HCCA Compliance Institute 2013 Privacy & Security
|
|
- Myrtle Elliott
- 8 years ago
- Views:
Transcription
1 HCCA Compliance Institute 2013 Privacy & Security 704 Conducting a Privacy Risk Assessment A Practical Guide to the Performance, Evaluation and Response April 23, 2013 Presented By Eric Dieterich
2 Session Objectivities Identify your data privacy risk factors Recognize what regulatory requirements impact data privacy Understand the key attributes and what it takes to perform a privacy risk assessment Learn how to conduct and leverage the results of a privacy risk assessment Session Highlight We will have Live Voting throughout the session. Participation is optional Can TEXT or submit response at Voting results are anonymous 2
3 Introduction Eric Dieterich, CISA, CRISC, CIPP/US Partner Sunera LLC Sunera is a leading provider of business consulting and technology risk management services throughout the United States and Canada. Responsible for the IT Advisory Services in South Florida and leads the National Data Privacy practice. Over 12 years of IT advisory and governance experience with regulatory and industry standards including GLBA, HIPAA, HITECH, MA 201 CMR and the PCI DSS. 3
4 Introduction Video Short video clip showing how one little event may lead to a much larger issue. 4
5 Why is a Data Privacy Risk Assessment Important? There is a growing body of laws, regulations and legal agreements across the globe that govern how personal information should be: Collected Processed Stored Shared Collected Processed Stored Shared An breach could result in: Regulatory or legal action Direct financial loss Loss of customer or employee confidence Damage to the brand reputation 5
6 POLL QUESTION 6
7 Business Drivers for a Data Privacy Program Its not if, but when! 7
8 Business Drivers for a Data Privacy Program HIPAA Risk Analysis Requirements under the Security Rule The Security Management Process standard in the Security Rule requires organizations to implement policies and procedures to prevent, detect, contain, and correct security violations. (45 C.F.R (a)(1).) Risk analysis is one of four required implementation specifications that provide instructions to implement the Security Management Process standard. Section (a)(1)(ii)(A) states: RISK ANALYSIS (Required) - Conduct an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of electronic protected health information held by the organization. A privacy risk assessment can help your organization understand the privacy related risks not just focusing on the Security Rule. 8
9 The Risks! Data privacy risks revolve around the inappropriate or unauthorized collection, use, retention, and disclosure of protected health information, personal information or business sensitive information. The three key risks to be considered when determining the overall data privacy risks include: (1) Legal (2) Reputation (3) Operational Increasing focus on business sensitive information. Digital intruders are increasingly targeting information about high-stakes business deals -- from mergers and acquisitions to joint ventures to long-term supply agreements -- and companies routinely conceal these breaches from the public, say government officials and security companies. Bloomberg, November 4,
10 Recent Data Breaches Wyndham Worldwide Breach Description: June 2012, The U.S. Federal Trade Commission has filed a lawsuit against hotel chain Wyndham Worldwide and three subsidiaries for allegedly storing data in plain text and other security failures that enabled hackers to access more than 600,000 payment card accounts in three data breaches in less than two years. The hackers used the data stolen from Wyndham's data center in Phoenix to make transactions, resulting in fraud losses of more than $10.6 million, the suit says. Impact: The FTC suit alleges that Wyndham's privacy policy misrepresented the security measures the company and its subsidiaries took to protect customer personal information. BlueCross BlueShield Breach Description: March 2012; The insurer today agreed to pay $1.5 million to the U.S. Department of Health and Human Services (HHS) to settle Health Insurance Portability and Accountability Act (HIPAA) violations related to the breach. Under the settlement, BlueCross BlueShield has also agreed to review and revise its privacy and security policies and to regularly train employees on their responsibilities under the HIPAA of The settlement is the first resulting from enforcement action taken by the HHS under Health Information Technology for Economic and Clinical Health (HITECH) breach notification requirements. 10
11 POLL QUESTION 11
12 Healthcare Data Breaches on the Rise! Organizations that have experienced data breach involving the loss of patient data in the past two years. Ponemon Institute, Inc., Third Annual Benchmark Study on Patient Privacy & Data Security, December
13 Healthcare Data Breaches on the Rise! Type of data that was lost or stolen. Ponemon Institute, Inc., Third Annual Benchmark Study on Patient Privacy & Data Security, December
14 Breach Related Expenses Notification Public Relations Forensics Legal Creating letter or other notification Advertising & Press Releases Legal Expenses for Outside Attorney Response to Claims or Suits Printing or design Mailing or other transmission Call Center Operations Other Services for Effected Persons: Credit Monitoring Cost of Forensic Examination Cost To Remediate Discovered Vulnerabilities Payment of Judgments or Settlements 14
15 DATA PRIVACY REGULATIONS 15
16 Data Privacy Regulatory Implications Federal, State, and industry specific regulations govern the collection, use, and storage of personal information. HIPAA Security and Privacy Rule / HITECH Act State Privacy/Security Regulations State Breach Notification Requirements GLBA Payment Card Industry (PCI DSS) 16
