confidentiality

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Confidentiality, Privacy, and Security:

Confidentiality, Privacy, and Security William A. Yasnoff, MD, PhD Oregon Health Division

Overview:

Overview Definitions Fair Information Practices Policies and Procedures Legislation Authentication Encryption Firewalls WWW security

Definitions:

Definitions PRIVACY: The right of individuals to hold information about themselves in secret, free from the knowledge of others.

Definitions (continued):

Definitions (continued) CONFIDENTIALITY: The assurance that information about identifiable persons, the release of which would constitute an invasion of privacy for any individual, will not be disclosed without consent except as allowed by law.

Definitions (continued):

Definitions (continued) SECURITY: The mechanisms by which confidentiality policies are implemented in computer systems, including provisions for: Access control Integrity Availability

Definitions (continued):

Definitions (continued) IDENTIFIABLE INFORMATION: Any information, including but not limited to demographic information, which will identify or may reasonably lead to the identification of one or more specific individuals.

Definitions (continued):

Definitions (continued) CONFIDENTIAL DATABASE: Any collection or grouping of information about individuals maintained by the Division in electronic form which is not comprised solely of public records subject to release on request, and the release of which could represent a breach of confidentiality. . . .

Definitions (continued):

Definitions (continued) . . . Such information includes, but is not limited to demographic information, medical or testing histories, clinical information, employment or financial status, the results of special studies, participation in or exclusion from specific programs, sources of . . .

Definitions (continued):

Definitions (continued) . . . information, or new collections of information derived from the linkage of one or more previously existing confidential databases.

Fair Information Practices:

Fair Information Practices Relevance Integrity Written Purpose Need-to-Know Access Correction Consent

1. Relevance:

1. Relevance All information collected should be necessary and relevant to public health or required by law. individuals entitled to privacy benefits of information should outweigh privacy concerns collection not overly burdensome, intrusive, or coercive

2. Integrity:

2. Integrity The integrity of information should be protected. prevent loss, interception, misuse maintain accurate, complete, timely data no unauthorized alteration or destruction

3. Written Purpose:

3. Written Purpose All information collected should be consistent with written public health purposes and/or required by law. databases must have written purpose(s) usage restricted to stated purpose(s) linkage of databases considered a new database

4. Need-to-Know Access:

4. Need-to-Know Access All confidential information should be accessible only on a need-to-know basis, both internally and externally. confidentiality agreements for all personnel access terminated when duties change no redisclosure external release for research requires IRB approval

5. Correction:

5. Correction Individuals should have access to information about themselves and the ability to correct this information to the extent allowed by law. maintain public list of all databases name of database description of information included information sources (non-confidential) disputed data must be marked

6. Consent:

6. Consent Information must be collected with the consent of the individual except as required by law. informed consent purpose of information collection data protections in place consequences of withholding information no consent if waived by law

Confidentiality Policies:

Confidentiality Policies Fair Information Practices Data Release Restrictions Personnel Agreements

Data Release Restrictions:

Data Release Restrictions Release without review is restricted Denominator > 50 [population data] Denominator > 10 [cohort data]

Personnel Issues:

Personnel Issues All personnel to sign confidentiality agreements periodically Special provisions for data system administrators

Confidentiality Provisions:

Confidentiality Provisions Definition of confidential information Need-to-know access only No redisclosure If questions, ask supervisor Breach will result in disciplinary action Confidentiality must be maintained indefinitely

Data System Administrators:

Data System Administrators Information used only as needed for administration of computer system Access granted to others only in accordance with established policies and procedures Disciplinary action for violations may be termination on first offense

Legislation:

Legislation Health Insurance Portability and Accountability Act (HIPAA) [1996] privacy standards by August 1997 security standards by February 1998 universal health identifier Fair Health Information Practices (bill introduced in 105th Congress)

Security:

Security Authentication Encryption Firewalls WWW

Authentication:

Authentication Who are you talking to? Methods what the user knows (password) what the user has (smartcard) what the user is (biometrics)

Passwords:

Passwords Longer is better Never use dictionary words word1;word2 is good working model Never write or store passwords On network, passwords often travel in the clear

End-to-End Authentication:

End-to-End Authentication Cryptography based Challenge-response response generated with encryption challenge varies to defeat interception Time synchronized password depends on time of day user-carried device generates password good for system administrators

Kerberos:

Kerberos User asks “key server” for access to target system Key server creates message, encrypts with user key, sends User decrypts message, then encrypts with “access key” of target system Key server sends “session key” to user and target system (both encrypted)

Kerberos:

Kerberos Key server must be secure Allows mediation by third party of access among multiple systems Potential model for electronic medical record exchange Developed at MIT

Cryptography:

Cryptography Convert plaintext into message readable only with “key” DES = data encryption standard 64 bit message 56 bit key uses repeated substitution, transposition breakable in reasonable time with large computer system (31 hrs @ $100K, 20 minutes @ $10 MM)

Cryptography:

Cryptography Triple-DES apply DES three times three different keys (168 bits total) now used for automated teller transactions

Public Key Cryptography:

Public Key Cryptography Public Key in phone directory Private Key known only to recipient Message encrypted with either key can be decrypted with the other sender encrypts with one key, receiver decrypts with the other key

RSA Cryptography:

RSA Cryptography Public key is product p x q Private key is factors p, q Security derived from difficulty in computing factors p, q if pq is large Larger key size provides more security

Firewalls:

Firewalls Separate, dedicated computer system Filters packets based on source and/or destination Mount disks read only Eliminate all unnecessary commands and services Minimum number of user accounts

Firewalls as Proxy Servers:

Firewalls as Proxy Servers Firewall connects to outside system, not your system By acting as your “proxy”, your system is protected from the outside system Can be used for telnet (session) ftp (file transfer)

Intrusion Detection:

Intrusion Detection Look for unusual access patterns or activity Types of evaluation statistical rule-based Example: lock account after 3 failed login attempts Assume all systems are subject to attempted unauthorized use

WWW Security:

WWW Security server scripts (Java) can execute programs on your machine! Types of WWW security SSL = secure sockets layer secure “pipe” between two machines transparent to application S-HTTP = secure HTTP secure “envelopes” for messages built into browsers

Security Pearls:

Security Pearls Back up key files Use encryption on sensitive data Use good passwords Network security requires expertise authentication encryption firewalls

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