Data Security for PII & PHI

There are many concerns from consumers and clients about protecting data security and privacy of personal identifiable and health data. Data Breaches is becoming too common among organizations that collect, store or process this information. As a result, protecting personally identifiable information (PII) and Protected Health Information (PHI) data has become a critical accountability and responsibility for organizations that handle such sensitive information. In today's digital age, data breaches and cyber-attacks are increasingly common and can result in significant financial, legal, and reputation damage. Organizations must implement effective controls to safeguard PII and PHI data from unauthorized access, use, disclosure or theft.

Personally identifiable information (PII) and Protected Health Information (PHI) are two types of sensitive information that require specific protections. PII refers to any information that can be used to identify an individual, such as name, address, Social Security number, or driver’s license number. PHI, on the other hand, refers to any information related to an individual’s health status or medical treatment, such as medical records, test results, and health insurance information. PHI is subject to additional legal protections under the Health Insurance Portability and Accountability Act (HIPAA) to ensure its confidentiality or use inappropriately. While PII and PHI may overlap in certain cases, they are distinct categories of sensitive information that require different levels of protection.

PII data security encompasses a broad range of protocols aimed at not only monitoring users’ data regularly but also mitigating the risk of security breaches in the event that one occurs. Here are some notable mentions

Identify the PII your company stores and find all locations where it is stored. Identifying and locating all instances of PII data within an organization is essential to effectively protecting it. Some steps that organizations can take include:

• Data inventory: Creating an inventory of all data assets that contain PII, including databases, file shares, and backup files.

• Data classification: Classifying PII data according to its sensitivity level to determine the appropriate security controls.

• Data mapping: Mapping the flow of PII data through the organization to identify potential security risks and vulnerabilities.

Access controls are designed to ensure that only authorized personnel have access to sensitive PII data. These controls can include:

• Password policies: Requiring strong passwords that are regularly changed, and implementing two-factor authentication to verify user identities.

• Least privilege: Ensuring that each user has only the minimum level of access required to perform their job duties, and no more.

• User monitoring: Regularly monitoring user activity to detect and respond to unauthorized access attempts.

Encryption is the process of converting plain text into a scrambled format that is unreadable without the appropriate decryption key. Encryption can be used to protect PII data both at rest (i.e. when stored on a server or in a database) and in transit (i.e. when being transmitted over a network). Some encryption controls to consider include:

• Data encryption: Encrypting PII data using industry-standard encryption algorithms such as AES-256 or RSA.

• Key management: Ensuring that encryption keys are securely stored and rotated regularly.

• Transport encryption: Using secure communication protocols such as SSL/TLS to encrypt PII data in transit.

Monitoring and auditing controls are designed to detect and respond to unauthorized access attempts and other security incidents involving PII data. Some monitoring and auditing controls to consider include:

• Security information and event management (SIEM): Implementing a SIEM tool to monitor network activity and generate alerts when suspicious activity is detected.

• Log management: Collecting and analyzing system logs to detect anomalies and identify security incidents.

• Incident response plan: Creating an incident response plan that outlines the steps to be taken in the event of a security incident involving PII data, and assigning roles and responsibilities to team members.

Similar to PII, there are several security controls regarding PHI data that ensure the confidentiality and privacy of protected health information and compliance with HIPAA and HITECH regulations.

Physical security controls are designed to protect the physical devices and locations where PHI data is stored. Some physical security controls to consider include:

• Facility access controls: Implementing physical access controls such as badge readers, security cameras, and biometric authentication to restrict access to areas where PHI data is stored.

• Secure storage: Storing PHI data in secure locations such as locked filing cabinets or secure data centers.

• Environmental controls: Implementing environmental controls such as fire suppression systems and temperature and humidity monitoring to protect against physical damage and environmental hazards.

Technical security controls are designed to protect PHI data from unauthorized access or disclosure through electronic means. Some technical security controls to consider include:

• Encryption: Encrypting PHI data at rest and in transit to prevent unauthorized access.

• Network security: Implementing firewalls, intrusion detection and prevention systems, and other network security measures to protect PHI data transmitted over networks.

• Data loss prevention: Implementing data loss prevention (DLP) software to monitor and prevent unauthorized copying or transfer of PHI data.

Privacy controls are designed to protect the confidentiality and privacy of PHI data. Some privacy controls to consider include:

• Access controls: Ensuring that only authorized personnel have access to PHI data and that access is based on the user's job role and responsibilities.

• Minimum necessary rule: Limiting access to only the minimum necessary PHI data required to perform a job function.

• Notice of privacy practices: Providing patients with notice of the organization's privacy practices and their rights related to their PHI data.

Incident response is the process of identifying, containing, and mitigating the impact of a security incident. Having a well-defined incident response plan can help organizations quickly and effectively respond to security incidents involving PHI data. Some key controls to consider include:

• Incident response plan: Developing a comprehensive incident response plan that outlines the roles and responsibilities of personnel, the steps to be taken in the event of a security incident, and the communication protocols for reporting and escalating incidents.

• Regular testing: Regularly testing the incident response plan to identify areas for improvement and ensure that personnel are familiar with their roles and responsibilities.

• Training and awareness: Providing regular training and awareness programs for personnel on incident response procedures and best practices for handling PHI data.

Protecting PII and PHI data is crucial for individuals and organizations, as it carries great importance and sensitivity. Implementing security best practices in data protection can help organizations comply with regulations, preserve their reputation, and build trust with their customers. Therefore, it is important for individuals ans organizations to prioritize data protection and continually improve their security controls to ensure the security and privacy of this PII and PHI.

Talk to a Cybersecurity Trusted Advisor at IRM Consulting & Advisory