SHUT THE DOOR AFTER THE HORSE HAS BOLTED. High Point Regional Health System, USA, September 2011
This excuse allows the breached organization to sound authoritative by providing an answer to how the breach could have been prevented to the media and public, even if it is a solution they haven’t put into practice yet. Unfortunately, the damage is already done and the misuse of privilege has caused significant enough damage to warrant the excuse being used in the first place.
High Point Regional Health System officials said they uncovered a breach involving the improper use of protected patient information by a former employee, in Fall of 2011. The former employee, who was fired after the breach came to light, had access to patients' names, addresses, dates of birth, Social Security numbers, driver's license numbers and insurance information.
After reassuring patients that they had apprehended the 'bad guy' - "We discovered it on our own and immediately took action on this employee," said Tracie Blackmon, director of Public Relations & Marketing for the health system. "We feel confident we took the correct action once we found out about this, and that's what's most important -- that our patients are taken care of and protected." - High Point went on to relate the steps they had taken to close the door after the horse had bolted.
'The health system has taken steps to prevent another breach, including a full review of the process of obtaining patient information at Premier Imaging. "Premier Imaging has stringent policies, procedures and systems in place to protect patient information and takes very seriously our obligation to safeguard the personal and health information of our patients," said Greg Taylor, chief operating officer. "We regret this incident has occurred and are committed to preventing future occurrences.
BeyondTrust says: Sounding authoritative about the steps you are going to take, doesn't mitigate for the fact it happened in the first place.
HiPAA regulations make quite clear the need for health organizations to:
i.) Manage network access based on the role based elevation of privilege - i.e access is granted based on what someone's job requires them to do, rather than their position and authority within the company.
ii.) Provide audit trails of who accessed what, when, and for what purpose.
