Local Encryption ... Why Not?
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@coliver said:
@BRRABill said:
@scottalanmiller said:
It's important to remember that while HIPAA states "reasonable security" they mean nothing of the sort. They expect extreme security is some regards and less than zero in others. It's all random and logic doesn't play in too much.
For example, does data need to be encrypted at rest? Does this include on paper? Does it include in the mail?
Can you encrypt paper?
Yes, they have been doing it since the time of the Romans if not earlier.
Maybe they did is long before but were so good at it that we don't know
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Really, disks are just like paper. Everything is written down in plain sight. If you can do it on disk, you can do it on paper.
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A SED is like a decoder ring!
The thing is that the paper shouldn't just be left out in the open.
Now if you are saying they put it in a folder, and then the folder gets stolen, well then yes, that is an issue. An issue I have no way of knowing how to work around. (I didn't deal with any walking paper in our HIPAA stuff.)
But it is not reasonable to think you'd "encrypt" paper. You would do whatever reasonable things you could do to protect it. Lock it up a rest, and keep it from being stolen if it is out on the town.
It is certainly reasonable to think you'd encrypt a laptop. Which is why OCR doesn't consider it a violation, and why places like the hospital in that article have 1000s of machines using SEDs.
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@BRRABill said:
But it is not reasonable to think you'd "encrypt" paper. You would do whatever reasonable things you could do to protect it. Lock it up a rest, and keep it from being stolen if it is out on the town.
What would make paper and disk different? Given that they are effectively identical, why is one reasonable and the other not? If you think disks should be encrypted, wouldn't that imply that all paper should just be encrypted? It's local so... why not?
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@BRRABill said:
It is certainly reasonable to think you'd encrypt a laptop.
Why, you just said that paper was not reasonable to encrypt. The logic that makes paper need to be insecure would extend to the laptop, right?
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@scottalanmiller said:
What would make paper and disk different? Given that they are effectively identical, why is one reasonable and the other not? If you think disks should be encrypted, wouldn't that imply that all paper should just be encrypted? It's local so... why not?
Because there is no reasonable way to encrypt paper.
There is a very reasonable, easy-to-use, and inexpensive way to encrypt disks that I have demonstrated healthcare organizations use.
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@scottalanmiller said:
@BRRABill said:
It is certainly reasonable to think you'd encrypt a laptop.
Why, you just said that paper was not reasonable to encrypt. The logic that makes paper need to be insecure would extend to the laptop, right?
Sure, it would be reasonable if it was possible.
If you are implying you cipher the text on the page, well, again that's not reasonable because how could anymore read it?
WIth a SED, the user has to do nothing more than they are used to doing, which is log in to their machine.
One is impossible, and silly.
The other is widely used, and acceptable to the only organization that matters in the HIPAA fine discussing, the OCR.
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You can see, there are many safeguards with paper as well.
But since there is no way to encrypt paper, it doesn't apply.
http://privacyoffice.med.miami.edu/awareness/tips/protect-paper-records-with-sensitive-information
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@BRRABill said:
@scottalanmiller said:
What would make paper and disk different? Given that they are effectively identical, why is one reasonable and the other not? If you think disks should be encrypted, wouldn't that imply that all paper should just be encrypted? It's local so... why not?
Because there is no reasonable way to encrypt paper.
There is a very reasonable, easy-to-use, and inexpensive way to encrypt disks that I have demonstrated healthcare organizations use.
That's debatable. Encrypting data is only easy as long as you decrypt it and leave it unprotected when going to the end user. Encrypt that data end to end and it gets very hard.
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@BRRABill said:
@scottalanmiller said:
@BRRABill said:
It is certainly reasonable to think you'd encrypt a laptop.
Why, you just said that paper was not reasonable to encrypt. The logic that makes paper need to be insecure would extend to the laptop, right?
Sure, it would be reasonable if it was possible.
If you are implying you cipher the text on the page, well, again that's not reasonable because how could anymore read it?
WIth a SED, the user has to do nothing more than they are used to doing, which is log in to their machine.
One is impossible, and silly.
The other is widely used, and acceptable to the only organization that matters in the HIPAA fine discussing, the OCR.
