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HIPAA Omnibus, Meet Indifference

Do you want to know what you will be reading about in the coming weeks? HIPAA. The Department of Health and Human Services has updated the HIPAA requirements. The 563-page package of regulations includes: Extensive modifications to the HIPAA privacy, security, and enforcement rules, including security and privacy requirements for business associates and their subcontractors. A final version of the HIPAA breach notification rule, which clarifies when a breach must be reported to authorities. Dramatic changes to marketing and fundraising requirements. Modifications to the Genetic Information Nondiscrimination Act (GINA) which prohibits health plans from disclosing genetic information for underwriting purposes. With topics such as breach notification and marketing constraints, it’s the page-turner you’d imagine it to be. Hundreds of pages of distilled public comments and final rulings. Even if you’re like me, and have an interest in these esoteric topics, they are just words on a page. Does this change anything? Probably not. We have been hearing about the serious nature of HIPAA and HITECH for about a decade without meaningful changes to data privacy or security for health related information. While there is a renewed focus on discouraging healthcare firms from marketing protected health data, or selling patient data to third-party marketing firms, there is little do promote proactive changes to data security or privacy. HIPAA will remain a “topic of interest”, but see little action until we see serious fines or someone goes to jail. Expect lots of media coverage and very little action. Share:

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It’s just Dropbox. What’s the risk?

From Ben Kepes’ post: Sure Dropbox is Potentially Insecure, but Does it Matter? First, why do people go around IT to use Dropbox? In the majority of cases these are good, solid, hardworking employees that don’t want to introduce risk to their organization but that do want to get stuff done. For whatever reason (inflexible legacy systems, stubborn IT departments, need to be agile) they’ve decided that for a particular project, they want to introduce Dropbox into their workflow to quickly and easily share some content. Evidently folks are storing important stuff in Dropbox, even though many of them know if violates their corporate policy. Duh. We have seen this over and over and over again through the years. Either IT and security helps employees get their jobs done, or employees find ways around the policies. Period. Then Ben gets into a discussion of risk, and trying to understand how bad all this file sharing is. He is trying to gauge the real risk of these folks storing that stuff on Dropbox. He uses a firefighter analogy too, so Rich must love this guy. It gets back to remembering the role of security, which is to ensure business operates safely. It would be great to just implement a blanket policy preventing Dropbox or any application you don’t like. Spend a zillion dollars on a whole mess of NGFW to enforce the policies, and everyone wins, no? It always comes back to making the right decision for your business. Don’t ever forget who you work for and why you are there. Ben sums up pretty well to close his post. Now of course my infosec friends are paid to be eternally suspicious. These guys are (professionally at least) glass half empty – their concerns are valid and they bring an important balance to the picture. But it’s just that, balance, at the same time we need to look long and hard at the benefits that “rogue IT” can bring and ask ourselves whether we shouldn’t in fact lighten up a little. There shouldn’t be absolutes, which irks me. I like clear black & white decisions. But that’s not the real world. If you are Dr. No, let me remind you of the immortal words of Sgt Hulka. Lighten up, Francis. I made my Stripes reference for the day, so I’m done. [drops mic] Share:

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