In the seminar, "Manage Data Breach Incidents and Improve Patient Privacy in Major Care Systems," experts discussed how to achieve organizational alignment around patient privacy across large organizations, how to mitigate the financial and reputational risks of a data breach, and specific ways to gain support from both the board and executives to create and maintain a culture of privacy. Experts included Kimberly Holmes, deputy product manager of healthcare at Chubb Group of Insurance Companies; Cheryl A. Parham, associate general counsel at New York-Presbyterian Hospital; Meredith Phillips, chief privacy officer at Henry Ford Health Systems; Marcy Wilder, co-chair of the Global Privacy and Information Group at Hogan Lovells; and Doug Pollack, chief strategy officer at ID Experts.
InformationWeek Healthcare spoke with Pollack, who recapped the four tips experts shared to make patient privacy and security part of an organization's culture.
1. Encrypt, Encrypt, Encrypt.
During the panel, Holmes outlined a core message, said Pollack, which was "simple and easy" but could substantially improve an organization's ability to maintain patient privacy. "That's encryption," said Pollack. "It’s particularly important and necessary to emphasize now because of the new device world we're moving into." Healthcare, he continued, is a "very aggressive" adopter of mobile technology, particularly tablets, and although encryption technology is often available, people might not focus on it as much as they should.
"A lot of times, when they're dealing with BYOD, they may not understand the need to maintain privacy and the importance of using encryption," said Pollack. "[We need to] get people focused on the one simple thing they can do in the security space and move the needle in terms of protecting patient privacy. Encryption is one of those rare focus areas that can make a huge difference."
2. Prepare For A Breach.
New York-Presbyterian's Parham said during the panel that when dealing with a large hospital system, the question isn't if, but when an organization will encounter a data breach. "It's a fact of life within the healthcare world that data is liquid; it needs to move around so much that it's impossible to completely eliminate breaches," said Pollack. "Her point was…it's important to have a plan in place that will dictate how you operate in the context of a breach."
Pollack added it’s important to understand who your first responders are, and, more importantly, how they will react in the situation. A common issue, though, is how often organizations will develop a response plan, "and then stick it in a file and that's it," he said. "We’re increasingly finding … hospitals are interested in testing their response plan. They'll assemble folks and do a table-top walk through of a sample data breach." By doing so, an organization can operationalize their response. "It can make a big difference as to whether you successfully or unsuccessfully deal with an incident," Pollack said.
3. Assess Privacy And Security Compliance Annually.
Even though it's required under HIPAA, said Pollack, many organizations still fail to perform a compliance assessment every year. "[Make] it part of your organizational DNA," he said. "Organizations need to get in the rhythm of doing it." Just as an organization develops its operating plan every year, it also needs to schedule and carry out a privacy and security assessment, "so they're budgeted and expected," he said. "The good news is by doing them, it'll help keep you out of trouble when you inevitably face an investigation by Office for Civil Rights (OCR), where they decide whether you've been acting poorly or not."
4. Find Gaps And Close Them.
Phillips spoke on how to find the security gaps within an organization and close them, and described what she and her team have done at Henry Ford Health System. "She talked about a natural follow-up to the assessment process, which is helpful to identify issues and do something about them," said Pollack. Phillips also said that she and her organization keep the OCR updated on the issues they have identified and are working to fix. "That’s to preempt any concerns or issues by illustrating your proactive efforts to address patient privacy," said Pollack.
Global Privacy's Wilder "wrapped a bow" around all the points executives made when it came to how to prepare for and combat against data breaches, said Pollack. To summarize, "encryption and culture come in, and organizations need to be prepared when breaches occur," he said. "[They] need to be transparent and especially transparent not only to those affected, but also to the regulatory systems, specifically OCR."
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