Every time we discuss server security issues it opens a debate about where is the best place to keep your servers. There are three options and we are going to discuss them today. Local hosting vs data center hosting vs cloud servers under HIPAA.
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The HIPAA legal reference and guidance mentions reasonable and appropriate all over the place. Many times that concept creates confusion. How do you determine what is reasonable or appropriate for any environment?
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Can a doctor have Alexa in OR to play music?
Is it a HIPAA violation for staff to look at their own records or is it an internal policy violation?
I am a small company BA do I really have to do all of HIPAA compliance requirements?
If I know my upstream BA or CE isn't following their HIPAA compliance obligations what am I legally obligated to do?
Why would you make daily copies of your visitor logs?
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Sometimes following the news lets you find things like security incident investigations with interesting details. But, these cases were different than most. Even better than that, we learned how can a fish tank help hackers! There were just too many parts of these stories that got my attention to pass them up. When something occurs and the investigation uncovers way more to the story than you normally see we should all learn from them.
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Incident response plans have been a topic of our show several times. But, these days we just can't get enough of a good thing!
Actually, there is a reason we are covering it in this episode. I was reviewing a Business Associate Due Diligence from a software provider. In the questionnaire, we always ask if you have a written incident response plan and trained incident response team. They responded Yes, with a comment of "we have an engineering department".
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There has always been a concern from many people we work with about compliance officer personal liability. Specifically, is a compliance officer personally liable for the compliance of the company?
The recent settlement agreement between the FTC and the Chief Compliance Officer of Moneygram has created interesting conversations for compliance circles. In this case, the Chief Compliance Officer of Moneygram was able to reach a settlement in the liability case against him but it included a $250,000 penalty payment and 3 years restriction on working in that industry. Yep, that is enough to make you sit up and take notice.
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The monthly OCR Cyber Newsletter for June had some interesting points. The fact that OCR mentions multiple times and in multiple ways that they do not endorse, certify, or recommend specific technology or products should serve as their "OCR mic drop moment" on this discussion. We can dream, can't we! Today we are going to review that newsletter and how they have pointed these things out once again.
Before we close out the episode we are also covering some questions and comments from listeners. Hang around for those just after the 30-minute mark.
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