17 HIPAA Notifications Notice to individuals must be provided in written or electronic format. Notice must be provided to prominent media outlets following the discovery of breaches that involved the information of 500 or more individuals. If the breach affected more than 500 individuals, notice must also be provided immediately to the Secretary of Health and Human Services. HHS will post on website If fewer than 500, keep a log of breaches and submit annually to HHS. Notice must be provided 60 calendar days after discovery Discovery is the first day the breach is known or should reasonably have been known Allows for delay if law enforcement is involved 17
18 State Breach Notification Laws 47 states plus Washington DC have passed breach notification legislation. State breach notification laws often require that a government agency (attorney general or a state appointed privacy commission) and/or credit agencies be notified of the data breach. 18
19 DATA PRIVACY RISK ASSESSMENT METHODOLOGY 19
20 Data Privacy Risk Assessment Understanding the Information Life Cycle Defining Establish a framework for controlling how sensitive data is collected, processed, stored, and shared throughout an organization. Collect Importance Enables the implementation of policies, procedures, and controls that will reduce the complexities, risks, and costs associated with sensitive data. Share Information Life Cycle Process Strategy Understanding of how and where information flows through all business processes. A framework can then be established to ensure sensitive information is protected throughout the information life cycle. Store 20
21 Data Privacy Risk Assessment Understanding the Information Life Cycle Creating detailed process flows of the information life cycle provides many added benefits: Baselines current business operations including data collection and storage practices, Helps identify security and privacy controls, Reduces impact on business operations during future audits and assessments, and When used in combination with a detailed data inventory, it can help identify the scope of a potential breach in an expedient manner. 21
22 POLL QUESTION 22
23 Data Privacy Risk Assessment Framework Design Key Activities Creation of a risk catalog for the processes that collect, process, or store personal information. An overall inherit risk profile is scored for each key process. The identification and evaluation of mitigating factors are evaluated. Overall risk score for each key process is calculated that will help identify areas of data privacy risk across the enterprise Results can drive the definition of a roadmap to mitigate these risks. 23
24 Data Privacy Risk Assessment Defining the Risk Criteria Electronic Privacy Risks 24
25 Data Privacy Risk Assessment Defining the Risk Criteria Paper File Privacy Risks 25
26 Data Privacy Risk Assessment Defining the Risk Criteria Application Privacy Risks Vendor Privacy Risks 26
27 Data Privacy Risk Assessment Evaluate Inherit Risk For each process or sub-process, the inherent risks need to be evaluated. The risk criteria should be defined specific for your organization, ensuring they address all relevant data privacy risks including both paper and electronic files. The matrix below identifies how the inherent risk could be scored for each risk and unique vendor or application specific risks. 27
28 Data Privacy Risk Assessment Evaluate Risk Mitigation Techniques Through the discovery sessions, you should attempt to identify any risk mitigation factors that are in place for each data privacy risk. A risk mitigation score can be assigned including the ability to assign different scores based on the level of certainty that the risk mitigation technique is effective. The matrix below shows how a risk mitigation technique can be used to lower the inherit risk for each privacy risk factor. 28
29 Data Privacy Risk Assessment Evaluate Risk Mitigation Techniques 29
30 Data Privacy Risk Assessment Evaluate Residual Risk Taking into account the inherent risk ranking and risk mitigation techniques, an overall residual risk score can be calculated. The matrix below identifies how the overall data privacy risk score can be calculated. The overall risk score is a key factor in defining a roadmap that helps lowers the data privacy risks identified throughout the enterprise. 30
31 Contact Information Eric Dieterich Partner (786)
By Ross C. D Emanuele, John T. Soshnik, and Kari Bomash, Dorsey & Whitney LLP Minneapolis, MN
Major Changes to HIPAA Security and Privacy Rules Enacted in Economic Stimulus Package By Ross C. D Emanuele, John T. Soshnik, and Kari Bomash, Dorsey & Whitney LLP Minneapolis, MN The HITECH Act is the
More informationThe Impact of HIPAA and HITECH
The Health Insurance Portability & Accountability Act (HIPAA), enacted 8/21/96, was created to protect the use, storage and transmission of patients healthcare information. This protects all forms of patients
More informationCOMPLIANCE ALERT 10-12
HAWAII HEALTH SYSTEMS C O R P O R A T I O N "Touching Lives Every Day COMPLIANCE ALERT 10-12 HIPAA Expansion under the American Recovery and Reinvestment Act of 2009 The American Recovery and Reinvestment
More informationData Security Breaches: Learn more about two new regulations and how to help reduce your risks
Data Security Breaches: Learn more about two new regulations and how to help reduce your risks By Susan Salpeter, Vice President, Zurich Healthcare Risk Management News stories about data security breaches
More informationData Breach and Senior Living Communities May 29, 2015
