Posts Tagged ‘Rebecca Herold’
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 »
Monday, April 29th, 2013
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…)
Tags:audit, awareness, breach, compliance, data protection, e-mail, electronic mail, email, employees, employment, exception management, facebook, FINRA, hiring, 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 Laws & Regulations, privacy | No Comments »
Saturday, March 30th, 2013
Locate 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…)
Tags:audit, awareness, BA, BA Agreement, BA contract, breach, business associate, compliance, customers, data inventory, data protection, e-mail, electronic mail, email, employees, employment, exception management, HIPAA, hiring, HITECH, HR, human resources, IBM, Information Security, information technology, infosec, IT security, job applicants, laws, liability, messaging, midmarket, non-compliance, Omnibus Rule, patients, personal information, personally identifiable information, personnel, PHI, 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, vendor management, vendor oversight, walk through
Posted in Information Security, PHI | 1 Comment »
Wednesday, March 27th, 2013
Don’t tell me it depends! Well, sorry, but…
I’ve been involved in several interesting discussions (some with lawyers, some with security folks, some with privacy folks, and a few of the folks wearing all three hats) about the liability of organizations that outsource business processing. Since January 17 I’ve also been working on a wide range of documentation changes to reflect the recently released 563 page tome that is the Final HIPAA Omnibus Rule. A significant part of the documentation and writing involves discussion of the increased liability a covered entity (CE) now has for the bad practices and mistakes made by their business associates (BAs).
Organizations want a clear cut answer to “how liable” they are for the actions of their outsourced entities. One CISO at a conference demanded, “Just tell me; are we going to be held responsible for the actions of our business associates or not? Just (more…)
Tags:audit, awareness, BA, BA Agreement, BA contract, breach, business associate, compliance, customers, data protection, e-mail, electronic mail, email, employees, employment, exception management, HIPAA, hiring, HITECH, HR, human resources, Information Security, information technology, infosec, IT security, job applicants, laws, liability, messaging, midmarket, non-compliance, Omnibus Rule, 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, vendor management, vendor oversight, walk through
Posted in BA, BA and Vendor Management, CE, HIPAA, HITECH, Information Security, Laws & Regulations | 1 Comment »
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 »
Wednesday, February 20th, 2013
Are you a covered entity (CE) or business associate (BA) as defined by HIPAA? There are literally millions of organizations in the U.S. that fall under these definitions, and possibly additional millions of BAs outside of the U.S. providing services to U.S.-based CEs. The impact is significant, and truly world-wide. If you are a CE or BA, did you know that your information security and privacy activities, or lack thereof, could cause physical harm to patients and insureds, and that you can receive significant penalties under the new HIPAA rules based upon those impacts? (more…)
Tags:audit, awareness, BA, BA Agreement, BA contract, breach, breach harm, breach response, business associate, compliance, contracted workers, customers, data protection, due diligence, e-mail, electronic mail, email, employees, employment, Final Rule, HIPAA, hiring, HITECH, HR, human resources, IBM, Information Security, information technology, infosec, IT security, job applicants, laws, liability, Mega Rule, messaging, midmarket, non-compliance, Obmnibus, outsource, oversight, patients, personal information, personally identifiable information, personnel, physical harm, 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 BA, CE, HIPAA, HITECH | No Comments »
Sunday, February 3rd, 2013
Over the years when working with a wide range of organizations, helping them to identify where all forms of their business information (including customer, client, patient and employee information) is located. One of the key activities is identifying and documenting all business associates, service providers, business partners, and all other types of outsourced entities that possess or have other types of access to this information. (more…)
Tags:audit, awareness, BA, BA Agreement, BA contract, breach, business associate, compliance, contracted workers, 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, liability, Mega Rule, messaging, midmarket, non-compliance, Obmnibus, outsource, oversight, 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 BA | No Comments »
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 »
