Health care facilities are trying to get a handle on introducing and managing mobile devices in their facilities, but are finding it difficult to keep their data safe. If the loss of unencrypted laptops with confidential patient data has not already earned a facility a place on the Department of Health and Human Services (DHHS) wall of shame, the risk of data being accessed and stolen internally is sure to follow.
So far, over 25 health care facilities and associated businesses have been embarrassed this year by the August 2009 Breach Notification Rule included in the Health Information Technology for Economic and Clinical Health (HITECH) Act – where facilities and businesses are required to notify the appropriate agencies that a data breach has occurred which compromised the protected health information (PHI) of 500 individuals or more. A significant amount of breaches listed on the DHHS site include lost or stolen laptops and unauthorized access or hacking of the network.
The latest occurrence was the loss of a laptop in a doctor’s office in Miami FL, where 1,137 patient’s PHI was exposed. One of the largest incidents reported last year was AvMed, Inc.’s report of two unencrypted laptops stolen from a conference room, which contained names, dates of birth, addresses, social security numbers, and personal health information of nearly 1,220,000 patients. According to the U.S. Department of Homeland Security’s (DHS) National Cybersecurity and Communications Integration Center “poor physical security protective mechanisms or operational security awareness make it easy for thieves. In addition, lack of hardware encryption allows thieves direct access to all data stored on the device”.
In addition to weak physical security, internal access controls, and weak passwords, the DHS has found increased vulnerabilities in mobile devices that contain commercial operating systems, which are vulnerable to malware and viruses. This includes not only mobile devices connected to the network, but all mobile devices used by the organization. When the device is connected to both the internet and the hospital network, it poses a higher risk for breaches. Devices are vulnerable to cyber attacks that can take advantage of software vulnerabilities, lack of software patches, firmware vulnerabilities, and wireless connections – which could open the capabilities to gain access to the health care network. An example is the doctor’s of the University of Chicago’s use of iPads that were affected by a vulnerability in the Apple IOS, where malware was found affecting iTunes users who connected their iPads to Windows operating systems. Backdoor. Bifrose.AADY allowed remote control access by a third party and “pulled serial numbers and read passwords for different programs including POP3 email and any protected storage”. Malware related threats to computers on the network can occur when PHI data is synced and transferred with improperly configured mobile devices, introducing a new avenue of malware transfer.
The result of PHI exposure becomes a violation of HIPAA regulations which monetary penalties; reputation damage; public embarrassment; lawsuits; and possible loss of the medical practice or business can occur. Additionally, the patients who were involved in the incident can face both identity theft and the use of their personal data being sold on the black market.
There is no silver bullet in completely eliminating the risks of mobile devices on the network. However, there are ways to reduce the risk of exploitations, while performing due diligence to minimize penalties and lawsuits resulting from HIPAA/HITECH violations. The best approach is always a solid evaluation of an organization’s information security program. It is absolutely vital that a security program not only include identifying, assessing, and remediating high risk areas, but to ensure that all controls – technical, administrative, and physical – are working in synchronization to create a holistic security program. These three components must integrate seamlessly in order to eliminate gaps in security. Gaps in security controls can easily lead to vulnerabilities.
The benefits of using a security consulting firm are endless. Not only can they become a strategic partner in an organization’s efforts to maintain compliance, but they can also provide all of the components that would otherwise be inaccessible – which can include the cost of finding and maintaining staff with years of expertise; in-depth knowledge of current health care IT regulations; contracted IT staff with current technology skills; and most importantly, objectivity. Hackers, as well as internal and external threats are always one-step ahead of the security industry – making it impossible for security administrators to stay on-top. However, minimizing threats, continuously updating their holistic security programs, and utilizing the expertise of security consultants can make a difference.
 National Cybersecurity and Communications Integration Center, Attack Surface: Healthcare and Public Health Sector (U.S. Department of Homeland Security, 2012) 7.
 National Cybersecurity and Communications Integration Center 4.
As technology use increases due to people using computers and Internet access for business and personal reasons, there has also been an increase in malicious software (or “malware”). Malware is most known for its ability to wreak havoc on both a user’s computer and the network that it has infected.
While some problems caused by malware infection often include such annoyances as computer and network slowness, more serious problems include network breaches facilitated by malware on company computers.
Types of Malware
There are several types of malware, the most common of which are viruses, worms, trojans, and rootkits.
Viruses and Worms: Both viruses and worms are infectious, which means that they can and will spread to other computers. Viruses spread when they are accessed or run, while worms can spread without additional user intervention.
Trojans and Rootkits: These are malware programs that conceal their true identity. Trojans are usually embedded in another program and are installed by a user who does not realize what they are installing is harmful. Rootkits are a means of hiding the malware from the user. A rootkit allows the program the ability to continue by either hiding within the operating system or by thwarting attempts at removal if detected.
How Malware Gets In
Malware can be introduced into a network in a number of different ways. Users are often unaware that they have allowed malware onto their computer and network until it is too late. Common infection scenarios include downloading e-mail attachments from an unknown source, downloading files on the Internet, or visiting untrusted websites.
To ensure and protect the integrity of your network, you need to reduce the threat of malware. Here are some tips to help:
The most common misunderstood term seen in the security industry is Risk Management. If you Google the term “Risk Management”, you will find yourself buried in a pile of information ranging from financial risk management to business risk management. And if you happen to fall upon the actual security risk management concept, you may come across a blog post, or online article describing risk management incorrectly. Even when speaking with some corporate decision makers (and some IT professionals), the security term risk is often used interchangeably with other terms such as vulnerability and threat. I have seen vendors marketing tools that were for “Risk Management” but in reality, they were vulnerability management tools. I can truly understand why education must be made a priority when talking to decision makers prior to discussing a risk management assessment.
