(ISC)²’s Common Body of Knowledge and the HIPAA Security and Privacy Rules

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It is no surprise that the security rules of the U.S. 1996 Health Portability and Accountability Act (HIPAA) appear closely modeled after existing generally accepted information security best practices.

The federal government lawmakers and subject matter experts knew better than to reinvent the wheel.

It should also be no surprise that the requirements of the HIPAA security rules are very much aligned with the security fundamentals found in the Common Body of Knowledge (CBK), a compendium of the security industry's best practices developed and maintained by the International Information Systems Security Certification Consortium (ISC)². After all, the (ISC)² CBK is considered by many in the industry as the premier compilation of all security information of international relevance to information security professionals.

Moreover, the CBK serves as the foundation for testing and certifying information security professionals who are tasked with carrying out their organizations' security programs. Attaining professional certification via the Certified Information Systems Security Professional (CISSP) not only confirms that the security professional has passed a rigorous examination, it also confirms that he or she possesses a working knowledge of the major disciplines of the profession.

Clearly, the success of a security program rests greatly with the skills and knowledge that the information security professional possesses. That said, the healthcare chief security officer (CSO) must be grounded in the principles and concepts represented in the 10 domains of the (ISC)² CBK to promote and make security part of their organization's culture. Those domains are:

  • security management practices
  • security architecture and models
  • access control systems and methodology
  • application development security
  • operations security
  • physical security
  • cryptography
  • telecommunications, network and Internet security
  • business continuity planning
  • law, investigations and ethics

The HIPAA security rules exemplify the overarching requirements found in the CBK, which are classified in the following sections: administrative procedures, physical safeguards, technical security mechanisms, and services to guard data integrity, confidentiality and availability. The requirements for HIPAA compliance are far-reaching, proving that security is cross-organizational, affecting internal business units, external trading partners and business associates, information technology and individual users alike.

Compliance with regulatory and industry security standards can become a competitive advantage if it is achieved in ways that enhance operational efficiency and effectiveness. And although the intent of HIPAA is to provide a uniform level of protection for all health information that is housed or transmitted electronically and pertains to an individual, the requirements are relevant to any organization in any industry.

Additionally, the HIPAA security rules support the finalized HIPAA privacy rules, proposed by the U.S. Department of Health and Human Services in 1999. Applicable organizations are required to comply with this regulation by April 2003. The HIPAA privacy regulation mandates specific requirements to protect health information rights for individuals that include use, minimum necessary, disclosure, de-identification, reasonableness and individual rights.

CISSP certification supports HIPAA compliance by providing the following areas of expertise for the CSO: security architecture and models, security management practices, operations security, application and systems development, telecommunications security and physical security. The following information, provided by the (ISC)² Institute, the CBK training arm of the consortium, compares the HIPAA requirements to the CISSP capabilities:

Certification

  • HIPAA requirements: the need for procedural documentation.
  • CISSP capabilities: multiple methods of securing information.

Training

  • HIPAA requirements: providing proper training to create a safe and secure environment for the transmission of information.
  • CISSP capabilities: ability to develop guidelines, standards and procedures to support policies; identification of risks, threats and vulnerabilities; creating security awareness for employees; using risk management practices appropriate for specific resources.

Access Control

  • HIPAA requirements: the need for access authorization rules for transactions, terminal access, applications, data processes or other users; the need to establish access policies that determine the initial right of access; the need for access modification rules that determine the reasons for modification
  • CISSP capabilities: providing access control concepts and methodologies and their enterprise-wide implementation in both centralized and decentralized environments; access control detective and corrective technologies used to minimize or avoid risks, exposures and vulnerabilities; mechanisms for directing or restraining influence over the behavior, use and content of the system to ensure availability, confidentiality and integrity.

Security Occurrence Procedures and Management Process

  • HIPAA requirements: use of methods to identify security incidents and reporting.
  • CISSP capabilities: ability to apply laws to computer crimes; how to determine the occurrence of a computer crime; methods of gathering and preserving evidence and investigating crimes.

Media Controls and Physical Security

  • HIPAA requirements: procedures required to protect information being added to or removed from the system.
  • CISSP capabilities: providing awareness of threats, vulnerabilities and countermeasures related to physically protecting the enterprise's sensitive information assets.

Security Program Responsibility and Physical Security

  • HIPAA requirements: assigning an individual to be responsible for security and privacy.
  • CISSP capabilities: providing awareness of threats, vulnerabilities and countermeasures related to physically protecting the enterprise's sensitive information assets.

Secure Workstation and Physical Security

  • HIPAA requirements: physical security of workstations.
  • CISSP capabilities: providing awareness of threats, vulnerabilities and countermeasures related to physically protecting the enterprise's sensitive information assets.

Contingency Planning

  • HIPAA requirements: tested and accepted plans for disaster recovery and backup of information.
  • CISSP capabilities: business continuity planning (business impact analysis, resumption strategies) and disaster recovery planning (information systems plan development, implementation and system restoration).

Security Configuration Management Security

  • HIPAA requirements: a full understanding of hardware and software installations and their implications for security measures.
  • CISSP capabilities: complete understanding of security models in terms of confidentiality, information flow and commercial vs. government requirements; Internet security services in terms of IETF IPsec; technical platforms in terms of hardware, firmware and software; system security techniques in terms of preventive, detective and corrective controls.

Digital Signatures

  • HIPAA requirements: need to include message integrity, user authentication and non-repudiation.
  • CISSP capabilities: full knowledge of basic concepts of cryptography; public and private key algorithms in terms of their applications and uses; algorithm types, key distribution and management and attack methods; the application, construction and use of digital signatures to provide authenticity of electronic transactions and non-repudiation of messages.

Communication and Network Controls

  • HIPAA requirements: organizations that use the network for communication of data should be aware of security issues surrounding transmission of information; ensuring that information is not accessible by others outside the organization (e.g., use of encryption).
  • CISSP capabilities: knowledge of communications and network security as it relates to voice, data, multimedia and facsimile transmissions; Internet/intranet/extranet networks in terms of firewalls, routers, gateways and various protocols; communication security management and techniques which prevent, detect and correct errors so that integrity, availability, and confidentiality of transactions over networks may be maintained.

Security Relationship Management Safeguards for Data Authentication

  • HIPAA requirements: data integrity and authentication guidelines and security concepts for software, hardware and network.
  • CISSP capabilities: security concepts used to ensure data and software integrity, confidentiality and availability; the security and controls that should be included within systems and application software; the steps and security controls in the software life cycle and change control process.

Audit Controls, Personnel Security and Authorized Use

  • HIPAA requirements: ability to track access, changes in information and security issues; proper authorization is necessary to access information.
  • CISSP capabilities: the resources must be protected; the privileges must be restricted; the control mechanisms available; knowledge of the potential for abuse of access; the appropriate controls; the principles of good practices.

It is evident by these comparisons that the certified security practitioner can be extremely beneficial in ensuring HIPAA compliance in a healthcare organization, as well as provide HIPAA-level processes to any organization. In these times of heightened security awareness, that can be a significant factor in protecting an organization's critical information infrastructure.

Micki Krause, CISSP, is director of information security for PacifiCare Health Systems and a founding board member of (ISC)². She is the co-author of the Information Security Management Handbook.

 

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