o365 and HIPAA information between two different agencies
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@Dashrender You just used the same logic for why we say that fax isn't okay... it's so easy to do something better that there's really no excuse for using something without in transit security
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@scottalanmiller said in o365 and HIPAA information between two different agencies:
@Dashrender You just used the same logic for why we say that fax isn't okay... it's so easy to do something better that there's really no excuse for using something without in transit security
except I disagree with you that it's easier - and so do millions of others. That said, I agree that we SHOULDN'T be faxing, but it's not easier.
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turning on TLS on email is completely transparent to the end user, moving from faxing to emailing is hugely impactful to the end user.
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Even though @scottalanmiller and I disagreed on this (I think, I forget at this point) FDE locally is also very easy. And it basically absolves you of a breach. Which is why it's implemented in a lot of healthcare systems.
But as you know, that's 2 pieces of hundreds if not thousands. Nuts.
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@scottalanmiller said in o365 and HIPAA information between two different agencies:
@Dashrender said in o365 and HIPAA information between two different agencies:
Incoming doesn't matter so it will remain opportunistic, as it's the senders responsibility to ensure encryption exists, not the receiver.
Does that wording exist somewhere? What makes one party more responsible than the other?
Not specifically that I am aware of, but how can you be responsible for how someone delivers something to you? I suppose given you fax thing, you could simply deny all access, but is that your job to ensure they are doing the right thing? You can't even tell if the message from them contains PHI until after they send it.
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@BRRABill said in o365 and HIPAA information between two different agencies:
Even though @scottalanmiller and I disagreed on this (I think, I forget at this point) FDE locally is also very easy. And it basically absolves you of a breach. Which is why it's implemented in a lot of healthcare systems.
But as you know, that's 2 pieces of hundreds if not thousands. Nuts.
FDE can be easy, but not cost effective. I have no idea how much FDE drives are these days, also what are the local system requirements to make them work? i.e. Does the BIOS have to support it?
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@Dashrender said in o365 and HIPAA information between two different agencies:
@scottalanmiller said in o365 and HIPAA information between two different agencies:
@Dashrender said in o365 and HIPAA information between two different agencies:
Incoming doesn't matter so it will remain opportunistic, as it's the senders responsibility to ensure encryption exists, not the receiver.
Does that wording exist somewhere? What makes one party more responsible than the other?
Not specifically that I am aware of, but how can you be responsible for how someone delivers something to you? I suppose given you fax thing, you could simply deny all access, but is that your job to ensure they are doing the right thing? You can't even tell if the message from them contains PHI until after they send it.
Because the communications is negotiated, you can be equally responsible in either direction. If it is "not your job to ensure that they do the right thing" then that suggests that as long as you offer TLS and they decline, you are covered even when you are the sender.
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@scottalanmiller said in o365 and HIPAA information between two different agencies:
@Dashrender said in o365 and HIPAA information between two different agencies:
@scottalanmiller said in o365 and HIPAA information between two different agencies:
@Dashrender said in o365 and HIPAA information between two different agencies:
Incoming doesn't matter so it will remain opportunistic, as it's the senders responsibility to ensure encryption exists, not the receiver.
Does that wording exist somewhere? What makes one party more responsible than the other?
Not specifically that I am aware of, but how can you be responsible for how someone delivers something to you? I suppose given you fax thing, you could simply deny all access, but is that your job to ensure they are doing the right thing? You can't even tell if the message from them contains PHI until after they send it.
Because the communications is negotiated, you can be equally responsible in either direction. If it is "not your job to ensure that they do the right thing" then that suggests that as long as you offer TLS and they decline, you are covered even when you are the sender.
Why do you think that? I would say, you offered, they declined, you know you can't because it's not secure - I suppose from an addressable standpoint, you did the best that YOU could do, so I see your point.
Damn there really needs to be some case law about this shit, because until there is, it's all just a guessing game waiting for someone to get sued over it. Or dealing with getting audited by the OCR and seeing what they have to say.
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@Dashrender said
FDE can be easy, but not cost effective. I have no idea how much FDE drives are these days, also what are the local system requirements to make them work? i.e. Does the BIOS have to support it?
The Samsung SSDs support FDE and they can be had for well under $100. The software to manage the FDE costs $39 if you want it for an individual use case, but in a healthcare type environment that would all be centrally managed. I'm not sure how much that is.
Though if you ever lose a laptop it's worth it!
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Actually, I guess what I am considering would be ... SED and not FDE? Or is that term interchangeable here?
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Can you manage drive based encryption from a network?
Something like Bitlocker you can manage from AD, but you're back to the management issue mentioned earlier.
But, like you said, a single lost machine could easily make it worth while.
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@Dashrender said
Can you manage drive based encryption from a network?
Something like Bitlocker you can manage from AD, but you're back to the management issue mentioned earlier.
What management issue?
I know some places around us use this:
http://wave.com/products/wave-self-encrypting-drive-managementThat's what I use for my users' SEDs, but I manage it all at the machine level. (I think you need 20 machines or something for it to start making sense financially.)
Though it looks like from the home page that company is in turmoil. Not sure if what is happening is good or bad.