Data Breach and Senior Living Communities May 29, 2015 Todays Objectives: 1. Discuss Current Data Breach Trends & Issues 2. Understanding Why The Senior Living Industry May Be A Target 3. Data Breach Costs
More informationHIPAA Data Breaches: Managing Them Internally and in Response to Civil/Criminal Investigations
HIPAA Data Breaches: Managing Them Internally and in Response to Civil/Criminal Investigations Health Care Litigation Webinar Series March 22, 2012 Spence Pryor Paula Stannard Jason Popp 1 HIPAA/HITECH
More informationADMINISTRATIVE REGULATION EFFECTIVE DATE: 1/1/2016
Page 1 of 9 CITY OF CHESAPEAKE, VIRGINIA NUMBER: 2.62 ADMINISTRATIVE REGULATION EFFECTIVE DATE: 1/1/2016 SUPERCEDES: N/A SUBJECT: HUMAN RESOURCES DEPARTMENT CITY OF CHESAPEAKE EMPLOYEE/RETIREE GROUP HEALTH
More informationSTANDARD ADMINISTRATIVE PROCEDURE
STANDARD ADMINISTRATIVE PROCEDURE 16.99.99.M0.26 Investigation and Response to Breach of Unsecured Protected Health Information (HITECH) Approved October 27, 2014 Next scheduled review: October 27, 2019
More informationIntelligent Vendor Risk Management
Intelligent Vendor Risk Management Cliff Baker, Managing Partner, Meditology Services LeeAnn Foltz, JD Compliance Resource Consultant, WoltersKluwer Law & Business Agenda Why it s Needed Regulatory Breach
More informationREPRODUCTIVE ASSOCIATES OF DELAWARE (RAD) NOTICE OF PRIVACY PRACTICES PLEASE REVIEW IT CAREFULLY.
REPRODUCTIVE ASSOCIATES OF DELAWARE (RAD) NOTICE OF PRIVACY PRACTICES THIS NOTICE DESCRIBES HOW PROTECTED HEALTH INFORMATION (PHI) ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS
More informationCase 2:13-cv-01887-ES-JAD Document 282-1 Filed 12/09/15 Page 1 of 18 PageID: 4861 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY
Case 2:13-cv-01887-ES-JAD Document 282-1 Filed 12/09/15 Page 1 of 18 PageID: 4861 THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY Federal Trade Commission, Plaintiff, v. Wyndham Worldwide
More informationNew HIPAA Rules and EHRs: ARRA & Breach Notification
New HIPAA Rules and EHRs: ARRA & Breach Notification Jim Sheldon-Dean Director of Compliance Services Lewis Creek Systems, LLC www.lewiscreeksystems.com and Raj Goel Chief Technology Officer Brainlink
More informationData Breach Cost. Risks, costs and mitigation strategies for data breaches
Data Breach Cost Risks, costs and mitigation strategies for data breaches Tim Stapleton, CIPP/US Deputy Global Head of Professional Liability Zurich General Insurance Data Breaches: Greater frequency,
More informationAre You Still HIPAA Compliant? Staying Protected in the Wake of the Omnibus Final Rule Click to edit Master title style.
Are You Still HIPAA Compliant? Staying Protected in the Wake of the Omnibus Final Rule Click to edit Master title style March 27, 2013 www.mcguirewoods.com Introductions Holly Carnell McGuireWoods LLP
More informationGuided HIPAA Compliance
Guided HIPAA Compliance HIPAA Solutions for Office Managers and Practitioners SecurityMetrics We protect business Since its founding in 2000, privately-held SecurityMetrics has grown from a small security
More informationHIPAA and the HITECH Act Privacy and Security of Health Information in 2009
HIPAA and the HITECH Act Privacy and Security of Health Information in 2009 What is HIPAA? Health Insurance Portability & Accountability Act of 1996 Effective April 13, 2003 Federal Law HIPAA Purpose:
More informationWhat Health Care Entities Need to Know about HIPAA and the American Recovery and Reinvestment Act
What Health Care Entities Need to Know about HIPAA and the American Recovery and Reinvestment Act by Lane W. Staines and Cheri D. Green On February 17, 2009, The American Recovery and Reinvestment Act
More informationCSR Breach Reporting Service Frequently Asked Questions
CSR Breach Reporting Service Frequently Asked Questions Quick and Complete Reporting is Critical after Data Loss Why do businesses need this service? If organizations don t have this service, what could
More informationA s a covered entity or business associate, you have
Health IT Law & Industry Report VOL. 7, NO. 19 MAY 11, 2015 Reproduced with permission from Health IT Law & Industry Report, 07 HITR, 5/11/15. Copyright 2015 by The Bureau of National Affairs, Inc. (800-372-1033)
More informationBusiness Associates and HIPAA
Business Associates and HIPAA What BAs need to know to comply with HIPAA privacy and security rules by Dom Nicastro White paper The lax days of complying with privacy and security laws are over for business
More informationEverett School Employee Benefit Trust. Reportable Breach Notification Policy HIPAA HITECH Rules and Washington State Law
Everett School Employee Benefit Trust Reportable Breach Notification Policy HIPAA HITECH Rules and Washington State Law Introduction The Everett School Employee Benefit Trust ( Trust ) adopts this policy
More informationChecklist for HITECH Breach Readiness
Checklist for HITECH Breach Readiness Checklist for HITECH Breach Readiness Figure 1 describes a checklist that may be used to assess for breach preparedness for the organization. It is based on published
More informationInformation Protection Framework: Data Security Compliance and Today s Healthcare Industry
Information Protection Framework: Data Security Compliance and Today s Healthcare Industry Executive Summary Today s Healthcare industry is facing complex privacy and data security requirements. The movement
More informationProtecting Personal Information: The Massachusetts Data Security Regulation (201 CMR 17.00)
Protecting Personal Information: The Massachusetts Data Security Regulation (201 CMR 17.00) May 15, 2009 LLP US Information Security Framework Historically industry-specific HIPAA Fair Credit Reporting
More informationNerds and Geeks Re-United: Towards a Practical Approach to Health Privacy Breaches. Gerard M. Stegmaier gstegmaier@wsgr.
