FHIR Security and Privacy - Open Educational Session

For those going to HL7 WGM in Dallas. I will be available Wednesday afternoon in an open educational session on FHIR Security and Privacy:

The best case is that everyone that comes to the session would have reviewed the freely available recorded tutorial sessions, and/or the freely available slides; so that we can have discussions and solve the world's problems regarding FHIR Privacy and Security.

- Recorded session -- https://vimeo.com/853094845/671e02f6db

- My slide deck -- http://bit.ly/FHIR-SecPriv 

Bonus points if people come having reviewed my IHE Privacy Consent on FHIR webinar

Super excited if people come with FHIR Security and Privacy problems that I have not yet written about. I would love to come out of this session scratching my head and inspired to create more solutions.

Why does IHE-MHDS not have a Document Repository?

The IHE-MHDS does not define a Document Repository Actor but does include architecture support for distributed FHIR Servers and thus the concept of a Document Repository is included in MHDS. The MHDS profile specifies how a collection of IHE profiles can be used by communities for exchanging health information, which includes support for patient identification, health document location and retrieval, provider directories, and the protection of privacy and security https://profiles.ihe.net/ITI/MHDS.

The Document Repository and Document Registry is an architectural construct that is foundational to XDS, but not necessarily part of Document Sharing. For example: XCA also does not make a distinction between a Document Registry or Document Repository, having a Responding Gateway Actor.

The MHDS profile defines a Document Registry Actor that persists, manages, and provides access using the MHD access methods. This supports IHE Document Sharing as described in the Health Information Exchange: Enabling Document Sharing Using IHE Profiles White Paper. The central HIE infrastructure defined in MHDS profile might be a single FHIR Server implementing all the defined central service actors or may be a virtual cloud of systems implementing the defined profile actors.

IHE-MHDS does not define the Document Repository Actor, as the concept of a set of distributed FHIR Servers is very natural to REST architecture. Thus IHE did not add complexity by defining a formal Document Repository Actor, as the concept can be addressed naturally with REST. For more detail see the Storage of Binary section in the MHDS profile. This is also explained in the HIE Whitepaper in section 3.2 Centralized Discovery and Retrieve

If you're looking for details on the functionalities or its implementation, the MHDS Volume 1 documentation would be a good resource to explore further. It outlines the core business functions provided by the MHDS Profile, including the publication of document-based information, persistence and lifecycle management of documents, and patient identity management among others. For broader discussion on the Document Sharing concept the whitepaper is more inclusive.

recording of my IHE Privacy Consent on FHIR webinar

I thank Health Samurai for making the recording of the Access Control meetup sessions available. Here is my presentation, and from that you can find the others.

Meetup on #FHIR Access Control

I will be speaking at an event coming up on Access Control. This is not just me speaking about IHE-PCF, but much more.

Join us for the FHIR® Access Control Meetup where we'll take a closer look at the real-world challenges and solutions.

 

Here's what you can look forward to:

• Privacy Policy Foundations: Dive into the essentials with John Moehrke, HL7 Security Workgroup Co-Chair. A great chance to understand the backbone of healthcare data security.
• Authorization Nuances: Explore the complex world of authorization with Josh Mandel, Microsoft Healthcare's Chief Architect. Perfect for those looking to navigate the intricacies of access control.
• Data Segmentation for Privacy: Learn from Mohammad Jafari, a Senior Privacy Consultant, about segmenting data to enhance privacy. An invaluable session for anyone interested in data protection.
• FHIR Label-based Access Control: Gain insights from Mike Kulakov, Health Samurai's Product Manager, on the innovative approaches to access control using FHIR labels.

Plus, you'll have the chance to ask questions to the speakers and engage in a round-table discussion.

 

Can’t attend? Register anyway and we’ll send you a recording after the meetup!

Sharing IPS (sIPS)

This Implementation Guide ready for Trial-Implementation.  Formal Publication -- https://profiles.ihe.net/ITI/sIPS

The Sharing of IPS (sIPS) IHE Profile provides for methods of exchanging the HL7 International Patient Summary (IPS), using IHE Document Sharing Health Information Exchange but does not modify the HL7 IPS specification, nor is there any need to change IHE Document Sharing Health Information Exchange. This means that any existing XCA/XDS environment needs NO change to support the IPS.

The International Patient Summary (IPS) content,
as defined in the ISO 27269 data model specification, utilizes IHE’s document sharing infrastructure including cross-community, HIE, direct exchange models, and more. It has been designed specifically to remove barriers to adoption, by leveraging architectures that are currently implemented, well-established, and robust. 

