HIPAA Assessments are the next wave

In February, CVS was ordered to pay a fine of 2.5million dollars by the FTC. This fine was because their employees threw out personal information about patients. Who knew poor recycling programs could cost so much? HIPAA has been around for a number of years but not until recently did we see that it has teeth and companies are going to be held accountable. CVS has to have an assessment every other year now for 20 years. And assessments are not cheap! Assessments based on the Security Rule cover many areas of technology controls such as Firewall protection, Antivirus, Encryption, Vulnerability Scanning and much more. I am sure conducting an assessment rather than getting fines would have been much cheaper for CVS.

The definition of a Covered Entity for HIPAA compliance really reaches out to more companies than just hospitals and doctors offices. Not only companies like CVS will get fined but business partners of hopsitals and doctors offices storing patient data will be in trouble if they do not conduct Risk Assessments.

There are a number of ways to conduct these assessments, make them practical and stay out of trouble with “The Man”. One company that is pretty helpful in this regard is RiskWatch, http://www.riskwatch.com Their software allows you to conduct HIPAA, PCI, Red Flag Rule and other types of assessments.

For security professional, these regululations provide a strong insentive for companies to get their act together regarding privacy and security of data. Its unfortunate they have to be fined first to get them to the ball rolling. But hopefully, more will take a proactive stance for compliance but also to get an ongoing security program in place.

Regards
Gary Bahadur
http://www.kraasecurity.com
http://blog.kraasecurity.com
http://twitter.com/kraasecurity
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Vanguard Security Conference - Supplier Security

I spoke at the Vanguard Security Conference (http://www.go2vanguard.com) Vanguard has been doing this conference for a number of years. The focus is on Mainframe security. Most security professionals these days have never worked on MF security. I am proud to say I have back in the mid-90’s. We perhaps I shouldnt be do happy, it was over a decade ago.

The point being, that there are so many areas of security out there that most of us will never touch yet there is a dire need for professionals. The conference was less attended, as are most conferences this year, but I found the folks here are REALLY interested in learning and excited about the classes.

My topic was on Supplier Risk Management processe. You are asking yourself, what is that? I asked myself that same question in coming up with some good processes to target Supplier security. We have to go way beyond a SAS70 if you want real security over the hundreds or thousands of vendors that a large company may work with.

The Problem:

-No framework for managing vendor risk
-Inconsistent processes for tracking vendors
-Lack of enforcement capabilitiesThe Problem:

The Opportunity:

-Provide practical steps to manage vendor access/management
-Provide cost effective solution for risk mitigation
-Provide numerical risk analysis of vendor/partner security issues
-Risk reduction or risk acceptance
-Documented exposure
-Iterative process for risk management
-Happy CIO

So a Supplier Security assessment follow 4 main steps:

1 Analyze current vendor database, catageorize each determine risk of each supplier,

2 Determine threats posed by each supplier
3 Perform assessment tests of each supplier, their processes of interaction, and data access
4 Develop risk mitigation plan, update processed, monitoring processes

Gary Bahadur

baha@kraasecurity.com

http://www.kraasecurity.com

http://blog.kraasecurity.com

*Managed Security Services

*Vulnerability Management

*Compliance & Policy Development

*PGP Security

*FREE Website Security Test