I like to watch industries evolve in how they deal with information security. It was interesting to watch retail evolve as PCI got more organized. The PCI Council put together the DSS with dates and penalties for breaches and non-compliance, and that drove significant change. It appears that a similar major change within healthcare is starting to take place. We have begun to see a proactive shift that incorporates compliance with HIPAA, an understanding of risk, and the development of security programs. As I’ve discussed in the past, the healthcare industry is significantly behind in dealing with IT-related risk. For an industry to change its approach to information security / risk, its culture needs to evolve. In my opinion, risk is the most effective driver of this change. If the risk is great enough, industries develop a mature understanding of risk management (of which security is a subset). The military and banking have tangible risks tied directly to their IT assets; therefore, they understand risk. The problem is that this mature understanding of risk doesn’t exist in most other industries. Without risk driving a security program, industries must rely on other drivers – usually compliance (also a subset of risk). What we’re seeing within healthcare is that PCI is driving the maturation of risk. For example, one key issue that keeps coming up, especially in hospitals, is the belief that PHI is more important than PCI / credit card information. Yet it is PCI compliance that has forced organizations to think systematically about risk. How do you reconcile the budget for PCI compliance with the lack of budget for PHI-related security? In addition, PCI has forced multiple groups (including IT, security, audit, and finance) to work together to deal with compliance and, ultimately, information security issues. Many of these same groups are now being asked to deal with HITECH / ARRA / updated HIPAA. With the new interpretations of HIPAA, the new regulations, and with these new sets of eyes, these groups are beginning to understand that they are not compliant with HIPAA, that they have significant risk exposure, and that they need to develop programs to deal with this exposure. From what we are seeing with many of our healthcare clients, the combination of a more pervasive awareness of PCI and new healthcare-specific regulations are creating a more mature understanding of risk and driving a new focus on developing successful information security programs. Let’s hope this trend continues.
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