Nerds and Geeks Re-United: Towards a Practical Approach to Health Privacy Breaches Gerard M. Stegmaier gstegmaier@wsgr.com @1sand0slawyer Data Breach Trends 2011 Average Loss to Organization = $5.5 million
More informationSustainable HIPAA Compliance: Protecting Patient Privacy through Highly Leveraged Investments
View the Replay on YouTube Sustainable HIPAA Compliance: Protecting Patient Privacy through Highly Leveraged Investments FairWarning Executive Webinar Series October 31, 2013 Today s Panel Chris Arnold
More informationNew Privacy Laws Impacting the Health Care Work Place
New Privacy Laws Impacting the Health Care Work Place Presented by Thomas E. Jeffry, Jr., Esq. Arent Fox LLP Washington, DC New York, NY Los Angeles, CA November 12 & 19, 2009 Overview 1. Overview of California
More informationShipman & Goodwin LLP. HIPAA Alert STIMULUS PACKAGE SIGNIFICANTLY EXPANDS HIPAA REQUIREMENTS
Shipman & Goodwin LLP HIPAA Alert March 2009 STIMULUS PACKAGE SIGNIFICANTLY EXPANDS HIPAA REQUIREMENTS The economic stimulus package, officially named the American Recovery and Reinvestment Act of 2009
More informationOverview of the HIPAA Security Rule
Office of the Secretary Office for Civil Rights () Overview of the HIPAA Security Rule Office for Civil Rights Region IX Alicia Cornish, EOS Sheila Fischer, Supervisory EOS Topics Upon completion of this
More informationWhat do you need to know?
What do you need to know? DISCLAIMER Please note that the information provided is to inform our clients and friends of recent HIPAA and HITECH act developments. It is not intended, nor should it be used,
More informationSINGAPORE HEALTHCARE ENTERPRISE RISK MANAGEMENT CONGRESS 2014 - Data Breach : The Emerging Threat to Healthcare Industry
SINGAPORE HEALTHCARE ENTERPRISE RISK MANAGEMENT CONGRESS 2014 - Data Breach : The Emerging Threat to Healthcare Industry DATA BREACH A FICTIONAL CASE STUDY THE FIRST SIGNS OF TROUBLE Friday, 5.20 pm :
More informationHIPAA Privacy and Security Changes in the American Recovery and Reinvestment Act
International Life Sciences Arbitration Health Industry Alert If you have questions or would like additional information on the material covered in this Alert, please contact the author: Brad M. Rostolsky
More informationUpdated HIPAA Regulations What Optometrists Need to Know Now. HIPAA Overview
Updated HIPAA Regulations What Optometrists Need to Know Now The U.S. Department of Health & Human Services Office for Civil Rights recently released updated regulations regarding the Health Insurance
More informationSAMPLE BUSINESS ASSOCIATE AGREEMENT
SAMPLE BUSINESS ASSOCIATE AGREEMENT This is a draft business associate agreement based on the template provided by HHS. It is not intended to be used as is and you should only use the agreement after you
More informationBREVIUM HIPAA BUSINESS ASSOCIATE TERMS AND CONDITIONS
BREVIUM HIPAA BUSINESS ASSOCIATE TERMS AND CONDITIONS The following HIPAA Business Associate Terms and Conditions (referred to hereafter as the HIPAA Agreement ) are part of the Brevium Software License
More informationCyber and Privacy Risk What Are the Trends? Is Insurance the Answer?
