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6 of 9 HIPAA Network Considerations

The HIPAA Omnibus Final Rule, released January 2013, goes into effect this month – Sept 23, 2013. Over the last several weeks, I’ve been posting a blog series around nine HIPAA network considerations.

  1. HIPAA Audits will continue
  2. The HIPAA Audit Protocol and NIST 800-66 are your best preparation
  3. Knowledge is a powerful weapon―know where your PHI is
  4. Ignorance is not bliss
  5. Risk Assessment drives your baseline
  6. Risk Management is continuous
  7. Security best practices are essential
  8. Breach discovery times: know your discovery tolerance
  9. Your business associate(s)must be tracked

This blog focuses on #6 – Risk Management is Continuous.

You can look at the Risk Management implementation specification as the actions taken in response to the Risk Assessment.  The HIPAA Security Rule defines Risk management (Required):  “Implement security measures sufficient to reduce risks and vulnerabilities to a reasonable and appropriate level to comply with [§ 164.306(a)]”

(1) Ensure the confidentiality, integrity, and availability of all electronic protected health information the covered entity creates, receives, maintains, or transmits.

(2) Protect against any reasonably anticipated threats or hazards to the security or integrity of such information.

(3) Protect against any reasonably anticipated uses or disclosures of such information

One common mistake companies make in compliance programs is taking the approach that once the work is done, the network doesn’t have to be looked at again for compliance.  If they put the security programs, processes, and technologies in place, they don’t have to spend time on compliance until next year (or the year after that, or even longer).

This makes compliance a onetime effort that is then ignored.  Worse, securing PHI often follows the same path, making it easy to hack and steal, causing a lot of problems for everyone involved.  Risk management―reducing risk―needs to be a continuous activity.   Through your risk assessment, you’ll know where your PHI is, what your highest risk factors are, and where to implement more continuous risk management tools in the network.

Continuous risk management does not mean tracking every single event on every single device throughout the network.  It may mean turning on automatic alerts on critical devices, setting traffic thresholds in network areas where PHI resides, logging anomalous events in those critical areas, and using network management tools to make sense of all this information the network devices are collecting.

Risk management is about a lot more than achieving HIPAA compliance, reducing risk to PHI and helping to prevent theft of PHI is of critical value.

Recommendation: Understand where you should implement continuous risk management, and what logging, alert, detection, and management tools you already have that can help with risk management.

To learn more about Cisco® compliance solutions and HIPAA services, please visit http://www.cisco.com/go/compliance

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More Effective Threat Visibility Using Identity and Device-Type Context

Following my previous blog post about identity and device aware IT platforms making IT operations easier and more effective, I wanted to delve a little deeper into a specific element of the IT infrastructure: Security Event & Information Management (SIEM) and Threat Defense (TD) systems.

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August 2013 #SecureDC Twitter Chat Recap: SDN Security

Our first SecureDC twitter chat created some great industry dialog around security for Software Defined Networks (SDN) as well as using SDN to improve security. SDN is going through a similar hype cycle as seen with cloud and we feel that it’s important to focus more on education now and broader collaboration, so that users can benefit from the tremendous potential SDN holds.

More Education, Less Buzz

We kicked off our conversation by asking what are the most pressing issues around SDN were. @Joltsik, Principal analyst at Enterprise Strategy Group, felt that users are confused with so much buzz, yet there’s little in the way of education.

@Raj_Samani, Chief Innovation Office at the Cloud Security Alliance and CTO at McAfee, went one step further indicating that greater transparency is also needed. However, @Jgreene3rd, Technical Lead for Data Center Security Technologies at Intel, noted that the upside of buzz is that it drives greater demand for availability, which in turn fuels education.

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SDN and Improving Security

@KenSBeck, Principal Engineer at the Cisco Security Technology Group Office of the CTO, led an interesting discussion on how APIs for programming the network at network speed will allow security intelligence to be much more dynamic and eventually part of the network itself. @shl_eax_1, Technical Lead Engineer at Cisco Security Technology Group Office of the CTO, further noted how global visibility of the network hastens the speed with which security issues get resolved.

@fsmontenegro elaborated on how SDN security can enable more intelligent, granular and efficient response, and that SDN improves security by adding policy exceptions at the network layer with redirect flow. @vernonxt, SVP for ICT Research at IDC, honed in on SDN enabling better policy management. @AndiMann, Vice President at CA Technologies, speculated with automation enabling embedded policy and preventing random changes, shouldn’t SDN be able to do the same.

SDN Impact on Regulatory Compliance

@alokmittal65, Chief of Staff for the Cisco Security Technology Group Office of the CTO, stressed the need for auditing, logging and monitoring of policy change events.

@Raj_Samani also noted that with greater proliferation of devices, the ability to achieve greater attestation on the endpoint becomes more challenging. @KenSBeck drew attention to leveraging network awareness of user, geo location, and device as contextual elements that can make attestations much more meaningful.

Wrapping Up

@KenSBeck, our host from the Office of the CTO at Cisco, closed with words of advice and a hint of what is in store.

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Keep the dialog going! Follow us on @Secdatacenter #SecureDC and join the conversation on LinkedIn Secure Datacenter Trends. For additional SDN resources, be sure to register today for our SDN Learning Seminars.

 

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MS Detours: Ongoing vigilance keeps customers on the right track.

Detours is a library offered by Microsoft Research for interception of functions on x86 and x64 platforms. It is sold for commercial use to various vendors that build products ranging from security to gaming applications.

Detours is often injected into most or all of the processes, either system-wide or in the context of the logged in user. The most common way this is done is through the AppInit_Dlls registry value. Because the injection is typically applied to a large number of processes running under various permissions, extra care must be taken to ensure the library and its usage are very carefully reviewed by engineers with a strong understanding of the implications of such wide hooking.

We have used this library in our own security products at Cisco (both CSA and AnyConnect) to provide certain security functions on the system. During one of our research projects earlier this year, we noticed a peculiar pattern on Windows systems where processes we were hooking had a change in the in-memory permissions, which marked the headers of the modules from the normal READ/EXECUTE to now include WRITE as well.

This was quite alarming to us, because a dll should not be writeable when loaded into memory. What was interesting, and led to clues of what might be the cause, was that it was only the dlls that had functions we were actively trying to hook. They were the common Win32 dlls that one would typically intercept methods for, such as Kernel32.dll.

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#ExecInsights: Defend, Discover and Remediate with Security Services

Like most industries, security has gone through many different evolutions. Over the past 20 years, the industry has been largely product focused, with customers deploying point products across the network in an effort to “cover” all security gaps. Over time and with the arrival of mobile, social and cloud, customers now recognize that having all the security products in the world is not going to close all the gaps. Today’s customers are looking for fully integrated solutions – a combination of services, products and people.

This is where Cisco delivers. We are elevating our security solutions efforts with the creation of a Services Security Practice, led by security industry veteran Bryan Palma, who comes to Cisco with an extensive background in both services and security. Reporting to Edzard Overbeek, Senior Vice President of Cisco Services, Bryan’s team will build three new service categories for our customers: Consultation; Product Implementation and Support; and Managed Services for enterprises and governments.

Cisco’s integrated security strategy is to defend, discover and remediate the most critical threats. With world-class products, research teams, global intelligence, advanced threat protection – and now services – our customers will benefit from continuous security in more places across the infrastructure.

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