Consumer exercise monitoring: Actual-time visibility throughout the EHR to remain forward of insider threats

Consumer exercise monitoring: Actual-time visibility throughout the EHR to remain forward of insider threats

In mild of the {industry}'s growing incidents and knowledge breaches, healthcare organizations are responding by strengthening their proactive cyber defenses to deal with the privateness and safety controls already required by HIPAA.

However whereas it has develop into customary follow for healthcare organizations to deal with figuring out and stopping exterior threats to knowledge privateness and safety, an typically missed danger could also be inside your workplace: worker snooping and malicious threats from inside.

Even with routine, efficient worker coaching that covers frequent assault strategies comparable to social engineering and phishing, healthcare knowledge stays weak. Almost 70% of knowledge breaches contain a human ingredient. This danger, along with regulatory danger, is why it’s so essential to intently monitor person exercise throughout your group (and the place attainable, your provide chain) for anybody who has entry to affected person knowledge and different protected knowledge.

What’s person exercise monitoring (UAM)?

The Nationwide Institute of Requirements and Know-how (NIST) defines person exercise monitoring (UAM) as the power to “observe and report a person's actions and actions, at any time, on any machine.” It goes on to say that UAM can “detect insider threats and help approved investigations.”

Sorts of UAM

Monitoring person exercise might help healthcare organizations detect and protectively determine suspicious or unauthorized entry to protected knowledge comparable to ePHI inside digital well being report (EHR) methods.

Trade-recognized UAM controls additionally assist guarantee compliance with HIPAA requirements to guard the confidentiality, integrity and availability of healthcare knowledge.

There are lots of sorts of person exercise monitoring, for instance:

  • Entry to logs and monitoring
  • Knowledge and file transfers, downloads or exports
  • Consumer authentication (multi-factor authentication and different controls to guard credentials)
  • Position-based entry
  • Actual-time alerts
  • Least entry (person can solely entry what is required based mostly on position)
  • Keystroke logging
  • Web monitoring
  • Endpoint safety and knowledge export monitoring
  • Routine entry management
  • Behavioral evaluation

Why healthcare organizations want UAM

Healthcare organizations can use UAM to proactively detect insider threats and malicious person exercise and information not solely incident response planning and actions, but in addition the enterprise danger evaluation course of. That is particularly essential because the healthcare {industry} faces relentless and more and more subtle cyber assaults, which can embrace social engineering to acquire credentials from staff with legitimate entry to knowledge, in addition to actual insider threats.

Menace actors are focusing on the healthcare {industry} as a result of the entities concerned and their enterprise companions course of huge quantities of delicate and identifiable knowledge. And these actors aren't simply after healthcare info. One profitable breach can lead to the exfiltration of different invaluable personally identifiable info (PII) present in medical data, comparable to Social Safety numbers, bank card numbers, financial institution accounts, dates of start, addresses and extra.

So it's not stunning that healthcare has the very best common price of knowledge breaches at practically $10 million by 2023, which has topped IBM's Value of a Knowledge Breach Report for greater than a decade.

Dangerous actors work across the clock to take advantage of safety vulnerabilities and weaknesses, realizing they’ve the capabilities to steal or ransom knowledge, negatively impression affected person care and repair supply, and worse, even trigger direct hurt , together with the lack of life.

UAM controls, particularly when carried out to observe entry throughout the EHR, might help healthcare organizations mitigate a few of this danger (and related response and reputational prices) whereas sustaining compliance with HIPAA and different requirements, comparable to NIST Cybersecurity Framework, to make sure. Another advantages of implementing UAM embrace:

  • Proactive menace detection
  • Actual-time monitoring and alerts
  • Quicker, more practical incident response
  • Much less downtime and higher operational resilience
  • Decrease compliance prices
  • Improved affected person confidence in companies
  • Model and popularity enhancement (we take privateness and safety significantly)
  • Skill to beat rivals not utilizing UAM controls

Danger evaluation and UAM

HIPAA requires lined entities and enterprise associates to implement cheap and applicable controls to guard the confidentiality, integrity, and availability of affected person knowledge, together with conducting HIPAA-compliant danger assessments.

