Category Archives: Controls

HIPAA COUNTDOWN – 26 DAYS LEFT TO COMPLY WITH HIPAA OMNIBUS RULE!

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The HIPAA Countdown continues, with the HIPAA Omnibus Rule compliance date of September 23rd looming in the distance.

Now that everyone is coming back to work, relaxed from the long weekend (we hope), it’s time to get back to work.

As a HIPAA Risk Analysis expert, I have gotten more than 300 calls and emails in the last 5 days (yes, even on Sunday) about
what NEEDS to be done right now.   Here’s a sample of the questions,

“Should I do a penetration test before Sept 23rd?”
“Should we update our policies before Sept. 23rd?”
“Should I hurry and get the laptops encrypted by Sept 23rd?” 
“We re-wrote our business agreements – what else do I need to do before Sept. 23rd?

To quote Leon Rodriguez, the Director of the Department of Health and Human Services, Office of Civil Rights, which is
the lead federal agency for HIPAA Enforcement, “The Number One Thing you need to do before September 23rd
is to update, or start a new HIPAA Risk Analysis.”  

According to the OCR Guideline on Risk Analysis,  “Conducting a risk analysis is the first step in identifying and
implementing safeguards that comply with and carry out the standards and implementation specifications in the Security
Rule. Therefore, a risk analysis is foundational, and must be understood in detail before OCR can issue meaningful
guidance that specifically addresses safeguards and technologies that will best protect electronic health information.”

This is why the First Area that OCR will address when they visit is:  “Where is your HIPAA Risk Analysis?”

Where is yours?  And has it been updated lately?

And did you know that Leon Rodriguez is on Twitter!  His twitter handle is @OCRLeon.

 

 

 

Oklahoma Tornado, Boston Bombing, Young Soldier Killed – It’s time to do a Security Risk Assessment!

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More Tornado victims will be buried this week.   Including many children who died at their schools because the school district didn’t spend the extra $3000 to have a storm cellar/safe room available.

One month ago, we watched as victims of the Boston Marathon Bombings were buried.

Yesterday, we watched an Islamic Jihadist savagely kill a  young British soldier with knives.

What other events do we have to witness before we start taking security assessments seriously?   How many more grieving parents do we have to watch crying on TV and, in my opinion, the casualities did not need to be so high and the aftermath so catastrophic.

If you group all these disasters together, you can that at the root of each one, is the feeling that, “IT CAN’T HAPPEN HERE”…..    Britain, for example, has tolerated mosques preaching hate, thinking that nothing like the knife attack could happen in civilized London.

In Moore, Oklahoma, people thought, “we already had a major tornado, so IT CAN’T HAPPEN AGAIN”!  Well, surprise – it happened again.  While forecasters cannot dictate the exact path of a tornado, they can get close, and with just fifteen minutes advance warning, there is  time to get everyone into storm cellars, safe rooms and underground shelters.  BUT IF THERE IS NO SHELTER AT A SCHOOL…….

Many obvious solutions-controls-safeguards were missed in these recent tragedies because proper, formal security risk assessments weren’t done effectively.  If they had been done, perhaps the London police could have picked up someone who touted murder and hate.

If a risk assessment had been done in Moore, OK, maybe the high risk of a tornado would have allowed the schools to all add the safe rooms they needed, and in Boston, the older brother Boston bomber, should have been in jail already for his participation in a previous murder – or at least actively monitored based on his facebook postings.

The clues are all there, and, looking backwards, you can see the pieces that SHOULD HAVE BEEN ENOUGH TO PROMOTE some kind of action to either:

        1. Eliminate the threat  or, 

              2. Reduce the severity of a potential threat in case it occurred.

Security risk assessments gather the numbers and the information organizations need to make better choices about how to protect people’s lives, facilities, and organizations.  I hope these events will prompt more Security Directors to take an objective and unbiased look at their own organizations, and the controls they have in place, before you end up on CNN!

 

Tragedy at the Boston Marathon – What Went Wrong?

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Looking at the CNN footage of the Boston Marathon finish line yesterday, I was struck by the shock of the bystanders and the chaos that followed the blasts.

Having just giving two seminars on security controls, I pulled out my list to see what could possibly have been done differently to prevent this devastating outcome, and there was the first word on the list ACCESS CONTROL.

After thirty years as a security expert and risk-threat analyst, I am about 85% sure that this was a lone wolf attacker who made his crude bombs to address some personal perceived problem, whether it was fear of gun legislation, spillover from the Israeli-Palestinian conflict, the Neo Con torture initiative, or something else.

Putting the attacker aside for a moment, the tragedy happened because SOMEONE WAS ABLE TO WALK RIGHT UP TO THE FINISH LINE AND PUT AT LEAST 3 BOMBS right near the finish line!   THiS IS NOT RIGHT.

There has to be SCREENING and ACCESS CONTROL PROCEDURES IN PLACE!  You can’t have security if you have open access to a major event like the Boston Marathon.  For year, security experts have cautioned that large crowds make a great target, and so events have paid lip service to this concept, without staying on the task, and making sure that SECURITY CONTROL NUMBER ONE –  ACCESS CONTROL  is ALWAYS in place.

But people don’t like access control, it’s too much trouble, they say.  They don’t like metal detectors, too expensive, too much trouble, too intrusive.  Well, it’s not as intrusive as having a major injury.   There are ways to secure these high profile sites, but the security community has to lead on this.

Yes, it is very sad and depressing that the world has come to this — but it has.  And it will happen again.  As long as security is perceived as too much trouble, too expensive, too tough to do, and too intrusive, there will be more tragic events like this one.

 

 

Wondering Which Security Controls Offer the Highest Protection for Less Money?

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Security Controls can be incredibly cost effective or astronomically expensive.  And when you’re faced with a facility or a school campus, or a system that has to be secured, but you also have a budget to keep in mind – what do you do?

The simple answer is ROI – Return on Investment.  This simple calculation compares the Cost of the Proposed Control to the Protection is Provides and that creates the magic ROI Number.

Here’s an example:   A hospital near the New Jersey shore wants to create a new emergency ops center.  They have the space,
but it would cost about $250,000 to build it out.  Here’s what we look at – how often would they use an emergency ops center?

Threat data shows that they would need to use it about 3-6

Operations Center (OPS)
Operations Center (OPS)

times a year, including severe storms, thunderstorms and hurricanes.

(After Hurricane Sandy, the hospital was closed for two days because they were not able to resume service right away.  As a result, the hospital lost about $2,000,000 per day because it could not bill for any services, none could be provided.)  

So we take that lost $2,000,000 per day and say that if we could keep the facility open because we had a better operational center, we could easily save 2 days of revenue which is $4,000,000 for the 2 days, and if it cost us only $ 250,000, and saves us $ 4,000,000, that’s a Return on Investment of SIXTEEN to ONE, 16:1.

Say it saved us 3 days of revenue a year – that’s a ROI of TWENTY-FOUR to ONE, 24:1!

You can get more info by writing to me directly at caroline@riskandsecurityllc.com and requesting a webinar invitation,
or a copy of the video.