Information Security Compliance
System Owner Training
Richard Gadsden
Information Security Office
Office of the CIO – Information Services
Sharon Knowles
Information Assurance Compliance
MUSC Medical Center
Overview
➲Information Security Fundamentals
➲HIPAA Security vs. HIPAA Privacy
● How the two regulations differ ● MUSC's compliance strategy ➲New Security Responsibilities
● Enterprise ● Covered Entities ● System Owners ● Other individualsInformation Security Process
➲The goal: protection of information assets
from threats to their:
● availability ● integrity ● confidentiality ➲Security is a process...
● not a product ● not really a state either ● not “set it and forget it”Information Security
A Risk Management Process
➲Risk management
● the process for making security decisions ➲Steps in the process
● identify significant risks ● evaluate possible controls ● implement the most costeffective set of controls that will keep risks within acceptable levels ➲Caveat: zero risk is not attainable
MUSC's Information Security Policy
System Owners Are Responsible For...
➲ Ensuring that accurate and thorough risk assessments are conducted and documented at appropriate points in the lifecycle of the System, beginning prior to the System's implementation, and that the findings are applied to the effective management of risks over the entire life of the System. ➲ Ensuring that appropriate Systemspecific policies, procedures and safeguards are developed and implemented, to comply with all applicable MUSC policies, any applicable Entity policies, and all applicable laws and regulations.Information Assurance
➲Standard of Due Care
● duty is to protect against “all reasonably anticipated threats” by implementing “reasonable and appropriate” safeguards ➲Reasonable and appropriate
● ideally, minimum but sufficient controls ● must avoid unacceptable risks ● must avoid unnecessary expenseReasonable and Appropriate
➲How to achieve?
● the risk management process ● assessment of risk ● evaluation and selection of controls ● approval, funding, implementation, operation ➲How to verify?
● the compliance process ● documentation ● audits and other reviewsInformation Assurance
Compliance Process
➲Document the level of assurance
● Are all security responsibilities clearly defined and understood? ● Is a sound (riskbased and costconscious) decisionmaking process being followed? ● Are security procedures documented? ● Are procedures being followed? ● Are controls working as intended?HIPAA: Security Rule vs. Privacy Rule
➲Security is more than just privacy
● confidentiality, integrity, availability ➲PHI vs. ePHI
● all electronic (“computerized”) PHI is subject to both the Privacy Rule and the Security Rule ● telephone and fax communications are subject to the Privacy Rule, but not the Security Rule ➲Covered Entities (CEs)
● responsible for compliance with both regulationsSecurity vs. Privacy: MUSC
➲Overall HIPAA compliance strategy
● Organizational: MUSC OHCA comprised of 4 CEs ➲Privacy Rule strategy
● policies were set by each MUSC Entity ➲Security Rule strategy
● One set of enterprisewide security policies ● these policies apply to all MUSC Entities ● not just for HIPAA/ePHI, but for all types of protected information ● 16 new policies and 1 updated policy were issued by the Office of the President in Feb 2005MUSC's Security Policies
➲Computer Use Policy (updated)
➲Information Security Policies (new)
● Information Security, Risk Management, Evaluation, Workforce Security, Awareness and Training, Incident Response, Contingency Plan, Workstation Use, Device and Media Controls, Access Control, Network Access, Audit Controls, Person or Entity Authentication, Data Integrity, Encryption, DocumentationNew Security Responsibilities
➲ Enterprise (Office of the CIO) ➲ Covered Entities (CEs) ➲ System Owners and System Administrators ➲ Managers and Supervisors ➲ Workforce membersResponsibilities: OCIO
➲Information Security Office (ISO) will:
● Document security architecture and plans ● Coordinate development of enterprise policies, standards, guidelines ● Manage Enterpriselevel safeguards ● Develop shared tools and services ● Direct MUSC's incident response team ● Conduct vulnerability assessmentsCovered Entities
➲ Each Entity will designate an Information Assurance Compliance Officer (IACO), who will: ● Monitor compliance (system owners, system administrators, managers, supervisors, workforce members) ● Report violations of policy to appropriate enforcement authorities ● Ensure access to documentation and trainingSystem Owners
➲Each System must have a designated
System Owner, who will:
● Assess and manage security risks ● Risk assessments and risk management plans must be documented if the system contains protected information (e.g. ePHI) ● Ensure that appropriate safeguards are implemented ● Some safeguards are required only if the System contains protected information (e.g. ePHI) ● Also, designate a System AdministratorMUSC Risk Management Standards
➲Standards established for managing risk at
4 stages in the System life cycle
● Initiation ● Development/Procurement ● Implementation ● PostImplementation ● aka “Existing Systems”Existing Systems
i.e.
“PostImplementation Stage”
➲Have you...
● Registered your system? ● Designated a System Administrator? ● Conducted a System risk assessment? ● Implemented appropriate safeguards? ● administrative measures ● physical security measures ● technical measures ● document, document, document...Step 1.0: Review MUSC Policies, Standards and Guidelines
Step 2.0: Document Current System Environment and Personnel ➲
Deliverable: Security Documentation,
Section 2 (System Identification)
●System Name
●Key System Personnel
●Functional Description
●Key Components
●System Boundaries
●Relationships with other systems
●interfaces, interdependencies
Step 3.0: Document Current SystemSpecific Security Procedures and Other Controls ➲
Deliverable: Security Documentation,
Section 3 (Current System Procedures)
➲Use the MUSC Information Security Policy
Compliance Checklist for System Owners
as a guide
➲http://www.musc.edu/security/tools
Step 4.0: Identify and Analyze Potential Issues ➲
Deliverable: Risk Analysis Worksheet
➲http://www.musc.edu/security/tools
➲Priorities
● Address policy compliance gaps identified using the Policy Checklist, or any other assessments ● Decide how to address other risks identified through formal risk analysis processStep 5.0: Develop Security Plan ➲
Deliverable: Security Plan Summary
➲http://www.musc.edu/security/tools
➲Document your plan for resolving all known
compliance gaps
● who ● what ● whenStep 6.0: Execute Security Plan ➲