Danger evaluation can do extra than simply determine the place you could be vulnerable to insider and provide chain dangers. Your group can even use danger assessments to tell your UAM methods, together with the simplest and complete UAM controls on your distinctive surroundings.

When a danger evaluation is finished correctly, you possibly can determine your essential property, perceive your vulnerabilities, and set priorities to proactively deal with weaknesses.

After you have recognized your safety and privateness dangers and used your danger evaluation to align these dangers with your online business targets and aims, you possibly can apply this info to information decision-making across the collection of cheap and applicable UAM controls, and as steerage for the training and coaching of staff. .

In return, you may as well use UAM knowledge, for instance person exercise logs, to drive ongoing danger administration, incident response, and worker engagement methods.

Going past danger evaluation

Whereas every lined entity and enterprise affiliate has a singular assault floor and enterprise aims, there are industry-recognized greatest practices for monitoring person exercise that any group can comply with to make sure compliance with HIPAA safety and privateness rules. Listed below are 4 suggestions to get you began:

  1. Use role-based entry controls (RBAC). Position-based entry controls be certain that customers have entry to solely the smallest quantity of knowledge essential to carry out particular duties. These controls may be position or duty particular. Utilizing RBAC is just not a matter of set it and neglect it. It ought to be an ongoing course of with routine critiques and changes, particularly as staff change roles or depart your group.
  1. Conduct routine employees coaching. Your UAM controls are solely as efficient as those that use them. Routine worker coaching and training is crucial, however this could transcend your workforce members and prolong wherever attainable to your C-suite, the board, different key stakeholders and even your provide chain. This consists of consciousness of cyber and knowledge privateness greatest practices, comparable to sturdy passwords, procedures to determine suspicious exercise, and the way and the place to report suspicious person exercise. By tailoring this coaching to every person's particular position or operate, you possibly can improve person engagement and assist them higher perceive their position in your group's total safety and resiliency wants.
  1. Use behavioral analyses. Use person exercise monitoring and related knowledge logs to raised perceive person patterns. This lets you shortly determine anomalies and reply shortly to potential incidents in actual time. Proactive menace identification can preserve you many steps forward of attackers so you possibly can successfully mitigate dangers earlier than they develop into real-world safety incidents.
  1. Conduct routine audits and set up audit trails. All healthcare organizations with ePHI require routine inner audits and third-party critiques and critiques to make sure HIPAA compliance, particularly to cut back the possibility of experiencing a breach and probably going through fines and penalties. Audits and compliance critiques that reveal that you’re successfully monitoring, monitoring, and documenting UAM controls can create a complete audit path to make sure you cross your subsequent audit or regulatory investigation and may reveal that you’re successfully defending the privateness and safety of affected person knowledge .

Monitoring person exercise is crucial to any healthcare group's cybersecurity and knowledge privateness technique. These controls can play an essential position in defending your online business from insider threats and potential knowledge breaches, whereas additionally guaranteeing ongoing HIPAA compliance.

Picture: traffic_analyzer, Getty Photos


Andrew Mahler, JD, CIPP/US, AI Governance Skilled (AIGP), CHC, CHPC, CHRC is the Vice President of Privateness and Compliance Companies at Clearwater, the place he leads knowledge privateness consulting and managed companies and healthcare compliance. Andrew has supported numerous shoppers with privateness and compliance critiques, advisory help and consultancy, and in roles as interim Chief Privateness Officer. Earlier than Clearwater, Andrew was Chief Privateness and Analysis Integrity Officer for the College of Arizona, the place he was chargeable for implementing privateness and analysis compliance applications for the universities, departments, clinics, hospitals and tutorial well being sciences all through Arizona.

Andrew is an lawyer and holds CIPP/US, CHC, CHRC, and CHPC certifications. He has developed programs in healthcare legislation and knowledge privateness and is a visitor lecturer for different authorized and enterprise programs in legislation, healthcare and compliance. As well as, he has printed and offered on matters together with well being legislation, knowledge privateness and HIPAA, analysis compliance and danger administration.

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