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Objective Vulnerability Assessment

Objective Vulnerability Assessment. Risks for Unauthorized Disclosure of Patient Information Farrokh Alemi, PhD. Confusion on What Works. Vulnerability assessment is a large and growing industry Best practices are not clear Consensus models perpetuate claims of vulnerability

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Objective Vulnerability Assessment

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  1. Objective Vulnerability Assessment Risks for Unauthorized Disclosure of Patient Information Farrokh Alemi, PhD

  2. Confusion on What Works • Vulnerability assessment is a large and growing industry • Best practices are not clear • Consensus models perpetuate claims of vulnerability • Consensus models are static as opposed to dynamic and evolutionary Objective data is needed

  3. Misleading Assessments • Without objective data we do not know if risk priorities are accurate • Like children fighting imaginary foes, organizations are asked to protect against vulnerabilities that may not exist Objective data is needed

  4. Money Is Wasted • Can’t secure all operations, have to pick and choose • More security is not better • Security may reduce productivity • Business builds on trust not fear • No point to secure a process if the business fails Objective data is needed

  5. Why Not Base Vulnerability Assessment on Data? • It can’t be done • Rare events • Risk is not quantifiable • Data is not available • Historical precedents are not relevant as terrorists and criminals innovate

  6. Accurate Probabilities for Rare Events • Time to event • p(Vi) = 1 / (1+ ti) • Allows calculation very small probabilities

  7. It Can be done: Application to Unauthorized Disclosure • p(U) = ∑ i=1, .., n p(U | Vi) p(Vi) • p(U | Vi) = p(Vi | U) p(U) / p(Vi) • Where • p(Vi) is probability of the vulnerability • p(U) is probability of unauthorized disclosure • p(Vi | U) is prevalence of vulnerability among reported unauthorized disclosures

  8. Sources of Data Incidence database List of vulnerabilities Prevalence of violations Prevalence of vulnerabilities Among violations Assessment surveys Risk Score

  9. Construction of Incidence Database • Legal case reviews • Office of Civil Rights database • Published reports • Private surveys

  10. Probability of Unauthorized Disclosure

  11. Clinician using unsecured email environment Clinician gather information from patients’ family and friends after the visit Discussion of patient care with co-workers not engaged in care Medical reports or records with wrong recipient information Caring for employees’ friends and family members Benefit Organizations or employers request employee information Employees engaged in whistle blowing to uncover illegal or unacceptable business or clinical practices Patient records (paper documents) not kept in secure environment or sealed envelope; or documents displayed in plain view of others Clinician discusses patient care in a setting where others can easily hear Employee removes patient records from secure location or workplace without authorization Employee views paper documents or manipulates computer passwords to view medical records of patients not under his/her care External infection of computers / password / network Systems (e.g. computer hacker) Theft of computers or hard drives Sale of patient records Blackmail/Extortion of organization or an employee Patient using identity of another person to gain insurance benefits Changes in custody or family relationships not revealed by the patient Audit of business practices by outside firm without clinicians’ approval Business Associate violates Chain of Trust Agreement Legal System/Law Enforcement requests, subpoenas or seizes patient records Error in patient identity during data transfer to third party insurers Vulnerabilities Derived from the Database

  12. Prevalence of Vulnerabilities Among Unauthorized Disclosures

  13. Prevalence of Vulnerabilities Among Unauthorized Disclosures

  14. Prevalence of Vulnerabilities Among Unauthorized Disclosures

  15. Best Practice Vulnerability Assessment Tool • Derived from incidence database • Relying on time between events • Asking questions like: • When were the last two times that you emailed a patient in an unsecured environment?

  16. Unprecedented Vulnerabilities • Assessed based on similarity to actual events • Where

  17. Advantages • Applies to privacy as well as security violations • Produces a quantitative score for overall risk, useful for benchmarking • Based on objective data • Focuses attention on vulnerabilities that are real and likely to occur • Reduces unnecessary fear and security interference with business processes • Can be used to set fair insurance premiums

  18. Objective Vulnerability Assessment is Possible It is Faster & More Accurate than Consensus-based Vulnerability Assessments

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