|By Gilad Parann-Nissany||
|April 12, 2013 09:15 AM EDT||
The new and enhanced HIPAA omnibus standard brings an interesting question with regards to cloud security and the shared responsibility model in IaaS clouds. Since the release of the HIPAA omnibus, we’ve received many questions around “BAA” agreements, and how the responsibility split actually happens between (for example) the cloud provider and an ISV providing a healthcare application in an IaaS environment.
Cloud HIPAA compliance still requires a shared responsibility model
Without getting to the details of what a “Business Associate Agreement” means, I’ll simply say that the updated regulation makes business associates (Healthcare ISVs’, and potentially the cloud providers themselves) of covered entities (i.e. clinics or hospitals) directly liable for compliance with certain requirements of the HIPAA privacy and security rules (read more about it in this excellent HIPAA survival guide post). In other words, the entire “food chain” (The cloud provider, the ISV, and any other business associates in the logical flow to the covered entity), should ideally sign a business associate agreement. But what is the practical meaning of such requirement in an IaaS cloud environment? As one should expect – full compliance can be achieved only if all parties (business associates) will enforce compliance where they can actually do so. The IaaS cloud provider for example, will prove compliance on the physical and hypervisor level, while the Healthcare ISV will prove compliance on the guest OS, the healthcare application, and PHI data stored in the cloud.
Cloud encryption is a critical element
When discussing the HIPAA omnibus standard with some of our healthcare oriented customers, they all say the same: Data encryption is a critical element for cloud security and compliance. It enables them to safely store personal health information (PHI) in a public cloud, knowing that the data will always stay encrypted, for example in a disk snapshot scenario, as well as when the data is backed up. This is critical for them, as encrypted PHI data does not disclose actual information; hence they are well within the compliance requirements, even if an encrypted snapshot is somehow lost. The bigger challenge for them is how to remain in compliance without compromising on critical cloud benefits such as flexibility and elasticity. Using the Porticor technology they were able to secure and encrypt PHI data quickly and effectively (click here for more information and the Porticor white paper), but as important, they integrated data encryption into their product flow without compromising cloud elasticity, by integrating the Porticor API both on the encryption level, as well as on the key management and key distribution level.
The IETF draft standard for M2M certificates is a security solution specifically designed for the demanding needs of IoT/M2M applications. In his session at @ThingsExpo, Brian Romansky, VP of Strategic Technology at TrustPoint Innovation, explained how M2M certificates can efficiently enable confidentiality, integrity, and authenticity on highly constrained devices.
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