I have an encryption talk that I give and usually find a few people in the audience that have implemented encryption. In almost every case this has been because of PCI or HIPAA regulations that dramatically reduce penalties if data is encrypted. Whether you agree with the regulations or not isn’t important. There are rules that some of us have to follow because of our data and my guess is that the number and scope of those rules will increase in the future, not just in these industries, but others as well.
If you are covered by HIPAA law, you may have gotten some increased scrutiny this year. There are audits underway from the Office of Civil Rights (OCR) for 115 organizations that will help them to ensure they comply with regulations. Penalties aren’t supposed to be assessed unless there are serious violations, but starting in 2013, the Health Information Technology for Economic and Clinical Health (HITECH) Act requires that the auditing program will be enforced with surprise audits.
For those managing health care data, you should be sure that you are complying with HIPAA regulations. If you’re not, you ought to make sure your boss is aware that next year you could have a surprise audit and should be ensuring that you meet the laws regulations. The OCR has released their audit protocol, and you should be sure that you understand what is being evaluated.
If you aren’t regulated by PCI or HIPAA, you might still check over the protocol as much of it is good practice for securing any data. It can be general, but if you abide by the spirit of the criteria, I’d bet that will pass an audit by your security group.
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