Monday Nov 23, 2009

IAM is a Journey, not a Project

In our recent CIO Roundtable tour, a question about Identity and Access Management that emerged in every session was, “where do I go from here?”  It is one thing to talk about the theory of IAM; it is quite another thing to actually implement it in your enterprise.

My advice to the Roundtable participants and to you is this, “IAM is a journey, not a short-term event. Enterprises must begin to approach compliance as a long-term program, not a single project.  Take stock of where you are now, set objectives for where you want to be in the future, and execute your strategy in stages.”

To illustrate this process, the white paper I recently wrote, Identity and Access Management: Enabling HIPAA/HITECH Compliance, proposes thirteen best practices for approaching the application of IAM to HIPAA/HITEC compliance efforts.  Recognizing that IAM is a journey, not a project, is one of the best practices.

Think program, not project. HIPAA/HITECH compliance is a journey, not a short-term event. Enterprises must begin to approach compliance as a long-term program, not a single project. An effective and holistic compliance program should also incorporate governance and risk management. Boards of directors and executives are frequently being held to higher standards than ever before as they are expected to be knowledgeable about, and held liable for, everything going on within the enterprise.

roadmap

The step-by-step process depicted above doesn’t fit everyone.  It only serves to illustrate the need to for defining your IAM journey as a series of phases subdivided into measureable steps.  Our experience has shown that those enterprises who follow this basic process usually succeed, while those who attempt to do much all at once, or focus on one small tactical project, often fail to realize the benefits of a well-executed IAM strategy.

Happy trails!  (I couldn’t resist that last comment, even though the “happy trails” comment in my previous post dealt with airline travel, not IAM journeys.)

Tuesday Nov 17, 2009

Identity and Access Management - Enabling HIPAA/HITECH Compliance

hipaa The white paper I mentioned several days ago, Identity and Access Management – Enabling HIPAA/HITECH Compliance, is now hot off the press and ready for download.  Thanks to all the great people at Sun Microsystems that contributed to this project and made it a reality.  Hopefully, the paper will be beneficial to those who are facing the challenges of how to comply with the increasing regulations surrounding management of healthcare data and information systems.

The paper’s abstract reads:

As healthcare organizations and vendors become more reliant on digital information technology, complying with increasing regulatory requirements presents a range of challenges. This paper explores the requirements that these organizations face, best practices for implementing identity management systems that help ensure compliance, and how Sun’s pragmatic approach to identity management simplifies the technology environment.

The table of contents:

  1. Executive Summary
  2. Healthcare Information Technology Challenges
  3. Health Insurance Portability and Accountability Act (HIPAA)
  4. Health Information Technology for Economic and Clinical Health Act (HITECH)
  5. Impact of HIPAA, HITECH and Related Regulations
  6. The Role of IAM in HIPAA/HITECH Compliance
  7. Sun IAM Product Introduction
  8. Best Practices for the IAM/Compliance Journey
  9. How to Get Started with HIPAA/HITECH and IAM
  10. The Sun IAM Workshop
  11. References

Please let me know if you have any questions or would like to discuss the content in more detail.

Monday Nov 09, 2009

Best Practices for the IAM/Compliance Journey

As explained in my recent post, I am awaiting final publication of a white paper I recently authored, entitled, “Identity and Access Management – Enabling HIPAA/HITECH Compliance.”  This post is a excerpt from that paper.

In the thirteen years since the initial passage of the HIPAA act, practical experience in the field has yielded several recommended best practices for implementing IAM systems to enable HIPAA/HITECH compliance. We recommend the following:

  1. Understand requirements. By developing a better understanding of compliance requirements, how compliance affects information technology (IT), and how IT in general and IAM specifically can help support the privacy, security and notification requirements of HIPAA/HITECH, companies can establish efficient, cost-effective, and sustainable programs that address all of these complex requirements within a holistic compliance framework.

  2. Recognize IT's critical role. In many companies, IT has evolved to become the critical backbone behind almost every operation, but many people still view technology as a cost rather than an investment or asset. By understanding the key roles that IT plays in support of HIPAA/HITECH compliance, enterprises can maximize the value of their technology investment.

