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What No One Is Saying about That Big HIPAA Fine

By now you have probably seen that the U.S. Department of Health and Human Services (HHS) fined Cignet healthcare a whopping $4.3M for, and I believe this is a legal term, being total egotistical assholes. (Because “willfull neglect” just doesn’t have a good ring to it). This is all over the security newsfeeds, despite it having nothing to do with security. It’s so egregious I suggest that, if any vendor puts this number in their sales presentation, you should simply stand up and walk out of the room. Don’t even bother to say anything – it’s better to leave them wondering. Where do I come up with this? The fine was due to Cignet pretty much telling HHS and a federal court to f* off when asked for materials to investigate some HIPAA complaints. To quote the ThreatPost article: Following patient complaints, repeated efforts by HHS to inquire about the missing health records were ignored by Cignet, as was a subpoena granted to HHS’s Office of Civil Rights ordering Cignet to produce the records or defend itself in any way. When the health care provider was ordered by a court to respond to the requests, it disgorged not just the patient records in question, but 59 boxes of original medical records to the U.S. Department of Justice, which included the records of 11 individuals listed in the Office of Civil Rights Subpoena, 30 other individuals who had complained about not receiving their medical records from Cignet, as well as records for 4,500 other individuals whose information was not requested by OCR. No IT. No security breach. No mention of security issues whatsoever. Just big boxes of paper and a bad attitude. Share:

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On Science Projects

I think anyone who writes for a living sometimes neglects to provide the proper context before launching into some big thought. I please guilty as charged on some aspects of the Risk Metrics Are Crap FireStarter earlier this week. As I responded to some of the comments, I used the term science project to describe some technologies like GRC, SIEM, and AppSec. Without context, some folks jumped on that. So let me explain a bit of what I mean. Haves and Have Nots At RSA, I was reminded of the gulf between the folks in our business who have and those who don’t have. The ‘haves’ have sophisticated and complicated environments, invest in security, do risk assessment, hey periodically have auditors in their shorts, and are very likely to know their exposures. These tend to be large enterprise-class organizations – mostly because they can afford the requisite investment. Although you do see a many smaller companies (especially if they handle highly regulated information) that do a pretty good job on security. These folks are a small minority. The ‘have nots’ are exactly what it sounds like. They couldn’t care less about security, they want to write a check to make the auditor go away, and they resent any extra work they have to do. They may or may not be regulated, but it doesn’t really matter. They want to do their jobs and they don’t want to work hard at security. This tends to be the case more often at smaller companies, but we all know there are plenty of large enterprises in this bucket as well. We pundits, Twitterati, and bloggers tend to spend a lot of time with the haves. The have nots don’t know who Bruce Schneier is. They think AV keeps them secure. And they wonder why their bank account was looted by the Eastern Europeans. Remember the Chasm Lots of security folks never bothered to read Geoffrey Moore’s seminal book on technology adoption, Crossing the Chasm. It doesn’t help you penetrate a network or run an incident response, so it’s not interesting. Au contraire, if you wonder why some product categories go away and others become things you must buy, you need to read the book. Without going too deeply into chasm vernacular, early markets are driven by early adopters. These are the customers who understand how to use an emerging technology to solve their business problem and do much of the significant integration to get a new product to work. Sound familiar? Odds are, if you are reading our stuff, you represent folks at the early end of the adoption curve. Then there is the rest of the world. The have nots. These folks don’t want to do integration. They want products they buy to work. Just plug and play. Unless they can hit the Easy Button they aren’t interested. And since they represent the mass market (or mainstream in Moore’s lingo) unless a product/technology matures to this point, it’s unlikely to ever be a standalone, multi-billion-dollar business. 3rd Grade Science Fair Time and again we see that this product needs tuning. Or that product requires integration. Or isn’t it great how Vendor A just opened up their API. It is if you are an early adopter, excited that you now have a project for the upcoming science fair. If you aren’t, you just shut down. You aren’t going to spend the time or the money to make something work. It’s too hard. You’ll just move on to the next issue, where you can solve a problem with a purchase order. SIEM is clearly a science project. Like all cool exploding volcanoes, circuit boards, and fighting Legos, value can be had from a SIEM deployment if you put in the work. And keep putting in the work, because these tools require ongoing, consistent care and feeding. Log Management, on the other hand, is brain-dead simple. Point a syslog stream somewhere, generate a report, and you are done. Where do you think most customers needing to do security management start? Right, with log management. Over time a do make the investment to get to more broad analysis (SIEM), but most don’t. And they don’t need to. Remember – even though we don’t like it and we think they are wrong – these folks don’t care about security. They care about generating a report for the auditor, and log management does that just fine. And that’s what I mean when I call something a science project. To be clear, I love the science fair and I’m sure many of you do as well. But it’s not for everyone. Photo credit: “Science Projects: Volcanoes, Geysers, and Earthquakes” originally uploaded by Old Shoe Woman Share:

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Friday Summary: March 4, 2011

