You Need Help, Not An Accomplice
Compliance is about being better and not just proving you are right
I met recently with a potential client to discuss a proposed HIPAA and HITECH compliance assessment. Doing a quick run-through of their current status, I quickly realized there were some problems, the biggest one being the client's perspective on the current situation.
The first problem I uncovered is very common in every line of consulting work: this potential client was not really looking for better answers; they were looking for an accomplice. They wanted their solution to be validated and endorsed instead of evaluated and improved.
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The second problem was the staff's compliance work, which was woefully incomplete and which they had no interest in acknowledging. They repeatedly cited the things they had done correctly, but had total disregard for the missing elements of the work. Sure they had an encrypted database, ran updates and patches regularly, and had strong password policies. It was not the completed tasks that were my concern -- it was that these alone did not bring them anywhere close to reasonable compliance.
The staff was quite insistent that their plan made them completely secure and that no extra work or cost would be necessary. I was asked only to approve their work so they could pass along our third-party review to their own clients as proof they were indeed compliant.
If only that were the situation. The staff asserted that because they used a software firewall, a hardware firewall was not necessary. They had never tested a full restore of their backup, had no documentation for configuring a secure server from scratch, and offsite backup was only once a month.
I pointed out that the issues that concerned me went far beyond compliance issues, they were business risk issues. The poor CEO didn't know who to believe. She clearly trusted her IT staff and had distanced herself so much from oversight of this department, she had left herself at their mercy. She had neither the expertise to overrule them nor the understanding to reach her own independent conclusions.
I got the impression she perceived the entire exercise as a discussion of expensive, never-ending technology magic, when she really wanted simply the quickest, cheapest conclusion so she could go back to pretending all was well.
The risks we uncovered were dismissed by her IT staff as either irrelative or not applicable to their company. "We know how to set up a server, and technology changes so often, we shouldn’t waste our time with a document no one will read anyway," sums up their attitude.
I could tell this IT staff also suffered the common unspoken fear, "If we document everything, we can more easily be replaced."
In the end, staff dysfunction won out, which is just as well, as my employees are not corporate social counselors, and I doubt our recommendations would have been followed anyway. It would have wasted the client's money and risked my company’s reputation. And realistically, they may be in great shape, at least as long as nothing ever goes wrong.
Glenn S. Phillips, the president of Forte' Incorporated, works with business leaders who want to leverage technology and understand risks within. He is the author of the book Nerd-to-English and you can find him on twitter at @NerdToEnglish.