  3. Understand the role of IAM. IAM plays a critical role in compliance with HIPAA/HITECH privacy, security and notification requirements.. However it does not automatically satisfy all HIPAA/HITECH requirements. Recognizing the value and the limitations of IAM in the entire spectrum of HIPAA/HITECH compliance is essential.

  4. Think program, not project. HIPAA/HITECH compliance is a journey, not a short term event. Enterprises must begin to approach compliance as a long-term program, not a single project. An effective and holistic compliance program should also incorporate governance and risk management. Boards of directors and executives are frequently being held to higher standards than ever before as they are expected to be knowledgeable about, and held liable for, everything going on within the enterprise.

  5. Establish privacy and security policy. A success privacy and security program requires a documented set of principles, policies, and practices. Using the Nationwide Privacy and Security Framework for Electronic Exchange of Individually Identifiable Health Information as a guide, the enterprise's privacy and security principles should be documented as a foundation upon which to build policies, practices and strategies.

  6. Develop a strategy. The only way to effectively address the wide spectrum of compliance requirements is to integrate them into a common compliance strategy that is intertwined with the business itself. A business-driven, risk-based, and technology-enabled compliance strategy can help create enterprise value by rationalizing unnecessary complexities, driving consistency and accountability across the enterprise, and identifying opportunities for a possible enhancement of operational performance and information quality.

  7. Collaborate. HITECH extends compliance responsibility and penalties to all business associates. Work closely with your vendors and business partners to form an overall security and privacy framework, including updating legal relationship documents as ncessary.

  8. Establish a governance process. Compliance efforts affect a broad spectrum of an enterprise. Stakeholders from many organizations, often with conflicting priorities, have vested interests in the outcomes of a compliance strategy. The governance process must provide representation from the impacted functional areas of the organization. A governance board should have appropriate representation from IT, security, audit, application owners, human resources, business process owners and applicable business associates. The board should be accountable for the project objectives and be vested with authority to make program decisions. The board should be empowered to 1) establish a statement of purpose for the program, 2) promote and give visibility to the program throughout the larger organization, 3) act as a mechanism for quickly making decisions regarding program scope, issues, and risks, and 4) monitor the program health on an ongoing basis.

  9. Implement your strategy in phases. By segmenting the overall solution into manageable parts, an organization can realize quick, visible business benefits and progressively realize overall program objectives in an orderly, measurable way. Implementing in manageable phases also makes it easier to battle issues such as scope creep or requirements drift.

  10. Standards. Follow the NIST and other applicable standards for electronic healthcare records. Adjust to form a compliance model with this emerging standard. Focus on open standards and vendors that are open standards compliant to insure long-term flexibility of computing platforms and security frameworks.

  11. Give real-time visibility. Real-time views into the functioning of controls across these systems and across the enterprise, through job-specific dashboards or portal views, can provide insight into compliance status, progress, and risks. Effective communications with all stakeholders is essential.

  12. Unify disparate compliance efforts. Many companies are beginning to realize the potential of technology to support sustained compliance and are actively looking to combine existing fragmented, reactive, and inefficient governance and compliance efforts into a single sustainable compliance program. Bringing together compliance, governance, and risk management under a holistic framework, can result in a centralized compliance organization with the understanding, structure, and ability to help optimize the company’s compliance efforts in a sustainable, strategic, and cost effective manner.

  13. Assess progress and adjust as necessary. Each phase of the progressive implementation of the compliance strategy will yield more in-depth understanding about the compliance process as it pertains to the specific enterprise. Implementing methods of continual process improvement will yield progressively refined results.

Please let me know what you think.  What have you found that really works in this IAM/Compliance Journey?

The Role of IAM in HIPAA/HITECH Compliance

I recently authored a white paper entitled, “Identity and Access Management – Enabling HIPAA/HITECH Compliance.”  The paper is now in the final editing and formatting process.  As we awaiting the final publishing date, let me share an excerpt from the paper, focused on the key ways IAM enables HIPAA/HITECH compliance.

