Allowing Wall Street privacy law exemption is crazy! Why, you ask? Why, I’m happy to explain. In March, 2012, I wrote “6 Good Reasons NOT To Ask for Facebook Passwords“. Since that time legislation prohibiting employers from requiring access to their employees’ protected areas of their social media accounts has been introduced or is pending in at least 35 states. Three states–Arkansas, New Mexico and (more…)
Posts Tagged ‘PHI’
The PHI PII Egg Hunt
Saturday, March 30th, 2013Locate it to protect it
I love speaking with folks about privacy, information security and compliance. I am sincerely interested in hearing about their challenges, and then also identifying common challenges amongst them all. We can then get to solutions.
One of the consistently common challenges I’ve heard from privacy and security folks in the past several months is trying to (more…)
Implementing a Data De-Identification Framework
Wednesday, November 21st, 2012Growing numbers of organizations are trying to figure out the benefits of anonymizing, or as HIPAA (the only regulation that provides specific legal requirements for such actions) puts it “de-identifying,” personal information. Healthcare organizations see benefits for improving healthcare. Their business associates (BAs) see benefits in the ways in which they can minimize the controls around such data. Of course marketing organizations salivate at the prospects of doing advanced analysis with such data to discover new trends and marketing possibilities. The government wants to use it for investigations. Historians want to use it for, yes, marking historical events. And the list (more…)
Lack of Basic Security Practices Results in $1.7 Million Sanction
Wednesday, June 27th, 2012July 4 Update to Original Post: See additional recent statements from the OCR and the Alaska DHSS about this case here.
Here is a significant sanction, just applied, that all organizations, of all sizes, need to take notice of. Even if you are not in the healthcare industry, this case points out the elements of an information security and privacy program, and the supporting safeguards, which will be used as a model of standard practices to by all types of regulatory oversight agencies. (more…)
Back to the Future Security Basics: Security through Obscurity Still Does Not Work
Tuesday, April 17th, 2012Last 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…)
6 Good Reasons to De-Identify Data
Friday, March 30th, 2012De-identification is a great privacy tool for all types of businesses, of all sizes. If you have personal data that you want to use for research, marketing, testing applications, statistical trending or some other legitimate purpose, but you don’t need to know the specific individuals involved in order to meet your goals, then you should consider de-identifying the personal data. Even though it sounds complicated there are many good methods you can use to accomplish de-identification. And the great thing is, (more…)
Encryption: Myths and Must Knows
Friday, March 2nd, 2012I 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…)
Is A W-2 PHI?
Monday, February 27th, 2012“Is a W-2 form protected health information?” is a simple question with a complex answer that begins (I know, to the nail-biting chagrin of many), “It depends…”
First the full question: (more…)
Make Privacy One of Your 2012 Resolutions
Tuesday, January 3rd, 2012Happy New Year! I hope your year is starting out great. Have you made it to day 3 without breaking any of your resolutions? How about adding one more… (more…)
Do Subpoenas Trump HIPAA and/or Trample Security Of PHI?
Saturday, December 10th, 2011On 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…)
