Disadvantages of Spreadsheets – Obstacles to Compliance in the Healthcare Industry

Most of the regulatory compliance issues we talked about concerning spreadsheets have been related to financial data. But there are other kinds of data that are stored in spreadsheets which may also cause regulatory problems in the future.

In the US, a legislation known as HIPAA or Health Insurance Portability and Accountability Act is changing the way health care establishments and practitioners handle patient records. The HIPAA Privacy Rule is aimed at protecting the privacy of individually identifiable health information a.k.a. protected health information (PHI).

Examples of PHI include common identifiers like a patient’s name, address, Social Security Number, and so on, which can be used to identify the patient. HIPAA covers a wide range of health care organisations and service providers, including: health plan payers, health care clearing houses, hospitals, doctors, dentists, etc.

To protect the confidentiality, integrity, and availability of PHI, covered entities are required to implement technical policies such as access controls, authentication, and audit controls. These can easily be implemented on server-based systems.

Sad to say, many health care organisations who have started storing data electronically still rely on spreadsheet-based systems. Those policies are hard to implement in spreadsheet-based systems, where files are handled by end-users who are overloaded with their main line of work (i.e. health care) and have very little concern for data security.

In some of these systems, spreadsheet files containing PHI may have multiple versions in different workstations. Chances are, none of these files have any access control or user authentication mechanism whatsoever. Thus, changes can easily be made without proper documentation as to who carried out the changes.

And because the files are normally easily accessible, unauthorised disclosures – whether done intentionally or accidentally – will always be a lingering threat. Remember that HIPAA covered entities who are caught disclosing PHI can be fined from $50,000 up to $500,000 plus jail time.

But that’s not all. Through the HITECH Act of 2009, business associates of covered entities will now have to comply with HIPAA standards as well. Business associates are those companies who are performing functions and services for covered entities.

Examples of business associates are accounting firms, law firms, consultants, and so on. They automatically need to comply with the standards the moment they too deal with PHI.

More Spreadsheet Blogs

Spreadsheet Risks in Banks

Top 10 Disadvantages of Spreadsheets

Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry

How Internal Auditors can win the War against Spreadsheet Fraud

Spreadsheet Reporting – No Room in your company in an age of Business Intelligence

Still looking for a Way to Consolidate Excel Spreadsheets?

Disadvantages of Spreadsheets

Spreadsheet woes – ill equipped for an Agile Business Environment

Spreadsheet Fraud

Spreadsheet Woes – Limited features for easy adoption of a control framework

Spreadsheet woes – Burden in SOX Compliance and other Regulations

Spreadsheet Risk Issues

Server Application Solutions – Don’t let Spreadsheets hold your Business back

Why Spreadsheets can send the pillars of Solvency II crashing down

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The General Data Protection Regulation & The Duty to use Encryption

The General Data Protection Regulation, abbreviated to GDPR, raised a storm when it arrived. In reality, it merely tightened up on existing good practice according to digital security specialists Gemalto. The right to withhold consent and to be forgotten has always been there, for example. However, the GDPR brings a free enforcement service for consumers, thus avoiding the need for third party, paid assistance.

The GDPR Bottom Lines for Data Security
Moreover, the GDPR has penalties it can apply, of the order that might have a judge choking on his wig. Under it, data security measures such as pseudonymisation (substitution of identifying fields) and encryption (encoding including password protection) have become mandatory. Businesses must further respect their client data by:

a) Storing it in a secure environment supported by robust services and systems

b) Having proven measures to restore availability and access after a breach

c) Being able to prove frequent effectiveness testing of these measures.

The General Data Protection Regulation places an onus on businesses to report any data breaches. This places us in a difficult situation. We must either face at least a wrist slap upon reporting failures. Alternatively, pay a fine of up to ?10 million, or 2% of total worldwide annual turnover.

The Engineered Weak Link in the System
Our greatest threat of breach is probably when the data leaves our secure environment, and travels across cyberspace to an employee, stakeholder, collaborator, or the client themselves. Since email became open to attack, businesses and individuals have turned to sharing platforms like Dropbox, Google Drive, Skydrive, and so on. While these do allow an additional layer of password protection, none of these has proved foolproof. The GDPR may still fine us heavily, whether or not we are to blame for the actual breach.

How Hacking is Approaching Being a Science
We may make a mistake we may regret, if we do not take hacking seriously. The 10 worst data hacks Identity Force lists are proof positive that spending lots of money does not guarantee security (any more than having the biggest stock of nuclear weapons). We have to be smart, and start thinking the way that hackers do.

Hacker heaven is finding an Experian or a Dun & Bradstreet that may have shielded 143 million, and 33 million consumer records respectively, behind a single, flimsy cyber-security door. Ignorance is no excuse for them. They should simply have known better. They should have rendered consumer data unreadable at individual record level. The hackers could have found this too demanding to unpick, and have looked elsewhere.

How Data Encryption Can Help Prevent Hackers Succeeding
Encrypting data is dashboard driven, and businesses need not concern themselves about it works. There are, however, a few basic decisions they must take:

a) Purge the database of all information held without explicit permission

b) Challenge the need for the remaining data and purge the nice-to-haves

c) Adopt a policy of encrypting access at business and customer interfaces

d) Register with three freemium encryption services that seem acceptable

e) After experimenting, sign up for a premium service and be prepared to pay

Factors to Consider When Reaching a Decision
Life Hacker?suggests the following criteria although the list is a one-size-fits-all

a) Is the system fast, simple, and easy to operate

b) Can you encrypt hidden volumes within volumes

c) Can you mass-encrypt a batch of files easily

d) Do all other files remain encrypted when you open one

e) Do files automatically re-encrypt when you close them

f) How confident are you with the vendor, on a scale of 1 to 10

It may be wise to encrypt all the files on your system, and not just your customer data. We are always open to a hack by the competition after our strategic planning. If we leave the decision up to IT, then IT, being human may take the easy way out, and encrypt as little as possible.