HIPAA/HITECH requirements for privacy, security, auditing and notification are supported directly by IAM. By streamlining the management of user identities and access rights and automating time-consuming audits and reports, IAM solutions can help support strong privacy and security policies across the enterprise and throughout Health Information Networks while reducing the overall cost of compliance.

IAM provides the following key enablers for HIPAA/HITECH compliance:

  1. Assign and control user access rights. Securely managing the assignment of user access rights is critical to HIPAA/HITECH compliance, particularly in distributed and networked environments typical of modern healthcare business. Decentralized provisioning is not only inefficient and costly, it also increases the risk of security and privacy violations. Automated provisioning allows centralized control of resources and applications that have historically existed in silos. This provides a much greater level of control over access to those resources. Checking audit policy at the time or provisioning ensures regulatory compliance, thus preventing audit policy violations.

  2. Adjust user access rights when responsibilities change. Business risk is introduced when employees change jobs and access isn’t appropriately adjusted or removed. Failing to appropriately adjust or remove users’ access when job changes occur can result in superuser-access and SOD violations. Automated provisioning effectively eliminates many of these risks, especially when combined with auditing and role management capabilities.

  3. Revoke user access upon termination. IAM systems can automate the process of immediately revoking user access rights upon termination or suspension. This eliminates a commonly-exploited security gap and opportunity for policy violation that may occur after an employee or contractor has been dismissed.

  4. Manage allocation of user credentials. Managing user names, passwords and other user access credentials is essential to assuring that only authorized users are granted access to information systems. IAM technology can provide enterprise-wide control of user credentials, including the enforcement of uniform password policies (e.g. password strength, periodic change).

  5. Enforce segregation of duties (SOD) policies. Segregation of duties (also known as separation of duties), has as its primary objective the prevention of fraud and errors. This objective is achieved by disseminating the tasks and associated privileges for a specific business process among multiple users. IAM methods can prevent, detect, and resolve access rights conflicts to reduce the likelihood that individuals can act in a fraudulent or negligent manner. Once violations are identified, notification and remediation steps are automatically initiated based on corporate policies.

  6. Provide uniform access policy. IAM can provide administration and enforcement of common user access policies across a wide span of diverse systems, improving executive confidence in how the enterprise complies with HIPAA/HITECH requirements.

  7. Manage access based on business roles. Provisioning and auditing at the business role level, rather than just at the IT access control level, ties user access rights more closely to business processes. With a role management solution, managers can approve access rights that have a meaningful business context, thus reducing the risk of managers inadvertently creating SOD violations by granting carte blanche access to their direct reports.

  8. Enforce secure access policies. While automated identity administration, provisioning and auditing are essential to HIPAA/HITECH compliance, these methods don't actually enforce the use of security policies when a user accesses the controlled systems. IAM Access Management technology can enforce user access policy at the point of entry to an application or other system, in harmony with established policy. Examples of such enforcement include Web access management (including single sign-on or SSO), enterprise single sign-on (ESSO), and Web service security.

  9. Enforce informed consent principles. Informed consent principles (e.g. opt-in, opt-out, notice) can be enforced, based on identities of individual patients and potential users of personal information associated with such data.

  10. Extend access control to business associates. Identity Federation can extend access control beyond enterprise boundaries to enable secure access to electronic records while safeguarding the privacy of sensitive information. This is essential to complied with extended requirements of HITECH.

  11. Verify access rights. While automated user access provisioning is designed to accurately assign access rights, such access rights should be confirmed by audit. IAM can provide the ability to both assign access rights according to established polices and then periodically verify that access rights are still compliant with those same policies.

  12. Conduct periodic compliance assessments. Periodic audits of access rights and privileges can assure that security and privacy policies are consistently enforced. Re-certification is a process where managers approve direct reports’ access to enterprise resources and applications. IAM can provide the ability to automatically present managers with the correct information to attest to each employee's access rights needs. By applying role management principles, this re-certification process can enable the approving manager to work at the business-role level, attesting to those entitlements quickly and accurately because they are given in a meaningful business context.

  13. Provide automated reports. The delivery of accurate, timely and complete reports can assess compliance with established requirements. IAM can provide scheduled and ad-hoc compliance reports, including automated violation notifications, comprehensive work flow processes, and audit assessment reports. Such reports can generated across multiple systems and enterprise applications and be submitted to appropriate people within the enterprise, to business associates and to appropriate regulatory agencies.