Minnesota Society for Healthcare Risk Management September 22, 2011 Cyber and Privacy Risk What Are the Trends? Is Insurance the Answer? Melissa Krasnow, Partner, Dorsey & Whitney, and Certified Information
More information2015 Minnesota e-health Summit Data Privacy and Security Prevailing Federal Laws for Local Public Health
2015 Minnesota e-health Summit Data Privacy and Security Prevailing Federal Laws for Local Public Health Adam Stone, MBA, CISSP, CIPP/US, ISSMP, HCISPP, CHPS Secure Digital Solutions, LLC 952-544-0234
More informationBreach Notification Policy
1. Breach Notification Team. Breach Notification Policy Ferris State University ( Ferris State ), a hybrid entity with health care components, has established a Breach Notification Team, which consists
More informationNew HIPAA Breach Notification Rule: Know Your Responsibilities. Loudoun Medical Group Spring 2010
New HIPAA Breach Notification Rule: Know Your Responsibilities Loudoun Medical Group Spring 2010 Health Information Technology for Economic and Clinical Health Act (HITECH) As part of the Recovery Act,
More informationHIPAA AND MEDICAID COMPLIANCE POLICIES AND PROCEDURES
SALISH BHO HIPAA AND MEDICAID COMPLIANCE POLICIES AND PROCEDURES Policy Name: HIPAA BREACH NOTIFICATION REQUIREMENTS Policy Number: 5.16 Reference: 45 CFR Parts 164 Effective Date: 03/2016 Revision Date(s):
More informationANATOMY of a DATA BREACH DISASTER. Avoiding a Cyber Catastrophe. June, 2011. Sponsored by:
ANATOMY of a DATA BREACH DISASTER Avoiding a Cyber Catastrophe June, 2011 Sponsored by: ANATOMY of a DATA BREACH DISASTER Avoiding a Cyber Catastrophe An Advisen Special Report Sponsored by Chartis Security
More informationDeveloping HIPAA Security Compliance. Trish Lugtu CPHIMS, CHP, CHSS Health IT Consultant
Developing HIPAA Security Compliance Trish Lugtu CPHIMS, CHP, CHSS Health IT Consultant Learning Objectives Identify elements of a HIPAA Security compliance program Learn the HIPAA Security Rule basics
More informationLessons Learned from Recent HIPAA and Big Data Breaches. Briar Andresen Katie Ilten Ann Ladd
Lessons Learned from Recent HIPAA and Big Data Breaches Briar Andresen Katie Ilten Ann Ladd Recent health care breaches Breach reports to OCR as of February 2015 1,144 breaches involving 500 or more individual
More informationHIPAA Hot Topics. Audits, the Latest on Enforcement and the Impact of Breaches. September 2012. Nashville Knoxville Memphis Washington, D.C.
HIPAA Hot Topics Audits, the Latest on Enforcement and the Impact of Breaches September 2012 Nashville Knoxville Memphis Washington, D.C. Overview HITECH Act HIPAA Audit Program: update and initial results
More informationHealthcare Practice. HIPAA/HITECH Act vs. the Washington Data Breach Notification Act. November 2009
Healthcare Practice HIPAA/HITECH Act vs. the Washington Data Breach Notification Act November 2009 HIPAA/HITECH Background Healthcare Practice Stephen Rose srose@gsblaw.com 206.464.3939 Ext 1375 Larry
More informationAuditing your institution's cybersecurity incident/breach response plan. Baker Tilly Virchow Krause, LLP
Auditing your institution's cybersecurity incident/breach response plan Objectives > Provide an overview of incident/breach response plans and their intended benefits > Describe regulatory/legal requirements
More informationData Breach, Electronic Health Records and Healthcare Reform
Data Breach, Electronic Health Records and Healthcare Reform (This presentation is for informational purposes only and it is not intended, and should not be relied upon, as legal advice.) Overview of HIPAA
More informationThe Institute of Professional Practice, Inc. Business Associate Agreement
The Institute of Professional Practice, Inc. Business Associate Agreement This Business Associate Agreement ( Agreement ) effective on (the Effective Date ) is entered into by and between The Institute
More informationHIPAA/HITECH Privacy and Security for Long Term Care. Association of Jewish Aging Services 1
HIPAA/HITECH Privacy and Security for Long Term Care 1 John DiMaggio Chief Executive Officer, Blue Orange Compliance Cliff Mull Partner, Benesch, Healthcare Practice Group About the Presenters John DiMaggio,
More informationBusiness Associates and Breach Reporting Under HITECH and the Omnibus Final HIPAA Rule
Business Associates and Breach Reporting Under HITECH and the Omnibus Final HIPAA Rule Patricia D. King, Esq. Associate General Counsel Swedish Covenant Hospital Chicago, IL I. Business Associates under
More informationHIPAA Cyber Security: Your Vendor is a Back Door to Your Server
HIPAA Cyber Security: Your Vendor is a Back Door to Your Server Prepared for the American Health Lawyers Association s Fraud and Compliance Forum held October 6, 2014 John E. Kelly, Esq. Member Bass, Berry
More informationThis presentation focuses on the Healthcare Breach Notification Rule. First published in 2009, the final breach notification rule was finalized in
This presentation focuses on the Healthcare Breach Notification Rule. First published in 2009, the final breach notification rule was finalized in the HIPAA Omnibus Rule of 2013. As part of the American
More information3/13/2015 HIPAA/HITECH WHAT S YOUR COMPLIANCE STATUS? Daniel B. Mills Pretzel & Stouffer, Chartered WHAT IS HIPAA?
