The Sony data breach is an exclamation mark on a year that is already known as the” Year of the Data Breach.” This data breach is the kind that makes even the least squeamish avert their eyes and wince. There are at least three things that this breach can teach us:
Last week, I gave a keynote address at a conference called Safeguarding Health Information: Building Assurance through HIPAA Security, sponsored by the National Institute of Standards and Technology (NIST) and the Department of Health and Human Services (HHS), Office for Civil Rights (OCR). I’d like to summarize my remarks here for anyone interested who wasn’t able to attend.
I was recently interviewed in the Journal of AHIMA on how the C-suite is waking up to the new realities of privacy and data security risks. Before the HITECH Act in 2009, HIPAA enforcement was based on a cooperative model where HHS was not punitive in its approach. Now, big fines are being issued. There is auditing. The climate has changed.
Privacy and security risks are quite costly. This is true not just under HIPAA, but also as a general matter. At many organizations, the C-Suite doesn’t fully appreciate the magnitude of the risk. Back about 10 years ago, for many organizations, privacy and security risks were barely on the radar. Now they are recognized for many organizations, but the significance of the risk is often not fully understood or appreciated.