I’ll share more excerpts soon and let you know when the full paper is ready for download.  Please stay tuned.

Tuesday Oct 27, 2009

Identity Trend 7: Regulation and Compliance

This post is the seventh in a series of eleven posts I am writing about key trends in the Identity Management industry.

imageGovernment regulations have been enacted to address problems problems with fraud, governance, security and privacy arising in various industries.  For example, the Sarbanes-Oxley Act of 2002 (Sarbox) was intended to make corporate governance practices more transparent and to improve investor confidence. It addressed financial control and financial reporting issues raised by the corporate financial scandals, focusing primarily on two major areas: corporate governance and financial disclosure.

Government regulations tend to become more complex and far-reaching over time.  For example, to address the challenges of security and privacy, the Health Insurance Portability and Accountability Act (HIPAA) was enacted by Congress in 1996 to establish national standards for use of health care records. HIPAA provided a foundation upon which multiple regulations have been based to address issues with the administration and protection of sensitive medical records information.

Title XIII of the American Recovery and Reinvestment Act of 2009 (ARRA), also known as the Health Information Technology for Economic and Clinical Health Act (HITECH) includes a section that expands the reach of HIPAA by introducing the first federally mandated data breach notification requirement and extending HIPAA privacy and security liability to business associates of "covered entities" (generally, health care clearinghouses, employer sponsored health plans, health insurers, and medical service providers that engage in certain transactions on behalf of individuals).

The current trend to more extensive government regulation of industry will likely continue or escalate, placing additional burden on enterprises to comply with increasingly complex compliance mandates.

imageA second source for industry regulations comes from industry itself.  For example, the Payment Card Industry (PCI) Data Security Standard (DSS) is a global security standard for safeguarding sensitive credit card data.  This standard was established by PCI Security Standards Council, an organization founded by industry leading enterprises: American Express, Discover Financial Services, JCB International, MasterCard Worldwide, and Visa, Inc. The standard was created to help organizations that process card payments prevent credit card fraud through increased controls around data and its exposure to compromise.

Identity and Access Management (IAM) is a critical enabler for compliance with government and industry regulations.  For example, Sarbox requirements for fraud reduction, policy enforcement, risk assessment and compliance auditing are supported directly by IAM technology and methods. By streamlining the management of user identities and access rights, automating enforcement of segregation of duties policies, and automating time-consuming audits and reports, IAM solutions can help support strong security policies across the enterprise while reducing the overall cost of compliance.

Similarly, IAM technology and processes, which control user access to data, applications, networks and other resources, can directly support HIPAA/HITECH requirements for privacy, security, auditing and notification.

Recommendations:

Practical experience in the field gained as many enterprises have implemented IAM systems to support compliance efforts has yielded several recommended best practices for implementing IAM systems to enable HIPAA/HITECH compliance.  The following list of best practices will be explored in more detail in a subsequent blog post:

  1. Understand regulatory requirements that apply to your enterprise.
  2. Recognize IT's critical role in the compliance process.

  3. Understand the role of IAM in supporting compliance.

  4. Think of compliance as a long-term program, not a single project.

  5. Establish compliance policies. principles should be documented as a foundation upon which to build policies, practices and strategies.

  6. Develop a business-driven, risk-based, and technology-enabled compliance strategy.

  7. Collaborate with your business partners and associates.

  8. Establish a governance process.

  9. Implement your strategy in phases.

  10. Follow established standards.

  11. Give real-time visibility into compliance status, progress and risks.

  12. Unify disparate compliance efforts.

  13. Assess progress and adjust as necessary.

About

Discovering Identity was founded on blogs.sun.com in May 2005 as a means of documenting my exploration of the field of Identity and Access Management. In February, 2010, I switched to hosting the blog at DiscoveringIdentity.com. In March 2012, I began posting Oracle-related information in both places.

Thanks for stopping by.

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The views expressed on this blog are my own and do not necessarily reflect the views of my employer, Oracle Corporation, or any other person or organization.

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