging, midmarket, non-compliance, Obmnibus, patients, personal information, personally identifiable information, personnel, PII, policies, privacy, privacy breach, privacy professor, privacyprof, Rebecca Herold, right to audit, risk, risk assessment, risk management, security, sensitive personal information, SPI, systems security, training, walk through
Posted in Information Security, Laws & Regulations | No Comments »
Friday, December 21st, 2012
This week I spoke with a small (~25 employees) organization (a business associate providing services to healthcare providers) that contacted me looking for help; they had purchased a whiz-bang “HIPAA compliance GRC” solution that included with everything else information security policies, but they couldn’t make any sense of the policies they were given or how they related to the rest of the expensive GRC tool. Grrr!! There are (more…)
Tags:audit, audits, awareness, BA, breach, business associate, business partner, CE, compliance, covered entity, customers, data protection, e-mail, electronic mail, email, employees, employment, HIPAA, hiring, HITECH, HR, human resources, IBM, Information Security, information technology, infosec, IT security, job applicants, laws, messaging, midmarket, non-compliance, patients, personal information, personally identifiable information, personnel, PII, policies, privacy, privacy breach, privacy professor, privacyprof, procedures, Rebecca Herold, risk, risk assessment, risk management, security, sensitive personal information, SPI, systems security, training, walk through
Posted in BA, CE, HIPAA, Information Security | 1 Comment »
Monday, December 17th, 2012
There have been a lot online posts and talk lately about risk management and the “proper” or “acceptable” way to do risk assessments. It seems that the overwhelming talk, though, is only about the right and wrong way to do a risk assessment whenever considering a risk management program. Certainly, using the best risk assessment method to fit your business environment is very important; one size, and one method, does not fit all! However, there are so many more activities necessary within a risk management program than just occasionally doing a risk assessment. Regulatory agencies are (more…)
Tags:audit, awareness, breach, compliance, customers, data protection, e-mail, electronic mail, email, employees, employment, facebook, fake IDs, hiring, HR, human resources, IBM, Information Security, information technology, infosec, IT security, job applicants, laws, messaging, midmarket, non-compliance, patients, personal information, personally identifiable information, personnel, PII, policies, privacy, privacy breach, privacy professor, privacyprof, Rebecca Herold, risk, risk assessment, risk management, security, sensitive personal information, social media, social networking, SPI, systems security, test data, training, twitter, walk through
Posted in Information Security | 2 Comments »
Tuesday, October 2nd, 2012
Okay, I just finished the 3rd conversation in just the past two weeks alone with an organization that is using Social Security Numbers (SSNs) as their primary form of customer and/or employee identification. I’ve written about this topic numerous times over the past 15 years. Seriously; all businesses out there doing this, please make a plan to stop doing this! Why? Here are three good reasons. (more…)
Tags:awareness, breach, compliance, customers, e-mail, electronic mail, email, employees, employment, hiring, HR, human resources, IBM, ID theft, identifiers, identity theft, IDs, Information Security, information technology, infosec, IT security, job applicants, messaging, midmarket, non-compliance, patients, personal information, personally identifiable information, personnel, PII, policies, privacy, privacy breach, privacy professor, privacyprof, Rebecca Herold, security, sensitive personal information, social security number, SPI, SSN, systems security, training
Posted in Information Security, Laws & Regulations | 1 Comment »
Monday, June 18th, 2012
June 22 update to this topic: Today the judge refused to block the release of the emails as Sebring and her lover requested. See http://www.desmoinesregister.com/article/20120622/NEWS/120622012/Judge-announces-decision-on-Sebring-email-release
In the past few weeks the use of emails at work has been in the news a lot in central Iowa, and the news quickly spread around the globe because of the sex and intrigue involved. Basically, approximately four months before the end of school, the Des Moines Superintendent of Schools at the time, Dr. Sebring, started sending what would end up being over 40 very personal and sexually explicit messages to
(more…)
Tags:awareness, breach, compliance, Des Moines, e-mail, electronic mail, email, IBM, Information Security, information technology, infosec, Iowa, IT security, messaging, midmarket, non-compliance, Omaha, personal information, personally identifiable information, PII, policies, privacy, privacy breach, privacy professor, privacyprof, public school, Rebecca Herold, Sebring, security, sensitive personal information, SPI, systems security, training
Posted in Information Security, Training & awareness | 4 Comments »
Tuesday, April 17th, 2012
Last week I provided Howard Anderson at HealthInfosecurity.com with some of my thoughts about the recent Utah Department of Health breach of the files of 900,000 individuals, and counting. He included some of my thoughts in his blog post, along with thoughts from others. I wanted to provide my full reply here, along with some expanded thoughts.
