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.

Friday May 01, 2009

Kuppinger Cole on IAM/GRC Trends

I enjoyed reading Martin Kuppinger's post addressing the Kuppinger Cole list of 10 Top Trends for IAM and GRC in 2009:
"As in the past years, Kuppinger Cole has worked out 10 top trends in IAM (Identity and Access Management) and GRC (Governance, Risk Management, Compliance). Things are going forward in 2009, despite the economic crisis – even more, especially GRC vendors are benefiting from the crisis and the increasing investments in GRC. The need for Risk Management is well understood now.

"But our analysis shows that there are advancements in many other areas of IAM and GRC as well. The impact of Cloud Computing, new electronic passports as a means for authentication, and more discussions about privacy are just some few of them."

Here is the K-C list of trends.  The major themes are maturity, expansion/extension, clouds and services.
  1. GRC as the Business Control Layer for IAM
  2. Growing Maturity of Identity 2.0 Approaches
  3. Multi-purpose Cards gain Momentum
  4. Context and Versatility become Reality
  5. More IAM and GRC for the Cloud
  6. Portable Identity Information for Social Networks
  7. GRC going beyond IAM
  8. First Impacts of new Electronic Passports
  9. Increasing Service Orientation in IAM and GRC
  10. Privacy is back – and there are more Solutions
Thanks, Martin, for your insight into the expanding, maturing world of IAM and GRC.

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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.

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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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