Storing PHI Data on External Drives or Cloud Services
As technology advances, healthcare organizations are increasingly looking to external and cloud-based storage solutions for protected health information (PHI). While these solutions can provide benefits like lower costs, increased storage capacity, and data backup, they also come with potential risks regarding PHI security and HIPAA compliance that must be carefully evaluated.
Benefits of External and Cloud Storage
External hard drives and cloud storage services offer healthcare groups several advantages over traditional on-site servers for storing PHI data:
– Cost savings – External storage is often cheaper than maintaining and expanding internal storage systems. Cloud storage allows organizations to pay only for the capacity needed.
– Scalability – Additional storage can be added quickly and easily as needed.
– Accessibility – External and cloud storage allows authorized users to conveniently access PHI from multiple devices and locations. Data is available 24/7.
– Disaster recovery – Data is backed up offsite and protected from problems like fire, floods, or system crashes.
– Collaboration – Cloud sharing features allow employees, physicians, and partners to collaborate more efficiently on PHI.
Potential Risks and Challenges
However, along with the benefits come potential security and compliance risks that must be addressed:
– Unauthorized access – PHI could be accessed by hackers or unauthorized users if storage devices or cloud accounts are not properly secured and encrypted.
– Data transmission – Transferring PHI to the cloud means transmitting it over networks where it can potentially be intercepted.
– Loss of control – Organizations cede direct control over security and access to PHI stored in the cloud.
– Data location – Cloud providers may store data on servers outside the U.S., subjecting it to foreign laws.
– Dependence on provider – If a cloud provider experiences technical issues or goes out of business, access to PHI could be lost.
– HIPAA compliance – Healthcare groups must ensure cloud providers are meeting HIPAA requirements for data security, access control, auditing, etc.
Recommendations for Secure External PHI Storage
Healthcare organizations can store PHI safely on external and cloud platforms by taking these steps:
– Conduct a risk analysis before moving PHI storage externally. Identify security requirements.
– Select established, reputable companies with a track record of high security and uptime. Avoid startups.
– Investigate providers’ HIPAA compliance program, data storage practices, encryption methods, backup systems, and security auditing.
– Use business associate agreements with liability clauses to hold providers accountable for HIPAA requirements.
– Store the minimum PHI necessary and de-identify data if feasible.
– Encrypt all PHI during transmission and when at rest on storage devices or platforms.
– Leverage access controls, multi-factor authentication, activity logging, and usage auditing to secure accounts.
– Ensure proper security on external hard drives like automatic encryption, strong password protection, and physical control.
– Maintain onsite backups of cloud-based PHI and have a migration plan to retrieve data if a provider fails.
– Stay up to date on evolving external storage risks, regulatory changes, and best practices.
External drives and cloud platforms offer healthcare organizations increased storage capacity, cost savings, and other benefits for housing PHI – but also introduce new security and compliance considerations. Following best practices for risk analysis, provider evaluation, and technical and administrative safeguards can help maximize the advantages while minimizing the potential pitfalls of PHI storage beyond the facility firewall. With proper due diligence and precaution, external storage can provide a safe and effective data solution.
Compliance Considerations for Cloud Storage of PHI
Using external cloud storage platforms introduces complexities regarding healthcare compliance that organizations must address:
– HIPAA rules apply to cloud storage just as they do onsite servers. Organizations retain responsibility for managing PHI and HIPAA security requirements.
– Cloud providers that access, store or transmit PHI are business associates and must comply with HIPAA and sign business associate agreements.
– HIPAA regulates PHI of U.S. patients but does not prevent offshore storage. This can create issues with foreign laws governing data.
– Contracts should specify that PHI must remain stored only within the U.S. or other specified locations to maintain HIPAA protection.
– Cloud providers often use subcontractors like data centers. They must have business associate agreements with subcontractors.
– Covered entities should contractually limit subcontractor access to PHI and require notification of new subs.
Right to Audit
– HIPAA grants covered entities right to audit business associates’ data security compliance.
– Contracts should specify audit authority, requirements, and financial responsibility.
– Audits may be conducted directly or via third-party auditors engaged by the covered entity.
Security Responsibilities and Options
While cloud providers bear responsibility for securing underlying infrastructure, organizations must take steps to protect PHI:
Minimum Necessary and De-identification
– Only the minimum necessary PHI should be stored in the cloud.
– De-identifying data to remove identifiers allows wider access without HIPAA restrictions.
– PHI must be encrypted when transmitted over networks and at rest in the cloud. Organizations control encryption keys.
Identity and Access Management
– Cloud identities must be linked to users and access strictly limited to appropriate personnel.
– Multifactor authentication should be enforced for cloud access.
– Cloud platforms should provide detailed access logs allowing monitoring for suspicious activity.
– Logs must be continually analyzed to identify potential insider threats.
– Cloud providers should have documented incident response plans that align with HIPAA breach notification rules.
– Contracts must outline provider and organization responsibilities in responding to incidents.
By understanding HIPAA obligations, establishing compliant contracts, and implementing administrative, physical, and technical safeguards, healthcare organizations can leverage cloud solutions to securely and effectively manage expanding PHI while maintaining compliance. Working closely with trusted, proven providers is key to reducing risks. With proper diligence, the cloud offers robust storage capacity along with enhanced accessibility, availability, and data protection.