The Friday summary is our chance to talk about whatever, and this week I am going to do just that. This week’s introduction has nothing to do with security, so skip it if you are offended by such things. I am a fan of basketball – despite being too slow, too short, and too encumbered by gravity to play well. Occasionally I still follow my ‘local’ Golden State Warriors despite their playoff-less futility for something like 19 of the last 20 years. Not like I know much about how to play the game, but I like watching it when I can. Since moving to Phoenix over 8 years ago it’s tough to follow, but friends were talking last summer about the amazing rookie season performance of Stephen Curry and I was intrigued. I Googled him to find out what was going on and found all the normal Bay Area sports blogs plus a few independents – little more than random guys talking baskeball related nonesense. But one of them – feltbot.com – was different. After following the blog for a while an amazing thing happened: I noticed I could not stomach most of the mainstream media coverage of Warriors basketball. It not only changed my opinion on sports blogs, but cemented in my mind what I like about blogs in general – to the point that it’s making me rethink my own posts. The SF Bay Area has some great journalists, but it also has a number of people with great stature who lack talent, or the impetus to use their talent. These Bay Area personalities offer snapshots of local sports teams and lots of opinions, but very little analysis. They get lots of air but little substance. Feltbot – whoever he is – offers plenty of opinions, just like every other Bay Area sports blogger. And he has lots of biases, but they are in the open, such as being a Don Nelson fanboi. But his opnions are totally contrary to what I was reading and hearing on the radio. And he calls out everyone, from announcers to journalist when he thinks they are off the mark. What got me hooked was him going into great detail on why why – including lots of analysis and many specific examples to back up his assertions. You read one mainstream sports blog that says one thing, and another guy who says exactly the opposite, and then goes into great detail as to why. And over the course of a basketball season, what seemed like outlandish statements week one were dead on target by season’s end. This blog is embarrasing many of the local media folk, and downright eviscerating a few of them – making them look like clueless hacks. I started to realize how bad most of the other Bay Area sports blogs were (are); they provide minimal coverage and really poor analysis. Over time I have come to recognize the formulaic approach of the other major media personalities. You realize that most writers are not looking to analyze players, the coach, or the game – they are just looking for an inflammatory angle. Feltbot’s stuff is so much better that the other blogs I have run across that it makes me feel cheated. It’s like reading those late-career James Patterson novels where he is only looking for an emotional hook rather than trying to tell a decent story. For me, feltbot put into focus what I like to see in blogs – good analysis. Examples that illustrate the ideas. It helps a basketball noob like me understand the game. And a little drama is a good thing to stir up debate, but in excess it’s just clumsy shtick. Sometimes it takes getting outside security to remind me what’s important, so I’ll try to keep that in mind when I blog here. On to the Summary: Webcasts, Podcasts, Outside Writing, and Conferences Adrian’s Dark Reading post: DAM Market Observation. Mort cited for talking about cloud security at Bsides. Rich and Mike covered on the Tripwire blog. Rich quoted on SearchSecurity. Favorite Securosis Posts Rich: Always Assume. This is a post I did a while back on how I think about threat/risk modeling. In a post HBGary world, I think it’s worth a re-read. Mike Rothman: What No One Is Saying about That Big HIPAA Fine. Sometimes you just need to scratch your head. Adrian Lane: FireStarter: Risk Metrics Are Crap. Yeah, it was vague in places and intentionally incendiary, but it got the debate going. And the comments rock! Other Securosis Posts On Science Projects. Random Thoughts on Securing Applications in the Cloud. Network Security in the Age of Any Computing: the Risks. Incite 3/2/2011: Agent Provocateur. React Faster and Better: Index. React Faster and Better: Piecing It Together. Favorite Outside Posts Rich: Numbers Good. Jeremiah’s been doing some awesome work on web stats for a while now, and this continues the trend. Mike Rothman: Post-theft/loss Response & Recovery With Evernote. We need an IR plan for home as well. Bob does a good job of describing one way to make filing claims a lot easier. Adrian Lane: Network Security Management-A Snapshot. Really nice overview by Shimmy! Project Quant Posts NSO Quant: Index of Posts. NSO Quant: Health Metrics–Device Health. NSO Quant: Manage Metrics–Monitor Issues/Tune IDS/IPS. NSO Quant: Manage Metrics–Deploy and Audit/Validate. NSO Quant: Manage Metrics–Process Change Request and Test/Approve. Research Reports and Presentations The Securosis 2010 Data Security Survey. Monitoring up the Stack: Adding Value to SIEM. Network Security Operations Quant Metrics Model. Network Security Operations Quant Report. Understanding and Selecting a DLP Solution. White Paper: Understanding and Selecting an Enterprise Firewall. Understanding and Selecting a Tokenization Solution. Security + Agile = FAIL Presentation. Top News and Posts Alleged WikiLeaker could face death penalty. SMS trojan author pleads guilty. NIST SHA-3 Status Report. Robert Graham Predicts Thunderbolt’s an Open Gateway. Malware infects more than 50 Android apps. Thoughts on Quitting Security. Gh0stMarket operators sentenced. Blog Comment of the Week Remember, for every comment selected, Securosis makes a $25 donation to Hackers for Charity. This week’s best comment goes to Alex Hutton,

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