Delfigo Security - Strong Authentication

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Regulatory Compliance

Changes Every Healthcare Institution Needs to Make?

In the wake of the recent data breach of Anthem Healthcare, which is believed to have compromised at least 80 million healthcare records, there is a need to re-examine security measures that merely meet baseline compliance needs, as opposed to those that may have a real impact on security. "There are three changes that every healthcare institution needs to make" says Dan Munro on

"The first is around the culture of security. What every healthcare institution is in the process of learning is that HIPAA “compliance” isn’t data/network level security.

There is no such thing as being “HIPAA Certified” in cloud computing.  Many hosting providers claim “HIPAA Compliance,” but they put the burden of any audits and assessments directly on their clients. The only hard evidence of best practices around security and privacy is a third party audit that is based on HHS’ Office of Civil Rights (OCR) Audit Protocol ‒ the same audit criteria that OCR uses for their audits. For us, this is more than just adherence to legislation, it’s a part of our company culture around protecting what we know to be our customers most valuable assets ‒ patient information. Mike Klein ‒ Co‒CEO of Online Tech, Inc. Is Anyone Really ‘HIPAA Compliant’ In Healthcare?

The second change is in securing the data itself. Healthcare enterprises need to establish airtight policies for encrypting all data both in transit and at rest.

Right now, attackers have the advantage. They know that all they have to do is pierce the porous perimeter of a typical large enterprise and they will find millions of records stored insecurely. We need every organization to implement full encryption for both data in transit and at rest and we need to redouble our efforts investing in new perimeter defense technologies. The traditional signature based detection model is no longer sufficient on its own. Marc Rogers Principal Security Researcher, CloudFlare

The third big change ‒ and technically the hardest ‒ is to abandon the almost ubiquitous use of social security numbers as a customer identifier across so much of healthcare.

This breach is different from any other recent cyber attack. The previous breaches were focused on stealing credit card data for quick cash. These thieves just built a stockpile of your social security numbers and income to use as part of a longer term strategy to steal your identity. As a cyber security expert, it frustrates me that companies are still using social security numbers as a customer identifier. If we want to talk about new cybersecurity laws, we should require all businesses and government organizations to simply stop using them. Theresa Payton ‒ CEO of Fortalice Solutions and former White House CIO"


FFIEC Finally Releases Supplement to Authentication in an Internet Banking Environment

The much anticipated FFIEC Authentication Guidance was released on June 28, 2011 as a supplement to the very dated 2005 Guidance on Authentication in an Internet Banking Environment.  The complete text of the Supplement to Authentication in an Internet Banking Environment is available on the FFIEC website.

There is not much difference from the draft mistakenly released on the National Credit Union Administration website in 2010. The guidance is weak in a number of areas, specifically the need for multi factor authentication in consumer banking, not just commercial banking; and the failure to address security of mobile banking.

The supplement does emphasize the need for ongoing updates of risk assessments and the need for a layered approach to security. Both recommendations commonly found among best practices for identity and authentication management.

A number of vendors will scramble to re-position their products as multi factor, or attempt to adapt single dimension OTP or challenge response offerings to address the emphasis on risk assessment and layered security. However, there are many current offerings available to address regulatory requirements of 2012. Careful research is essential to identifying an authentication solution  that not only fits yours needs, but does so without adding additional burden to users, and also provides a flexible platform that can adapt and extend to meet the challenges of tomorrow.


  1. Supplement to Authentication in an Internet Banking Environment
  2. BankInfo Security – New Authentication Directives Don't Address Emerging Risks


Protecting Access to electronic Personal Health Information (ePHI)

The HITECH Act contains incentives (and disincentives) designed to accelerate adoption of electronic health record (EHR) systems and deliver on the original goals of the Health Insurance Portability and Accountability Act (HIPAA). These goals are rightly identified as “critical to patient safety, quality of care and reduction of delivery costs.” These are all admirable goals. However, regardless of how admirable, there is little among the many recommendations that address the significant consequences that accompany the rollout of EHR systems.  Electronic medical records contain a vast wealth of personal information, and this information will only become more vulnerable, and more susceptible to potential misuse, as access extends to an ever wider network of consumers and health care providers. As has historically been the case with all information systems, the desire to provide more open access and greater usability is always at odds with genuine concerns for security and privacy.