Impossible? It's literally identical to the digital way. It's VERY possible. if it was not, computers could not do it either.
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@BRRABill said:
You can see, there are many safeguards with paper as well.
But since there is no way to encrypt paper, it doesn't apply.
http://privacyoffice.med.miami.edu/awareness/tips/protect-paper-records-with-sensitive-information
There is EVERY way to encrypt paper. We can all do it. Kids do it every day. Saying that this is all not true doesn't make it untrue.
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I totally understand that one system is more automated than the other and it is easier to use computers than not to use computers, but we are already going to the high effort paper world here. ALL security that applies to a drive applies to paper, all, no exceptions. They are the same type of thing (bits on physical media.) You can, at any point, print disk data to paper and vice versa. They are interchangeable.
But it would be trivially easy to put in a little encryption on paper end to end. Super easy. But we don't bother, we just ignore security there.
Although it needs to be pointed out, we don't encrypt anything digitally end to end, but we take it much farther.
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I understand in the HIPAA world because security is not a related topic and laws are, it's probably worth encrypting local drives, even if we lose data, because we don't care about losing data, we care about getting sued. But it is really important to understand that the reasons we do it for HIPAA are not security related and that HIPAA discussions don't apply to non-HIPAA discussions.
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@scottalanmiller said:
I understand in the HIPAA world because security is not a related topic and laws are, it's probably worth encrypting local drives, even if we lose data, because we don't care about losing data, we care about getting sued. But it is really important to understand that the reasons we do it for HIPAA are not security related and that HIPAA discussions don't apply to non-HIPAA discussions.
Agreed.
Though I also use SED personally. Just in case.
I'm a "WHAT IF"-er.
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You know, whilst at lunch today, this paper thing (and encryption in general) kind of clicked for me.
(This story might seem long winded, but it has a point)
I had my trusty little Moleskin mini notebook with me, with notes I had jotted down on Christmas gifts. I usually put this thing in my shirt pocket, but I have no shirt pocket today, so I put it in my back pants pocket. Then I thought ... what if this thing fell out of my pocket? So what? I said to myself. Ah. There it is. There is nothing of value in there. I don't write anything personal or sensitive in there. If I ever did need to, I would encode it, as we have been talking about. Like add 5 to all the PIN numbers or something. But generally I would know better than to store anything important in a notebook I carry around in my pocket and could lose.
Now, being the paranoid type, I would still worry that I had something in there. Because sometimes I admit I am a little careless about things. But for the most part I wouldn't worry about it.
Same things holds for other notebooks I have. I write some more sensitive stuff in them, but they are more for my inside the office use. Very slim chance of them getting lost. Though I always write code in those too, just to protect from prying eyes.
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Here is someone fearful of encryption ending up, by accident, acting like a threat: http://community.spiceworks.com/topic/1357724-de-encrypting-network-shares-server-question
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@scottalanmiller said:
Here is someone fearful of encryption ending up, by accident, acting like a threat: http://community.spiceworks.com/topic/1357724-de-encrypting-network-shares-server-question
I'm not sure how he would prevent someone from putting encrypted files onto the network?
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Yeah, he can prevent one system from doing it, but not someone encrypting files and dropping them.
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@scottalanmiller said:
Here is someone fearful of encryption ending up, by accident, acting like a threat: http://community.spiceworks.com/topic/1357724-de-encrypting-network-shares-server-question
I never said there weren't risks.
You always have to have systems to get around the encryption for your own uses, and also good backups.
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@BRRABill said:
@scottalanmiller said:
Here is someone fearful of encryption ending up, by accident, acting like a threat: http://community.spiceworks.com/topic/1357724-de-encrypting-network-shares-server-question
I never said there weren't risks.
You always have to have systems to get around the encryption for your own uses, and also good backups.
But if there are risks, that answers the "why not" question. It's only in cases where there is no or effectively no downsides (good examples are virtualize every server and open sources is always better than closed source for end users) where you don't have to weigh the options. But with encryption, it's not a clear win. The weighting leans heavily towards encryption, I grant you, but there are downsides strong enough to warrant needing to consider if it is truly adding enough to make up for what it takes away. It remains situational.
