Strategies to Monitor and Protect PHI from Inappropriate 3rd Party Access
by Gracie Belle Smith on September 14, 2023
Engaging with external parties such as vendors, suppliers, or contractors are often necessary to conduct business, but may bring unwarranted risk to your healthcare organization and your patients. Third-party risk can occur when potential threats and vulnerabilities go undetected as these third parties gain insider access to your sensitive and business-critical information. Healthcare sector attacks are becoming more sophisticated as large amounts of PHI data are lucrative targets for hackers and insider threats. Any breach or mishap on your third-party vendor's end can severely affect your organization’s reputation, financial health and patients.
Hospitals and health systems have countless third-party vendors that have access to a vast amount of PHI and PII. Compliance professionals must stay aware of these third-party accesses to ensure patient breaches do not occur. A single data breach from a third-party vendor can tarnish your organization's reputation, lead to financial losses, and even result in catastrophic legal consequences. This makes mitigating third-party risk crucial to safeguarding your organization, its assets, and most importantly, patient privacy.
More people are requesting access to our system to provide additional services…insider threats are those that are our employees, our contractor or anybody else that comes in contact with our solutions.” - Charles E. Christian, VP of Technology at Franciscan Health, healthsystemCIO webinar Strategies for Mitigating Insider Threat Risk
Practical Strategies to Mitigate Third-Party Risk: With the importance of mitigating third-party risk now prevalent, let's delve into some practical strategies you can implement to protect your organization:
Due Diligence with Good Governance of PHI
When a healthcare organization partners with a third-party software vendor, its threat landscape increases. A thorough vetting process is essential before entering into any business relationship. Conducting background checks and reviewing their security practices, certifications, and track record is the first step to ensuring your data is shared only with organizations who also practice good data governance. Without proper governance and safeguards, seemingly insignificant security breaches can adversely affect your organization in a serious way. Recent HHS Breach Data revealed insider unauthorized access was the most significant cause of breaches, reaching 93 percent. Whether these breaches were intentional, due to negligence, or even a lack of security controls between the two parties, these hidden dangers arise quickly disrupting your organization's operations. Proper management and monitoring of third-party access to PHI is critical in maintaining good governance of sensitive information.
Assess and Monitor
Understanding your threat landscape involves identifying your key vendors and what data is being shared between systems. During a recent healthsystemCIO webinar entitled “Strategies for Mitigating Insider Threat Risk”, Protenus CEO Nick Culbertson shared, "One of the things we often hear from CISOs and privacy officers is that it's really difficult to protect the data if you don't really know where all of it is." This challenging task leaves compliance professionals needing to establish the volume and sensitivity of shared data to determine each vendor's potential impact and risk probability. Once accomplished, your compliance team can begin to monitor PHI accesses and allow you to prioritize your mitigation efforts more effectively. Upon evaluating your vendors and their associated risks, you should include contracts with third-party vendors that explicitly outline their data security and privacy responsibilities. Involving legal experts to protect your interest is critical during this process. Remember that a well-drafted contract can be your first line of defense!
Build Awareness with Targeted Education
Empowering your organization's leaders with the knowledge of the increasing threat of third-party breaches enables them to make informative business decisions against bad actors. Gaining stakeholder buy-in doesn't end with leadership. Creating awareness throughout all facets of your organization develops a true culture of compliance. Awareness training can be fueled by targeted education that is pulled from insights gained from monitoring efforts. In the same healthsystemCIO webinar, Nick Culbertson suggested, "What we can do is identify those early warning signs or benign behaviors, reach out to them, and point out what they're doing wrong." Education, coupled with Patient Privacy Monitoring solutions like what is offered by Protenus help compliance professionals proactively monitor and intervene before it's too late can further enforce the need for proper security controls to protect your data from potential breaches.
Harness the Power of AI Technology
Risk management continues beyond the initial vetting stage. Regularly monitoring your vendors' security practices, conducting audits, and keeping a close eye on any security incidents or breaches through proactive monitoring allows your compliance team to address emerging risks promptly and stay ahead of evolving threats. In the face of increasingly sophisticated cyber threats, relying solely on traditional security measures is no longer sufficient. Adam Zoller, CISO at Providence believes leaning on data-driven insights are the key to understanding “your risk posture as an organization and the proactive measures you’ve put in place to protect against adverse events.” Implementing monitoring controls like Protenus allows your team to harness the power of artificial intelligence (AI) technology to augment your monitoring efforts, providing an additional layer of security controls. An AI-driven solution proactively detects potential threats to patient privacy enabling you to investigate further and ensures patient data remains secure.
Mitigating third-party risk might not have been at the forefront of your priority list, but it's undoubtedly one that deserves your compliance team’s attention. By implementing these strategies, including AI-driven technology, you can proactively protect your organization from potential threats, ensure smooth operations and maintain your reputation. Remember, prevention is always better than dealing with the aftermath of a risk gone awry. So, take the necessary steps to safeguard your organization, and feel confident your organization, workforce, and, ultimately, your patients privacy are secure from third-party risks.