"It's bigger than privacy and security … it's about involving everyone in the organization at the highest level down to the help desk level [people] who are inputting calls into the system," he said. In a recent webinar hosted by ID Experts, Ewell said that in addition to accountability, there needs to be a shift in organizational culture to combat breaches.
Seattle Children's is a not-for-profit hospital and the academic research center for the University of Washington. It deals mainly with research, genetics and diseases, bioethics, and all avenues of pediatric care.
Ewell said the culture within his organization has changed since he implemented an incident response team. For instance, the employees at Seattle Children's have learned to expect breaches, no matter what they do to prevent them. "It's not a matter of if, but when," he said. The hospital operates under the assumption that "people will get in and there will be issues. You need to have that expectation that it's going to happen no matter what you do."
Ewell advises considering setting up outside help before an incident occurs. A small breach of 4,000 or 5,000 patients, he said, could be handled by the organization itself. But a larger breach might require additional help, such as call center professionals and interpreters. "You can do a lot in-house, but you have to have the ability to ad hoc within a short period of time for a large incident," he said.
Management should not be caught off guard by a breach, and should plan to be flexible enough to spend time rectifying problems, said Ewell. "Sometimes, we lack time and resources, and that's an element we see when you have a big or moderate incident," he said. "I've worked with small to large [breaches], and it's different depending on what resources you need, but you need to plan for that: incident response versus incident management. You want to get management pre-planning ahead of time and not just being active when you have an incident."
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Determining whether there is a breach in the first place can be one of the hardest tasks, said Ewell, followed by determining what the risk is to the institution and what patient data might have been compromised. "Part of our process is to determine that motive and intent," he said. Documentation of a breach is key. "With all breaches, tell the story: why did it happen and why did that person want that information."
"It helps me paint a picture and determine what the risks are," Ewell said. In order to meet the requirements of the Health Insurance Portability and Accountability Act, he said, an organization needs to determine if there was significant financial harm or harm of another kind done to the patient. It also needs to have documentation in place to show processes that were undertaken, and why it did or did not notify patients.
At Seattle Children's, Ewell and his team always circle back after an incident to see whether they can improve their processes, he said. "It's a continual loop of reviewing and assessing. That 60-day time limit: once you identify an incident, it gets spun up quickly and you have to make a determination of who to notify; that will keep going until the incident is done."
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