— Erin Head (@ErinHead_HIM) July 27, 2015
This was a great tweet coming out of the HIM Summit that’s run by HealthPort. I agree with the comment 100%. Sure, we see lots of large HIPAA breaches that make all the news. However, I bet if we looked at the total number of breaches (as opposed to patient records breached), the top problem would likely be due to the people in an organization. Plus, they’re the breaches that are often hardest to track.
What’s the key to solving the people risk when it comes to privacy and security in your organization? I’d start with making security a priority in your organization. Many healthcare organizations I’ve seen only pay lip service to privacy and security. I call it the “just enough” approach to HIPAA compliance. The antithesis of that is a healthcare organization that’s create a culture of compliance and security.
Once you have this desire for security and privacy in your organization, you then need to promote that culture across every member of your organization. It’s not enough to put that on your chief security officer, chief privacy officer, or HIPAA compliance officer. Certainly those people should be advocating for strong security and privacy policies and procedures, but one voice can’t be a culture of compliance and security. Everyone needs to participate in making sure that healthcare data is protected. You’re only as strong as your weakest link.
One of the attendees at the session commented that she’d emailed her chief security officer about some possible security and compliance issues and the chief security officer replied with a polite request about why this HIM manager cared and that the HIM manager should just let her do her job. Obviously I’m summarizing, but this response is not a surprise. People are often protective of their job and afraid of comments that might be considered as a black mark on the work they’re doing. While understandable, this illustrates an organization that hasn’t created a culture of security and compliance across their organization.
The better response to these questions would be for the chief security officer to reply with what they’ve done and to outline ways that they could do better or the reasons that their organization doesn’t have the ability to do more. The HIM manager should be thanked for taking an interest in security and compliance as opposed to being shot down when the questions are raised. It takes everyone on board to ensure compliance and security in a healthcare organization. Burning bridges with people who take an interest in the topic is a great way to poison the culture.
Those are a few suggestions about where to start. It’s not easy work. Changing a culture never is, but it’s a worthwhile endeavor. Plus, this work is a lot better than dealing with the damaged reputation after a security breach.