The Privacy and Security Tiger Team of the Office of the National Coordinator for Health IT recently released recommendations aimed at addressing this big elephant in the room. They point out that the HIPAA Security Rule requires covered entities to implement procedures to verify that a person or entity seeking access to electronic PHI is the one claimed. However, the Security Rule does not specify authentication options, assurance levels or verification requirements. The Tiger Team’s goal was to establish stronger authentication policy as part of governance for the Nationwide Health Information Network (NwHIN). Their recommendations for authentication of a certified EHR include:

  • Baseline user authentication policies should require more than just user name and password for remote access. At least two factors should be required.
  • Organizations and entities are encouraged to adopt a risk based approach and provide multi factor authentication for sensitive, high risk transactions
  • Minimum two factor authentication of e-prescriptions of controlled substances are required, consistent with the current DEA rule.
  • Meaningful Use Stage 2 certification testing criteria for EHRs should include testing of compliance with the DEA authentication rule

It is refreshing to see direct commentary regarding stringent authentication standards. However, the open access-security conflict is clearly apparent throughout the document. This is evident in statements such as “providers must manage the risk of inappropriate access; however they should not set the identification requirements in a way that discourages or inhibits patients from participating.”  Open access to patients is no longer the future, it is happening now. EHR systems need to balance the requirement for access with the equally important need for security. An approach focused on layered access to information, using a risk based authentication modality that answers three simple questions – are you who you say you are, where will I allow you to go, and what will I allow you to do - is the best means of achieving this goal.    



  1. ONC Privacy and Security Tiger Team

  2. Summary: HIPAA Security Rule

FFIEC Mandates - Are You Prepared For The Coming Changes?

The FFIEC was expected to provide an update to the 2005 Guidance on Authentication in an Internet Banking Environment in early 2011. Yet here it is almost May and nothing has been forthcoming. Bank Information Security recently reported the release is close, but would not speculate on when it would actually occur, as one FFIEC agency is rumored to be holding up the process.

It would be a dramatic understatement for the FFIEC to simply “reiterate and reinforce” given the dramatic change in online banking risks today as compared to 2005. In the 5 years since the FFIEC last released its guidelines on risk strategies and authentication technologies, a query of the Privacy Data Clearinghouse database shows that 2135 publicly reported data breach incidents have occurred. These breaches compromised 459,217,337 sensitive records (bank account information, credit card numbers or Social Security numbers). The ready availability of more advanced technology that allows those with little or no programming knowledge to launch sophisticated attacks, combined with the recognition that a more aggressive criminal element exists today, would certainly require much more than a reaffirmation.

Banking institutions and industry associations demonstrated their concern about the pending guidelines by scrambling to provide feedback following the public availability of an initial draft, "Interagency Supplement to Authentication in an Internet Banking Environment”, mistakenly posted on the National Credit Union Administration website in December 2010. This has led security analysts to speculate on the possibility that important changes are ahead.
Currently, the leaked draft remains the only available indicator of what to expect. The draft contained the following recommendations:
  • More frequent risk assessments focusing on authentication and related controls at least every 12 months and prior to implementing new electronic financial services
  • More robust controls as the risk level of transactions increases.
  • Layered Security to detect and effectively respond to suspicious or anomalous activity both at initial login access and at initiation of online transaction
  • Multi Factor Authentication, well beyond simple device identification and easily answered challenge questions
  • Increased Customer Education and Awareness.
Here is the question: Are you prepared?  Many vendors are currently scrambling to re-position their products as multi factor, or attempting to adapt single dimension offerings to address the emphasis on layered security. In a complex and confusing market, careful research will be essential to identifying an authentication solution that will increase identity assurance without adding additional burden to users; while also providing a flexible platform that can adapt and extend to meet the challenges of tomorrow.
  1. Symantec Report on Attack Kits and Malicious Websites : Executive Summary
  2. Verizon 2011 Data Breach Report
  3. Privacy Rights List of Data Breaches 2005 to Present
  4. Top Nine Security Threats of 2011
  5. 2010 "Interagency Supplement to Authentication in an Internet Banking Environment" (summary here and here )
  6. 2005 Guidance on Authentication in an Internet Banking Environment

FFIEC To Offer New Guidance on Strong Authentication

Bank Info Security reports that the  Federal Financial Institutions Examination Council (FFIEC) is expected to provide new guidance on online banking and strong authentication:

 The Federal Financial Institutions Examination Council is expected to issue new security guidance revisiting online banking and strong authentication, according to industry experts who have been involved in recent meetings with the FFIEC.

Gartner Analyst Avivah Litan is quoted,  "I got the feeling that the guidance this time will be much more specific, suggesting banks might even be held more accountable in future cases of account takeover. Holding banks financially responsible for accounts would bring about significant change. Some solutions currently in place are more "check the box" solutions, designed primarily to address compliance, but not necessarily to improve security.

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