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By Peter Morrison
The National Institutes of Health (NIH) recently found itself at the center of public and media scrutiny when an employee’s laptop was stolen, potentially compromising the personally identifiable information (PII) of NIH study participants. The data included the names, birth dates, hospital medical record numbers, and diagnosis-related information for 2,500 study participants. It was not encrypted – a violation of the U.S. Office of Management and Budget (OMB) June 23, 2006 mandate M-06-16, Protection of Sensitive Agency Information, requiring federal agencies to encrypt all sensitive data on mobile devices.
This same scenario, in which a mobile device containing sensitive data is lost or stolen, has played out in several government agencies in recent years and will inevitably recur as government employees increase their use of mobile devices (i.e., laptops, thumb drives, smartphones, etc.) to perform mission-critical activities.
Public health organizations are particularly at risk: the widespread use of mobile devices to manage patient information in the public health arena increases the likelihood that a patient’s private health data and other PII may be lost or stolen, leaving these organizations and their patients vulnerable to compromise.
The intense scrutiny surrounding the NIH incident and similar instances of sensitive data loss should motivate public health agencies to pursue mobile data protection. Federal, state, and local public health agencies and organizations can turn to a variety of sources, including the U.S. General Services Administration (GSA) SmartBUY program or the U.S. Department of Defense Enterprise Software Initiative (DoD-ESI) program, as appropriate, to find solutions to protect data on their vulnerable endpoints.
At the same time, federal agencies must guard against the instinct to make a knee-jerk decision to buy a solution simply to meet OMB M-06-16. The goal of the federal mandate is not compliance. Instead, it is to “compensate for the protections offered by the physical security controls when the information is removed from, or accessed from outside of the agency location.”
Compliance is intended to help an agency perform its mission-critical activities. Like any other information technology (IT) investment, identifying the appropriate mobile data security solution should be considered based on the needs of the public health agency’s enterprise and how that solution enables the enterprise to fulfill its mission.
To find the right solution to protect patient and related sensitive information in your public health organization, there are a number of key factors to consider:
-- Security, end-user transparency, and ease of operational management. Most vulnerable endpoint security solutions are based on older encryption technologies that were never designed to work in today’s sophisticated environments. Understanding how your agency needs to balance these three requirements to meet its mission is essential.
-- Data-centric vs. device-centric solutions. The GSA and DoD purchasing vehicles offer both solutions. Agencies need to ask themselves: what are we really trying to protect – the data on the device (e.g., medical records, patient diagnoses, phone numbers, etc.), or the device itself? That’s a business, policy, and management decision that only you can answer for your public health organization’s enterprise.
-- Centralized (integrated) vs. non-centralized encryption approaches. As you consider the solution that best meets your public health organization’s needs, you need to decide what role security policy plays in its implementation.
A centralized approach places a larger emphasis on security policy as the driving factor for decision-making. In contrast, a non-centralized approach offers the end-user greater flexibility in deciding what to encrypt and why. Do you really want the end-user deciding security policy?
Ultimately, the solution should be one that considers the roles that people, processes, operations, enforcement, and management play in ensuring vulnerable endpoint protection.
Whether or not to pursue mobile data security is no longer a question for public health agencies– it is a necessity. Agencies must now rise to the challenge and determine how to meet those needs throughout their organizations.
Pete Morrison is Vice President, North American sales for Credant Technologies, a provider of endpoint data protection solutions. He can be reached at pmorrison@credant.com.
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