As background, for those of you who may not have heard of this hack yet, in a nutshell: (more…)
Tags:audit, breach, breach response, change controls, compliance, DTS, encryption, IBM, Information Security, information technology, infosec, IT security, Medicaid, midmarket, non-compliance, personal information, personally identifiable information, PHI, PII, policies, privacy, privacy breach, privacy professor, privacyprof, protected health information, Rebecca Herold, security, security engineering, sensitive personal information, SPI, systems security, Utah
Posted in BA, CE, healthcare, HIPAA, HITECH, Information Security, Privacy Incidents | No Comments »
Friday, March 2nd, 2012
I am looking forward to the day when we can look at the news headlines and not see some report about a lost or stolen computing device or storage device that contained unencrypted personal information and/or other sensitive information. And, I also want to stop seeing stories reappear about such an incident, such as the stolen NASA laptop with the clear text Space Station control codes that was stolen last year, but is making the headlines yet again today. NASA is a large enough, and tech savvy enough, organization to know better! However, there are many organizations that simply don’t understand what a valuable information security tool encryption is. I work with many small to medium sized businesses (SMBs), all of which have legal obligations (such as through HIPAA and HITECH, along with contractual requirements) to protect sensitive information, such as personal information. Over the past year I’ve heard way too many of them make remarks such as… (more…)
Tags:BA, business associate, CE, covered entity, encrypt, encryption, HIPAA, HITECH, IBM, medium business, midmarket, PHI, privacy, privacy professor, privacy rule, privacyprof, protected health information, Rebecca Herold, safeguards, security, security rule, small business, SMB, W-2, W2
Posted in Information Security | 1 Comment »
Sunday, January 8th, 2012
When looking ahead to what may happen in this new year it is necessary to first look back. Not only to 2011, but when making plans to move forward even further back to help make the best decisions moving forward. I do a lot of reading, including many mainstream publications written for the general public. You can see a lot of trends and problems by reading about how the general public is reporting (or not) about them. I also like to read the various publications specific to information security, privacy, compliance and technology to see the backstories and guts of the problems. Looking at all such reports helps to provide a more comprehensive view necessary for making good decisions. (more…)
Tags:2011, 2012, awareness, cloud computing, compliance, governance, GRC, Information Security, infosec, mobile computing, privacy, privacyprof, Rebecca Herold, security, Smart Grid, Smart Meter, training
Posted in Information Security, mobile computing, privacy | No Comments »
Saturday, December 10th, 2011
On October 10, 2011, there was a report in the Baltimore Sun, “Law firm loses hard drive with patient records: Attorneys represent St. Joseph cardiologist sued for malpractice.” I posted about the report to one of the LinkedIn groups I participate in, pointing out that this is yet one more example of (more…)
Tags:BA, Baltimore, business associate, cardiologist, CE, compliance, covered entity, HIPAA, HITECH, hospital, Information Security, lawyer, malpractice, PHI, privacy, privacy breach, Rebecca Herold, St. Joseph, subpoena
Posted in BA, CE, healthcare, HIPAA, HITECH, Information Security, Laws & Regulations, privacy, Privacy and Compliance | 6 Comments »