The terms risk, vulnerability and threat are three separate terms that work together:
1. Vulnerabilities – are holes and weaknesses in an organization, which are typically the easiest to find and remediate, usually through penetration and vulnerability tests.
2. Threat – is the possibility that something or someone will find out about the vulnerability and exploit it.
3. Risk – is the probability that a threat can become real, resulting in some form of impact on the business, should that vulnerability become exploited – the unanswered question is how badly will it hurt the organization. This is usually the hardest to calculate.
Some companies think they have a risk management program already in place, but due to the misunderstanding of terminology, will actually have a vulnerability program in place. I have had some companies actually refer to their traditional Enterprise Risk Management (ERM) program when asked if they had a risk management program in place – which is completely different from any security program. ERM includes credit, liquidity, regulatory compliance, and market risk, as well as risk transfer strategies, capital management, and strategy development. However, a solid IT Security Risk Management Program should be an integral part of a holistic ERM – which will cover the organizations risks more efficiently and effectively. After a brief explanation between the differences of the terms, it is quickly understood that their misunderstanding may have caused them to fall short in implementing a solid risk management program. Additionally, if the risk management program does not include and address all of the layers of the organization that can contain threats – such as administrative, technical, physical, operations, tactical, and strategic – it is not a risk management program.
Risk Management can be both complex and time consuming. The need to understand business, capital, and human resource issues, as well as management levels are critical during assessment – rather than looking at it solely through a technical perspective. An organization must attempt to read the future, determine what can happen, and how much it can cost.
Risk management should not solely rest on the shoulders of the CSO. It should be a collective effort by including decision makers and department heads throughout the entire organization that are knowledgeable and able to contribute to the process. Not only are they able to fully understand their department and the risks that take place – which are not just technical risks – they are also effectively positioned to enforce the plan, as well as assist in making changes to the culture of the organization starting within their department.
During the assessment, a tremendous amount data will be gathered and the current security component, as well as the business issues than can be affected by the current security in place, will be reviewed. Vulnerability and penetration tests will reveal what needs to be protected and how, and interviews with staff will provide information on gaps in policies and procedures. This process will allow organizations to learn their acceptable risk levels – which will tell them how much security they actually need. An organization’s policies should reflect acceptable risk levels in order to implement the right amount of security.
You can’t address all of your risks, and in many situations, it would not be necessary to do so. Once you associate the vulnerability with the threat, and how that threat can affect the business, this will clarify how to manage your risk. The vulnerability that has the highest threat and will cost the company the most if exploitation occurs will be the order in which risk should be managed.
Understanding what risk management truly is continues to be the best strategy in properly assessing your organization the first time around, which will save you money in the long-term. When this concept is not fully understood, organizations find themselves either spending too much money on security, or not enough money – yet still lacking the right countermeasures implemented for tangible and intangible assets or controls that actually need risk management.
With all of the statistics, comprehensive data, and war stories shared from security officer to security officer, I often wonder what is behind the thought process of decision makers declining assistance in implementing a cyber security risk assessment – especially organizations that clearly need it for compliance reasons.
I speak with many technology decision makers of fairly large companies regarding implementing a free cyber security risk assessment for their infrastructure. If I had a dollar for the amount of individuals within these organizations who believed that the assessment done over 2 years ago makes them prepared for the black hat techniques that advance faster than the pace of white hat security initiatives, I could hang up my coat and retire. There is a false sense of security that is prevalent in companies both large and small that believe if they were not significantly compromised in the last 3 or 4 years, their risk and compliance practices are consistent or above average with best practices in their industry. According to Economist Intelligence Unit Survey, “Ascending the Maturity Curve, Effective Management of Enterprise Risk and Compliance”, at least 87% of respondents agreed with this notion.
However, it is recommended that a review of an organizations security program should be done a minimum of every 2 years. And it is not only to their advantage to outsource this task to a reputable security consulting company in order to provide an objective point of view, something that is difficult to accomplish in-house, but to also use a different consulting company to continue to gain a different perspective each time. Rotating security consulting companies provides the opportunity to catch risks that may have been missed previously.
Although the financial services field was found to be most likely to have this false sense of security, the health care industry is barely on the map. The health care industry is just now beginning to embark on discovering a consistent risk assessment standard. Standards are underdeveloped as to how assessments and vulnerability remediation should be completed. Although HIPAA developed a requirement, a lot is left for interpretation. Unfortunately, this results in spotty assessments, or horrifically, no assessments done at all.
That’s why I scratch my head at a decision maker who turns down a free risk assessment. They have the opportunity to find out – utilizing a fresh pair of eyes – what may be exposed in their organization…for free. Addressing the risks, of course, is another subject. So, the next time you receive that call from a reputable security consultant about evaluating your risk assessment program that was implemented more than a year ago, reconsider. Hackers are not waiting every 2 years to develop new ways to crack you network – they are advancing each day.
Ensuring the security of your business network should be a priority for any company. Because so much work is done on your computer, storing files with important customer information and company secrets, it is crucial that a business protect that information as well as it can. Here are ten easy-to-implement tips for protecting the security of your network:
Although having an IT consultant can help you to limit damage if your network security is breached, this is one case in which prevention really is worth an ounce of cure. By creating a secure network ahead of time and working with your employees to implement safe practices, you can avoid damage or lost productivity before it occurs.