Archive for the ‘Information Security’ Category

HIPAA: It is About the Information!

Friday, February 4th, 2011

NOTE: This is a repost for those that have browsers that could not open the original. Hopefully this will fix the problem!

Over the years I’ve had a lot of organizations ask me about whether HIPAA applies to faxes, copy machines, and other types of specific technologies.  It is very important that covered entities (CEs), business associates (BAs) and their subcontractors understand that HIPAA applies to protecting the information!  It doesn’t matter what the conduit is for how the information is transmitted, or where it is stored or accessed from.  The important point is that protected health information (PHI), in all forms, must be protected. The Security Rule applies to only electronic data, but the Privacy Rule and HITECH apply to all forms of PHI.  Okay; let’s keep this in mind when considering the following question I got earlier this week from a HIPAA business associate… (more…)

HIPAA: It’s About the Information!

Friday, February 4th, 2011

Over the years I’ve had a lot of organizations ask me about whether HIPAA applies to faxes, copy machines, and other types of specific technologies.  It is very important that covered entities (CEs), business associates (BAs) and their subcontractors understand that HIPAA applies to protecting the information!  It doesn’t matter what the conduit is for how the information is transmitted, or where it is stored or accessed from.  The important point is that protected health information (PHI), in all forms, must be protected. The Security Rule applies to only electronic data, but the Privacy Rule and HITECH apply to all forms of PHI.  Okay; let’s keep this in mind when considering the following question I got earlier this week from a HIPAA business associate… (more…)

HIPAA Compliance Investigations And The Insider Threat

Wednesday, February 2nd, 2011

I’ve been getting a lot more questions about HIPAA and HITECH lately from folks I’ve never met, but who have concerns about the security and privacy of their health information (“protected health information” or “PHI” as referenced within HIPAA/HITECH), businesses that are trying to understand how to protect PHI according to the regulatory requirements, and a growing number who express frustration with the unsecure ways in which clients, customers, patients and business partners are sharing information with them.  There just are not enough hours in the day to answer them all, but  I decided I’d start sharing some of the questions, and my corresponding answers, that seem to be topics that a wide range of readers may be interested in.

I was recently contacted by someone who had a question about a recent HIPAA complaint against Rowan Regional Medical Center (more…)

HIPAA/HITECH Final Rule Set To Be Published in March

Tuesday, January 4th, 2011

On December 20, 2010, the U.S. federal government published “Part II: Regulatory Information Service Center: Introduction to The Regulatory Plan and the Unified Agenda of Federal Regulatory and Deregulatory Actions.”  If you are a healthcare Covered Entity (CE), Business Associate (BA) or BA subcontractor, as defined under HIPAA and HITECH, this should be of interest to you.  Why?  Because within it is the long-awaited Department of Health and Human Services (HHS) timeline for when they would publish the final rule of the Notice of Proposed Rule Making (NPRM) that came out in July, 2010.  The date?  Well, (more…)

2011 Information Security, Privacy and Compliance Soothsaying

Monday, December 20th, 2010

Looking ahead to what will happen in the coming year is always an interesting exercise.  Just like within a great novel, foreshadowing occurs every day in our lives to drop the hints of things that are likely to come.  The trick is to separate out the valuable hints from the extraneous breadcrumbs that are dropped by dozens of other inconsequential sources that mislead us and cause us to fail in our predictions.   We shall see at the end of the year how close I am with the following predictions… (more…)

Reining In Mobile Computing Risks

Sunday, October 3rd, 2010

As demonstrated over and over again over the past several years, mobile computing devices and storage media present a huge risk to business and personal information.  Because of the portability of these devices, organizations are basically entrusting the security of the information stored upon them into the hands of the people using them.  It is vital that an effective mobile computing device and storage media security and privacy management program is in place.

A mobile computing device and storage media security and privacy management program should be able to answer the questions: (more…)

Smart Grid Privacy: Possible Privacy Standards To Address Concerns

Saturday, November 28th, 2009

Sorry to be so tardy in getting a blog post out. As many of you know I’ve been working with the NIST Smart Grid Privacy Subgroup since late June. The work done for this group is through time volunteered by all involved.
As a quick recap, I led the privacy impact assessment (PIA) for the consumer-to-utility portion of the planned smart grid during the late June to late August/early September time frame. On Friday, 11/20, I provided an update on our NIST groups activities during the Gridwise Alliance phone conference; perhaps some of you were on that call?
Here are some links showing information about our NIST Smart Grid privacy group’s work:

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HIPAA And Surveillance In Hospitals

Thursday, November 5th, 2009

Over the years there have been many…too many…instances where doctors have performed the wrong types of surgeries on patients, and even the wrong surgeries on completely wrong patients…

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Smart Grid Privacy: Laws and Implications

Wednesday, October 21st, 2009

I was recently asked several questions about my work with the NIST Smart Grid privacy group and associated issues. Here are a couple of those questions, and my answers to them…

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6 Critical Factors for Effective Information Security & Privacy Policies

Wednesday, October 14th, 2009

I’ve been feeling bad about not posting to my blog as often as I have historically…

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