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Mobile Security

Today’s advanced enterprises make extensive use of mobile devices in order for team members to exchange information, collaborate, and carry out business whenever and wherever they need to. BlackBerries, iPhones, Google Phones, and other smartphones as well as PocketPCs and PDAs are now allowed wireless remote access to the enterprise network.

As a result, they introduce additional vulnerabilities into the system.

Bluetooth exploits and unencrypted passwords can allow malicious individuals to gain access to private information.
Various wireless technologies that have substantially simplified the task of transferring data have provided openings for malicious code. In addition, the diversity of these wireless technologies combined with the constrained environments of these devices have made it difficult to come up with an all-in-one solution.
All PocketPCs, PDAs and smartphones can be synchronised with PCs and laptops, giving malware an entry point into computers and networks. Memory cards are guilty of this too.
VoIP, which are usually unencrypted, allow other people to perform unauthorised capture and recording of private conversations.

Mobile security is still an emerging discipline. Because of this, many organisations that allow members’ mobile phone access into the network don’t actually have a specific security policy for such devices.

That’s why we’re here to help. We’ll conduct a thorough evaluation of your security policies and systems in relation to mobile devices and seal gaps we spot along the way. If you don’t have the needed policies or if what you have needs an overhaul, we’ll set everything up (including the needed applications and infrastructure) for you.

Once we’ve got everything in place, you won’t have to worry about the vulnerabilities mentioned earlier. In addition to that, your organisation will already be capable of preventing the following:

Access to company information when the phone ends up in the hands of anyone other than the authorised user.
Being billed for phone usage due to virus activity
Unauthorised phone activity monitoring through spyware
Other disruptions caused by mobile-based malware

Other defences we’re capable of putting up include:

The Better Way of Applying Benford’s Law for Fraud Detection

Applying Benford’s Law on large collections of data is an effective way of detecting fraud. In this article, we?ll introduce you to Benford’s Law, talk about how auditors are employing it in fraud detection, and introduce you to a more effective way of integrating it into an IT solution.

Benford’s Law in a nutshell

Benford’s Law states that certain data sets – including certain accounting numbers – exhibit a non-uniform distribution of first digits. Simply put, if you gather all the first digits (e.g. 8 is the first digit of ?814 and 1 is the first digit of ?1768) of all the numbers that make up one of these data sets, the smallest digits will appear more frequently than the larger ones.

That is, according to Benford’s Law,

1 should comprise roughly 30.1% of all first digits;
2 should be 17.6%;
3 should be 12.5%;
4 should be 9.7%, and so on.

Notice that the 1s (ones) occur far more frequently than the rest. Those who are not familiar with Benford’s Law tend to assume that all digits should be distributed uniformly. So when fraudulent individuals tinker with accounting data, they may end up putting in more 9s or 8s than there actually should be.

Once an accounting data set is found to show a large deviation from this distribution, then auditors move in to make a closer inspection.

Benford’s Law spreadsheets and templates

Because Benford’s Law has been proven to be effective in discovering unnaturally-behaving data sets (such as those manipulated by fraudsters), many auditors have created simple software solutions that apply this law. Most of these solutions, owing to the fact that a large majority of accounting departments use spreadsheets, come in the form of spreadsheet templates.

You can easily find free downloadable spreadsheet templates that apply Benford’s Law as well as simple How-To articles that can help you to implement the law on your own existing spreadsheets. Just Google “Benford’s law template” or “Benford’s law spreadsheet”.

I suggest you try out some of them yourself to get a feel on how they work.

The problem with Benford’s Law when used on spreadsheets

There’s actually another reason why I wanted you to try those spreadsheet templates and How-To’s yourself. I wanted you to see how susceptible these solutions are to trivial errors. Whenever you work on these spreadsheet templates – or your own spreadsheets for that matter – when implementing Benford’s Law, you can commit mistakes when copy-pasting values, specifying ranges, entering formulas, and so on.

Furthermore, some of the data might be located in different spreadsheets, which can likewise by found in different departments and have to be emailed for consolidation. The departments who own this data will have to extract the needed data from their own spreadsheets, transfer them to another spreadsheet, and send them to the person in-charge of consolidation.

These activities can introduce errors as well. That’s why we think that, while Benford’s Law can be an effective tool for detecting fraud, spreadsheet-based working environments can taint the entire fraud detection process.

There?s actually a better IT solution where you can use Benford’s Law.

Why a server-based solution works better

In order to apply Benford’s Law more effectively, you need to use it in an environment that implements better controls than what spreadsheets can offer. What we propose is a server-based system.

In a server-based system, your data is placed in a secure database. People who want to input data or access existing data will have to go through access controls such as login procedures. These systems also have features that log access history so that you can trace who accessed which and when.

If Benford’s Law is integrated into such a system, there would be no need for any error-prone copy-pasting activities because all the data is stored in one place. Thus, fraud detection initiatives can be much faster and more reliable.

You can get more information on this site regarding the disadvantages of spreadsheets. We can also tell you more about the advantages of server application solutions.