HIPAA/HITECH WHAT S YOUR COMPLIANCE STATUS? Daniel B. Mills Pretzel & Stouffer, Chartered WHAT IS HIPAA? 1 DEFINITIONS HIPAA Health Insurance Portability and Accountability Act of 1996 Primarily designed
More informationHow To Notify Of A Security Breach In Health Care Records
CHART YOUR HIPAA COURSE... HHS ISSUES SECURITY BREACH NOTIFICATION RULES PUBLISHED IN FEDERAL REGISTER 8/24/09 EFFECTIVE 9/23/09 The Department of Health and Human Services ( HHS ) has issued interim final
More informationPOLICY AND PROCEDURE MANUAL
Pennington Biomedical POLICY NO. 412.22 POLICY AND PROCEDURE MANUAL Origin Date: 02/04/2013 Impacts: ALL PERSONNEL Effective Date: 03/17/2014 Subject: HIPAA BREACH NOTIFICATION Last Revised: Source: LEGAL
More informationManaging Cyber & Privacy Risks
Managing Cyber & Privacy Risks NAATP Conference 2013 NSM Insurance Group Sean Conaboy Rich Willetts SEAN CONABOY INSURANCE BROKER NSM INSURANCE GROUP o Sean has been with NSM Insurance Group for the past
More informationFEDERAL AND STATE BREACH NOTIFICATION LAWS FOR CALIFORNIA
APPENDIX PR 12-A FEDERAL AND STATE BREACH NOTIFICATION LAWS FOR CALIFORNIA LEGAL CITATION California Civil Code Section 1798.82 California Health and Safety (H&S) Code Section 1280.15 42 U.S.C. Section
More informationThe ReHabilitation Center. 1439 Buffalo Street. Olean. NY. 14760
Procedure Name: HITECH Breach Notification The ReHabilitation Center 1439 Buffalo Street. Olean. NY. 14760 Purpose To amend The ReHabilitation Center s HIPAA Policy and Procedure to include mandatory breach
More informationHIPAA Breach Notification Policy
HIPAA Breach Notification Policy Purpose: To ensure compliance with applicable laws and regulations governing the privacy and security of protected health information, and to ensure that appropriate notice
More informationHackers, Slackers & Packers: Preventing Data Loss & Dealing with the Inevitable. Data Breaches Are All Too Common
Hackers, Slackers & Packers: Preventing Data Loss & Dealing with the Inevitable Steven J. Fox (sjfox@postschell.com) Peter D. Hardy (phardy@postschell.com) Robert Brandfass (BrandfassR@wvuh.com) (Mr. Brandfass
More informationReporting of HIPAA Privacy/Security Breaches. The Breach Notification Rule
Reporting of HIPAA Privacy/Security Breaches The Breach Notification Rule Objectives What is the HITECH Act? An overview-what is Protected Health Information (PHI) and can I protect patient s PHI? What
More informationThe HITECH Act: Implications to HIPAA Covered Entities and Business Associates. Linn F. Freedman, Esq.
The HITECH Act: Implications to HIPAA Covered Entities and Business Associates Linn F. Freedman, Esq. Introduction and Overview On February 17, 2009, President Obama signed P.L. 111-05, the American Recovery
More informationHIPPA and HITECH NOTIFICATION Effective Date: September 23, 2013
HIPPA and HITECH NOTIFICATION Effective Date: September 23, 2013 Orchard Creek Health Care is required by law to maintain the privacy of protected health information (PHI) of our residents. If you feel
More informationBrief. The BakerHostetler Data Security Incident Response Report 2015
Brief The BakerHostetler Data Security Incident Response Report 2015 The rate of disclosures of security incidents in 2015 continues at a pace that caused many to call 2013 and then 2014 the year of the
More informationMaxMD 2200 Fletcher Ave. 5 th Floor Fort Lee, NJ (201) 963 0005 www.max.md www.mdemail.md support@max.md Page 1of 10
Business Associate Agreement This Business Associate Agreement (the Agreement ) shall apply to the extent that the MaxMD Customer signee is a Covered Entity or "HIPAA Business Associate," as defined below.
