Bridging the Gap Between Compliance and IT Security in Healthcare

It should come as no surprise that the per capita cost of a data breach is much higher for heavily regulated industries such as healthcare, financial and pharmaceuticals than for those less regulated, like retail and public services. But what might be surprising is that according to the 2013 Ponemon Cost of Data Breach Study, healthcare has surpassed the financial industry and now bears the highest cost of all – 70 percent above the overall mean value.

With the update last year to the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and HITECH Act of 2009, the cost will likely continue to increase. The annual cap on fines for security breaches has now increased from a maximum of $25,000 per year to $1.5 million. And fines are only part of the financial burden. Investigation and legal efforts, business downtime and decreased credibility all drive up costs even further.

Costs aren’t the only aspect of security on the rise – cyber threats are as well. According to the Cisco 2014 Annual Security Report, threat alerts grew 14 percent year-over-year. Whether a breach is a result of actions by an insider or a targeted attack from outside the organization, the goal is to find and stop the breach as quickly as possible to minimize damage.

But many healthcare organizations are challenged to effectively communicate and collaborate when it comes to security. In many of these organizations there is a department for privacy and compliance and then a separate department for enterprise IT security. Functional groups are often siloed and share very little information with each other. This becomes a major issue in the event of a breach as neither side is able to understand the full spectrum of the threat without the others’ data. Let’s take a look at a couple of examples.

These days we hear a lot about insider threats. An individual’s actions may look legitimate but when correlated with some other activity, it could indicate that malicious activity is occurring. A workstation that has always accessed clinical data or some other patient information doesn’t raise suspicion. But a subtle, steady increase in traffic, say of five or 10 percent, correlated with communication to an unauthorized or new IP address, likely indicates a breach. The same example could apply to an external threat with a malicious actor using social engineering methods to entice an unwitting user to download malware. Once inside the network, the malware can replicate the very same scenario. Either way, a breach has occurred. The IT security department may discover the situation, investigate and handle it and move on to the next task. But without visibility into this type of data, how would the compliance department learn about a possible data leakage and take the necessary steps to investigate and report?

On the flip side, the compliance department is the only group authorized to see private and sensitive patient data so there are very strong access controls to protect that information. But the compliance department doesn’t have the training or tools to spot unusual system activity. While the IT security department should not have access to privacy data, certain data can be summarized and presented to IT security without disclosing any sensitive information. Specifically, system data, such as total number of accesses by hosts or by role on a machine, won’t disclose patient records or clinical data but could indicate a potential breach and initiate an investigation.

It cuts both ways. For either side of the organization, limited data visibility and collaboration hampers the ability to identify a breach and, in turn, limit losses.

Technology and compliance leaders at healthcare organizations need to take a holistic approach to security risk management to allow for true visibility and full spectrum threat remediation.However, with limited budgets and priorities often, and rightfully, placed on patient care, many healthcare organizations lack the resources to take the necessary steps. Despite these constraints, with the right technology and best practices in place healthcare organizations can position themselves for success.

The same Ponemon report finds that the top three factors that decrease the cost of a breach include: having a CISO with overall responsibility for enterprise data protection, a strong security posture and an incident response plan. Below are a few recommendations to help healthcare organizations make inroads on these fronts.

A CISO with overall responsibility for enterprise data protection. Successfully bridging the gap between IT security and privacy/compliance is predicated on having support from the highest levels within the organization. An innovative C-level IT security executive who understands the challenges and appreciates the value that comes from an enterprise-wide approach to protecting data must be at the helm. The most effective CISOs are able to collaborate across the organization, aligning technology with business objectives to ensure risk tolerances are met while supporting business imperatives. They also understand the necessary action to take should a breach occur, including involving the appropriate parties to protect the organization and patients. And they know how to leverage technology to optimize resources while accomplishing the mission.

A strong security posture. With limited resources, healthcare organizations need to be savvy about technology investments. They need solutions that satisfy requirements now but can also carry them into the future. IT security teams should ask technology vendors the following questions:

What types of data can you integrate with? Healthcare companies needs to collect data from a large variety of sources including off-the-shelf and custom applications, including patient systems, infrastructure devices (switches, routers, firewalls, VPN concentrators, proxy servers, etc.), servers and desktops, application access logs and physical security data (badge access records). They also need to be able to add more sources easily over time.

How much data can you store and for how long? In the healthcare industry, regulations can require storing data for up to 10 years. Organizations need storage infrastructure that can support collection and analysis of increasingly large data sets over long timeframes. Traditional relational database technologies can be a poor match for storing and querying massive volumes of unstructured or semi-structured time series event data.

How can we access that data for audits and investigations? Stitching together a scenario for investigation takes time, money and is subject to error. Access to data in a single place with appropriate access controls by user is essential for an enterprise-wide approach. The ability to automatically analyze relevant data from patient systems and IT systems in order to identify anomalous patterns that could indicate potential malicious activity increases effectiveness.

An incident response plan. The Verizon 2013 Data Breach Investigations Report found that in 22 percent of the incidents investigated, it took months to contain the breach. Security events happen, yet many organizations don’t have an incident response plan in place with a designated team and documented processes and policies so that the right people are notified at the right time. With fines that mount as breaches progress, technology solutions that have an alerting mechanism that ties into the incident response process will help expedite investigation and action and minimize risk.

Healthcare organizations are facing cyber threats daily and the need to protect highly sensitive patient data is critical. Government fines are skyrocketing and for many healthcare organizations, paying the fines and enduring the collateral damage is a cost they can ill-afford. With a better understanding of the key ways to lower the costs of a breach, healthcare organizations can bridge the gap between the privacy office and the enterprise security department for a faster, more accurate and cost-effective approach to data protection.


Kim Lennan serves as Director of Healthcare Markets for Hexis Cyber Solutions, a subsidiary of The KEYW Holding Corporation based in Hanover, Maryland, which provides complete cybersecurity solutions for commercial companies, government agencies and the intelligence community.