At the close of 2018, the Department of Health and Human Services (HHS) published Health Industry Cybersecurity Practices (HICP): Managing Threats and Protecting Patients. While not formally styled as guidance or interpretive material, when the primary regulator of patient and health data protection offers “suggestions,” those subject to HIPAA had better pay attention. Beyond highlighting common threats to the protection of patient data, the HICP encompasses two supplemental technical volumes centering on small organizations and medium and large organizations. Background Healthcare and life sciences organizations (particularly... more
If your organization has a website, it probably needs a publicly posted privacy notice explaining how personal data is (or is not) collected, used, protected, and shared. Privacy notices are expressly required under some laws, such as the EU’s General Data Protection Regulation (GDPR), the California Online Privacy Protection Act (CalOPPA), and the Australian Privacy Act. Even in countries where a privacy notice for an organization’s website is not expressly required, obligations to process personal data fairly, transparently, and lawfully often make developing a well-crafted... more
This past Friday, the Office of Civil Rights within the U.S. Department of Health and Human Services published a formal Request for Information on Modifying HIPAA Rules to Improve Coordinated Care. The RFI’s publication starts a 60-day comment period ending on February 12, 2019. As many of us prepare for the J.P. Morgan Healthcare Conference in January, and then HIMSS in February, savvy healthcare innovators and investors will recognize this RFI as an opportunity to help frame the discussion about how to lower privacy barriers... more
While references to “the cloud” and “cloud computing” are significantly more familiar than they were five years ago, it remains clear that many organizations implement cloud resources ineffectively – or at least do not understand the implications of the shift. Some all-too-common lines of thinking: We’ve moved our applications to our cloud provider – what does that have to do with our software development life cycle?; Our cloud-platform provider is responsible for securing our applications and data; or We’ve outsourced that – and all the... more
On November 30th, Marriott announced that a guest reservation database on the Starwood side of its business had been breached. Initial reports indicated that upwards of 500 million individuals were affected. The stolen data includes quite sensitive information, such as guest passport details and, likely, payment card information. Although it will probably take time before we fully understand the details of the incident – which appears to have continued unabated since 2014 – there are lessons that we can learn from the details already in... more
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