On March 8, 2023, the U.S. Department of Health and Human Services (HHS) released its HPH Sector Cybersecurity Framework Implementation Guide (the Guide) to help healthcare organizations leverage the NIST Cybersecurity Framework. This Guide is not only a must-read for all healthcare “covered entities,” especially small and midsize organizations, but it is excellent advice for…
Category: Regulatory
The White House Cybersecurity Plan – the Devil is in the Details
“The devil is in the details” — that about sums up my take on the White House Cybersecurity Plan. Many thanks to Lily Newman for including this and some other points from our discussion in her Wired article The High-Stakes Blame Game in the White House Cybersecurity Plan. I appreciate that the Administration is talking…
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SEC Continues to Emphasize Importance of Cybersecurity and Cyber Risk Governance
“While this is an oversimplification of all of the requirements and nuances of the forthcoming SEC rules, the SEC’s objectives are to require companies to provide meaningful and actionable information to shareholders to better understand companies’ cyber risks and how companies are managing and responding to them. From a very high level, this can be…
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Dental Practice Responses to Online Reviews Cost $23,000 Settlement with OCR for Impermissible Disclosure of PHI
On December 14, 2022, the U.S. Department of Health and Human Services Office of Civil Rights published a notice of a settlement with a dental practice over disclosures of patients’ protected health information over social media. Here is the full version reproduced below: Date: Wed, 14 Dec 2022Subject: HHS Civil Rights Office Enters Settlement with…
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“Data is the hot potato!” — some data governance lessons from the Twitter Whistleblower Testimony
Hopefully you saw my recent post “Data is the hot potato!” and data minimization lessons from the FTC’s Drizly case and it reinforced in your mind just how important it is to focus on the data when we are talking about cyber and privacy risk management. If it didn’t, that’s ok, here’s another reminder. My…
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OCR Releases Video Guidance on Recognized Security Practices for National Cybersecurity Awareness Month
On October 31, 2022, the U.S. Department of Health and Human Services Office of Civil Rights provided guidance titled OCR Releases New Recognized Security Practices Video. This guidance is not only a must-read for all healthcare “covered entities,” especially small and midsize organizations, but it is excellent advice for all organizations — healthcare and non-healthcare…
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“Data is the hot potato!” and data minimization lessons from the FTC’s Drizly case
Thank you, Jamie Sorley! I have a few sayings about cybersecurity and data privacy but one of my favorites is “data is the hot potato!” When doing presentations, I love to have the attendees chant over and over in unison, “Data is the hot potato! Data is the hot potato! Data is the hot potato!”…
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OCR Guidance on HIPAA Security Rule Security Incident Procedures for National Cybersecurity Awareness Month
On October 25, 2022, the U.S. Department of Health and Human Services Office of Civil Rights in its October 2022 OCR Cybersecurity Newsletter provided guidance titled HIPAA Security Rule Security Incident Procedures. This guidance is not only a must-read for all healthcare “covered entities,” especially small and midsize organizations, but it is excellent advice for…
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Why did Lifespan Health face such a stiff HIPAA penalty for a stolen laptop? (publication)
Many thanks to HealthcareITNews for publishing my recent article Why did Lifespan Health face such a stiff HIPAA penalty for a stolen laptop? HHS is trying to get companies to comply with the law and, more broadly, their obligation to protect the sensitive information that people have entrusted to them. We have handled numerous cases…
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Helpful FTC Guidance on Cybersecurity for Small and Midsize Companies
It is important for all companies — especially small and midsize companies — to have a basic understanding of what the FTC considers to be reasonable cybersecurity. The FTC is known for being one of the more aggressive regulators that are investigating and enforcing (what it views as) inadequate cybersecurity by companies doing business in the United States….
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