Storing PHI on External Drives and Cloud Services
As technology advances, healthcare organizations are faced with new options for storing sensitive patient health information (PHI). While electronic medical records make accessing and sharing patient data more efficient, they also come with risks if not properly secured. Two common methods for storing PHI beyond the healthcare organization’s own servers are external hard drives and cloud-based storage services. However, both options require careful evaluation to ensure compliance with HIPAA regulations.
External Hard Drives
External hard drives can provide a simple and cost-effective way to back up large amounts of PHI. The data is stored on a physical device that can be kept secured, with only authorized users able to access the drive. However, there are several precautions healthcare organizations must take when using external hard drives for PHI storage:
– The external hard drive should be encrypted to prevent unauthorized access if lost or stolen. Full disk encryption is recommended.
– Strict physical security measures should be in place wherever the drive is stored and used. This includes locking the drive in a secure location when not in use.
– Access to the drive should only be granted to personnel who need it for their job functions. Authentication and access controls should be implemented.
– The external hard drive should not be the only place PHI is stored. Multiple redundant copies of data should exist to prevent loss.
– Any PHI should be completely wiped from the external drive before disposal or reuse to prevent data breaches.
Cloud-Based Storage Services
Major cloud storage providers like Google Drive, Dropbox, iCloud and OneDrive make backing up and accessing PHI convenient for authorized users. However, HIPAA compliance becomes more complex with a third-party hosting data on their servers. Companies that want to leverage the benefits of cloud storage must:
– Use cloud vendors that are HIPAA compliant, with a Business Associate Agreement in place.
– Encrypt PHI both in transit and at rest using robust algorithms. The cloud provider should not have access to encryption keys.
– Carefully configure access settings so that only authorized personnel can access PHI based on their role. Two-factor authentication is highly recommended.
– Establish contingency plans to retrieve data if the relationship with the cloud provider ends for any reason.
– Conduct a thorough risk analysis before uploading PHI to the cloud. Assessments should be repeated periodically.
– Understand how and where the cloud storage provider houses data. Using a vendor with data centers in multiple geographic regions can reduce risks.
– Verify the cloud vendor has strong physical and system security, backup systems, logging and audit procedures.
External hard drives and cloud services each come with their own advantages and disadvantages for securing PHI. Healthcare organizations must weigh the risks and benefits of each method carefully based on their specific needs and capabilities. Regardless of the storage solution, following HIPAA guidelines on encryption, access controls, risk analysis and auditing is essential to protecting patient data. With proper precautions, external and cloud storage can securely supplement an organization’s storage ecosystem and enable more efficient PHI access and sharing.
Risk Management for External and Cloud Storage
While the technical safeguards discussed are critical, healthcare organizations must also implement comprehensive risk management programs to protect PHI stored externally or in the cloud. Some key elements include:
Policies and Procedures
Detailed policies and procedures should outline proper use of external drives and cloud services for PHI. This includes:
– User access controls and authentication protocols
– Encryption requirements
– Asset management/tracking procedures
– Backup schedules and data recovery processes
– Retention periods and destruction procedures for external drives
– Event logging and alerting procedures
– Compliance audits and assessments
Personel should receive regular training on all policies. Procedures should be reviewed and updated periodically to address evolving security threats and new risk scenarios.
Business Associate Agreements
Cloud service providers that handle PHI are Business Associates under HIPAA. Rigorous Business Associate Agreements must be executed to ensure security and accountability. Agreements should outline:
– Permissible uses of PHI
– Security controls in place
– Breach notification processes
– Compliance with all HIPAA regulations
– Data ownership and transfer provisions
-associate termination procedures
Incident Response Plans
Despite best efforts, data breaches may still occur. Incident response plans outline processes to limit damage, including:
– Emergency containment procedures
– Investigation protocols and forensic analysis
– Notification procedures for affected individuals, HHS and others
– Post-incident mitigation like data recovery and preventing future breaches
– Evaluation and potential updates to policies, controls and risk assessments
The goal is to respond swiftly and effectively to any breach.
Ongoing audits evaluate real-world effectiveness of security controls and procedures for external and cloud storage. Different types of valuable audits include:
– General compliance audits to assess adherence with HIPAA regulations
– Penetration testing to identify vulnerabilities in security controls
– Phishing simulations to improve cybersecurity awareness
– Access audits to detect unauthorized access attempts
– Vulnerability scanning to identify risks like outdated software
Backups and Contingency Planning
If external drives or cloud accounts fail or are otherwise unavailable, contingency plans enable continued operations and prevent catastrophic data loss. Elements include:
– Regular backups of PHI to alternate devices/locations
– Secondary cloud accounts for redundancy
– Retention of previous PHI backup versions
– Emergency procedures to restore access and recover data
Following contingency plans helps maintain productivity and safeguard PHI if issues arise.
With careful selection and implementation of security controls, coupled with robust risk management, external drives and cloud services can be safely leveraged for PHI storage. As technologies evolve, healthcare organizations must remain vigilant about identifying new cyber risks and enacting controls to counter them. Maintaining compliance and securely managing PHI is an ongoing process requiring continued diligence and adaptation.