More informationData Privacy: What your nonprofit needs to know. Donna Balaguer and Ed Lavergne Washington, D.C. February 5, 2015
Data Privacy: What your nonprofit needs to know Donna Balaguer and Ed Lavergne Washington, D.C. February 5, 2015 Overview 2 Data privacy versus data security Privacy polices and best practices Data security
More informationPanel Title: Data Breaches: Industry and Law Enforcement Perspectives on Best Practices
Panel Title: Data Breaches: Industry and Law Enforcement Perspectives on Best Practices Over the course of this one hour presentation, panelists will cover the following subject areas, providing answers
More informationBUSINESS ASSOCIATE AGREEMENT
BUSINESS ASSOCIATE AGREEMENT The parties to this ( Agreement ) are, a _New York_ corporation ( Business Associate ) and ( Client ) you, as a user of our on-line health record system (the "System"). BY
More informationBUSINESS ASSOCIATE AGREEMENT. Recitals
BUSINESS ASSOCIATE AGREEMENT This Agreement is executed this 8 th day of February, 2013, by BETA Healthcare Group. Recitals BETA Healthcare Group consists of BETA Risk Management Authority (BETARMA) and
More informationOutline. Outline. What is HIPAA? I. HIPAA Compliance II. Why Should You Care? III. What Should You Do Now?
Outline MOR-OF Education and Medical Expo August 23, 2014 Tatiana Melnik Melnik Legal PLLC tatiana@melniklegal.com 734-358-4201 Tampa, FL I. HIPAA Compliance II. Why Should You Care? A. Market Pressure
More informationData Breach Response Planning: Laying the Right Foundation
Data Breach Response Planning: Laying the Right Foundation September 16, 2015 Presented by Paige M. Boshell and Amy S. Leopard babc.com ALABAMA I DISTRICT OF COLUMBIA I FLORIDA I MISSISSIPPI I NORTH CAROLINA
More informationCloudy With a Chance Of Risk Management
Proudly presents Cloudy With a Chance Of Risk Management Toby Merrill, ACE USA John Mullen, Nelson Levine de Luca & Hamilton Shawn Melito, Immersion Ltd. Michael Trendler, ACE INA Canada What is Cloud
More informationSpecial Report The HITECH Act
Special Report The HITECH Act Privacy and Data Breach Notification Provision An Overview of the HITECH Act On February 17, 2009, President Obama signed into law the $787 billion stimulus package known
More informationHealthcare Practice. Breach Notification Requirements Under HIPAA/HITECH Act and Oregon Consumer Identity Theft Protection Act. Oregon.
Healthcare Practice Breach Notification Requirements Under HIPAA/HITECH Act and Consumer Identity Theft Protection Act August 2013 Anchorage Beijing New York Portland Seattle Washington, D.C. www.gsblaw.com
More informationCYBER & PRIVACY LIABILITY INSURANCE GUIDE
CYBER & PRIVACY LIABILITY INSURANCE GUIDE 01110000 01110010 011010010111011001100001 01100 01110000 01110010 011010010111011001100001 0110 Author Gamelah Palagonia, Founder CIPM, CIPT, CIPP/US, CIPP/G,
More informationHIPAA and HITECH Compliance for Cloud Applications
What Is HIPAA? The healthcare industry is rapidly moving towards increasing use of electronic information systems - including public and private cloud services - to provide electronic protected health
More informationAnatomy of a Privacy and Data Breach
Anatomy of a Privacy and Data Breach Understanding the Risk and Managing a Crisis Adam Kardash: Partner, Heenan Blaikie LLP Robert Parisi: Senior Vice President, Marsh Leadership, Knowledge, Solutions
More informationHIPAA Privacy and Security
HIPAA Privacy and Security Cindy Cummings, RHIT February, 2015 1 HIPAA Privacy and Security The regulation is designed to safeguard Protected Health Information referred to PHI AND electronic Protected
More informationPlease Read. Apgar & Associates, LLC apgarandassoc.com P. O. Box 80278 Portland, OR 97280 503-384-2538 877-376-1981 503-384-2539 Fax
Please Read This business associate audit questionnaire is part of Apgar & Associates, LLC s healthcare compliance resources, Copyright 2014. This questionnaire should be viewed as a tool to aid in evaluating
More informationMIT s Information Security Program for Protecting Personal Information Requiring Notification. (Revision date: 2/26/10)
MIT s Information Security Program for Protecting Personal Information Requiring Notification (Revision date: 2/26/10) Table of Contents 1. Program Summary... 3 2. Definitions... 4 2.1 Identity Theft...
More informationCovered Entities and Business Associates: An Evolving Relationship
Covered Entities and Business Associates: An Evolving Relationship Rebecca L. Williams, RN, JD Partner, Chair of HEALTH/HIPAA Practice Davis Wright Tremaine LLP beckywilliams@dwt.com 1 No health care provider
More informationHIPAA Security Rule Compliance
HIPAA Security Rule Compliance Caryn Reiker MAXIS360 HIPAA Security Rule Compliance what is it and why you should be concerned about it Table of Contents About HIPAA... 2 Who Must Comply... 2 The HIPAA
More informationData Privacy & Security: Essential Questions Every Business Must Ask
Data Privacy & Security: Essential Questions Every Business Must Ask Presented by: Riddell Williams P.S. Riddell Williams P.S. May 6, 2015 #4841-4703-9779 Innocent? 2 Overview 3 basic questions every business
More informationUsing Data Loss Prevention for Financial Institutions Banks, Credit Unions, Payments
Using Data Loss Prevention for Financial Institutions Banks, Credit Unions, Payments How Data Loss Prevention (DLP) Technology can Protect Sensitive Company & Customer Information and Meet Compliance Requirements,
More informationBUSINESS ASSOCIATE AGREEMENT
BUSINESS ASSOCIATE AGREEMENT 1. DEFINITIONS: 1.1 Undefined Terms: Terms used, but not otherwise defined, in this Agreement shall have the same meaning as those terms defined by the Health Insurance Portability
More informationBusiness Associate Management Methodology
Methodology auxilioinc.com 844.874.0684 Table of Contents Methodology Overview 3 Use Case 1: Upstream of s I manage business associates 4 System 5 Use Case 2: Eco System of s I manage business associates
More informationNetwork Security & Privacy Landscape
Network Security & Privacy Landscape Presented By: Greg Garijanian Senior Underwriter Professional Liability 1 Agenda Network Security Overview -Latest Threats - Exposure Trends - Regulations Case Studies
More informationLessons Learned from HIPAA Audits
Lessons Learned from HIPAA Audits October 29, 2012 Tony Brooks, CISA, CRISC Partner - IT Assurance and Risk Services HORNE LLP AGENDA HIPAA/HITECH Regulations Breaches and Fines OCR HIPAA/HITECH Compliance
More informationCyber Insurance: How to Investigate the Right Coverage for Your Company
6-11-2015 Cyber Insurance: How to Investigate the Right Coverage for Your Company Presented by: Faith M. Heikkila, Ph.D., CISM, CIPM, CIPP-US, ABCP Greenleaf Trust Chief Information Security Officer (CISO)
More information2009 HIMSS Analytics Report: Evaluating HITECH s Impact on Healthcare Privacy and Security
2009 HIMSS Analytics Report: Evaluating HITECH s Impact on Healthcare Privacy and Security Commissioned by ID Experts November 2009 INTRODUCTION Healthcare breaches are on the rise; according to the 2009
More informationWritten Information Security Programs: Compliance with the Massachusetts Data Security Regulation
Written Information Security Programs: Compliance with the Massachusetts Data Security Regulation Melissa J. Krasnow, Dorsey & Whitney LLP A Note discussing written information security programs (WISPs)
More informationPristine Technology Solutions, Inc.
Pristine Technology Solutions, Inc. 25 Measures 1. CPOE for Medication Orders 2. Drug Interaction Checks Drug-Drug/Allergy 3. Maintain Problem List 4. Permissible Prescriptions - eprescribing 5. Active
More informationARRA HITECH Stimulus HIPAA Security Compliance Reporter. White Paper
ARRA HITECH Stimulus HIPAA Security Compliance Reporter White Paper ARRA HITECH AND ACR2 HIPAA SECURITY The healthcare industry is in a time of great transition, with a government mandate for EHR/EMR systems,
More informationCREATIVE SOLUTIONS IN HEALTHCARE, INC. Privacy Policy
CREATIVE SOLUTIONS IN HEALTHCARE, INC. Privacy Policy Amended as of February 12, 2010 on the authority of the HIPAA Privacy Officer for Creative Solutions in Healthcare, Inc. TABLE OF CONTENTS ARTICLE
More informationFive Rivers Medical Center, Inc. 2801 Medical Center Drive Pocahontas, AR 72455. Notification of Security Breach Policy
Five Rivers Medical Center, Inc. 2801 Medical Center Drive Pocahontas, AR 72455 Notification of Security Breach Policy Purpose: This policy has been adopted for the purpose of complying with the Health
More informationData Loss Prevention and HIPAA. Kit Robinson Director kit.robinson@vontu.com
Data Loss Prevention and HIPAA Kit Robinson Director kit.robinson@vontu.com ID Theft Tops FTC's List of Complaints For the 5 th straight year, identity theft ranked 1 st of all fraud complaints. 10 million
More informationBUSINESS ASSOCIATE AGREEMENT
BUSINESS ASSOCIATE AGREEMENT THIS BUSINESS ASSOCIATE AGREEMENT is made and entered into as of the day of, 2013 ( Effective Date ), by and between [Physician Practice] on behalf of itself and each of its
More informationLaw Firm Cyber Security & Compliance Risks
ALA WEBINAR Law Firm Cyber Security & Compliance Risks James Harrison CEO, INVISUS Breach Risks & Trends 27.5% increase in breaches in 2014 (ITRC) Over 500 million personal records lost or stolen in 2014
More informationBUSINESS ASSOCIATE AGREEMENT
BUSINESS ASSOCIATE AGREEMENT 1. The terms and conditions of this document entitled Business Associate Agreement ( Business Associate Agreement ), shall be attached to and incorporated by reference in the
More informationBUSINESS ASSOCIATE AGREEMENT
BUSINESS ASSOCIATE AGREEMENT This Business Associate Agreement ( Agreement ) between Inphonite, LLC ( Business Associate and you, as our Customer ( Covered Entity ) (each individually, a Party, and collectively,
More information