The sIPS Profile provides implementation guidance to vendors and implementers and joins a growing suite of IPS standards artefacts contributed by a variety of Standards Development Organizations (SDOs) and coordinated by the Joint Initiative Council for Global Health Informatics Standardization (JIC).

YouTube presentation, long, and short.

If you want a purely FHIR transport for this FHIR IPS, then look to the
Mobile Health Document Sharing (MHDS) Profile

CyberSecurity recommendation

My top recommendation is to look to experts in that field. I mostly participate in healthcare standards organizations such as HL7, IHE, and DICOM. These standards organizations focus on health informatics interoperability, they are not experts in CyberSecurity. These healthcare standards always recommend that you use standards developed by appropriate standards organizations. See the 2023 HL7 Cyber Security Event with all recordings available now. My HL7 FHIR Security and Privacy Education track.

My second top recommendation is to make it very clear that Security (and Privacy, and Safety) are risk domains. Meaning that you must manage them according to risk, not a checklist. A checklist can help you be comprehensive in your analysis, but it can't help you determine the actual risk, and it can't decide for you what level or risk you are willing to accept. I covered risk in a blog article 12 years ago, and it is still relevant.

• I prefer NIST Cybersecurity Framework (CSF) because it is free, and it is very readable. This is a high-level roadmap for managing comprehensive cybersecurity risk.  It can be used by large and small organizations.
• I know that some are forced to use ISO 27001 and 270002. I am okay with these, but accessibility to ISO specifications is a big problem. This is international specification, so is seen as appropriate everywhere outside the USA. There is a large number of consulting firms that can help with the implementation of this.
• In the USA the HITRUST organization, although expensive, has a crosswalk of all the cybersecurity frameworks; and a methodology to record evaluation and decisions. This would be my recommendation if an organization didn't have experts on staff and needed to get started.

HITRUST and NIST are just as applicable outside the USA, but I also recognize that some see anything with a USA focus to be bad for use outside the USA.

• For specific things like a FHIR or even a SOAP interface, is where I would add the prioritization and clarity that OWASP brings. 

Of course, we leverage other standards by security experts including IETF(https, tls, s/mime, oauth, certs), and W3C (signatures, prov, p3p, soap), ETSI (XAdES, PAdES, JAdES), NIST (AES, SHA), etc. 

What is your recommendation?

PS, sorry about the AI authored answer a few weeks ago - Give me a cyber security check list for FHIR RESTful API Systems, but you will note it is similar.

Give me a cyber security check list for FHIR RESTful API Systems

So I asked Gemini, googles latest AI...

Cyber Security Checklist for FHIR RESTful API Systems

FHIR (Fast Healthcare Interoperability Resources) is a standard for healthcare data exchange. It is important to secure FHIR RESTful API systems to protect sensitive patient data. Here is a checklist to help you secure your FHIR API system:

Authentication and Authorization

• Implement strong authentication: Use a standard like OAuth 2.0 or OpenID Connect to authenticate users and clients. This will help to ensure that only authorized users and applications can access the API.
• Implement authorization: Use a fine-grained authorization system to control what users and applications can do with the API. This includes what data they can access, what operations they can perform, and what resources they can create, read, update, and delete.
• Use strong passwords: Enforce strong password policies for all users. This includes requiring a minimum password length, complexity requirements, and regular password changes.

Data Security

• Encrypt data at rest and in transit: Use strong encryption algorithms to protect patient data at rest and in transit. This will help to prevent unauthorized access to the data, even if it is intercepted.
• Mask sensitive data: Mask sensitive data, such as Social Security numbers and credit card numbers, before returning it from the API. This will help to prevent unauthorized disclosure of the data.
• Implement logging and auditing: Log all API access attempts, including successful and failed attempts. This will help you to track who is accessing the API and what they are doing.

Other Security Measures

• Keep software up to date: Regularly update your FHIR server software and any other software that is used to access the API. This will help to fix security vulnerabilities that could be exploited by attackers.
• Perform regular security assessments: Regularly assess the security of your FHIR API system to identify and fix any vulnerabilities.
• Monitor for suspicious activity: Monitor your FHIR API system for suspicious activity, such as unauthorized access attempts or unusual data access patterns.

By following these recommendations, you can help to secure your FHIR RESTful API system and protect sensitive patient data.

Additional points to consider:

• Rate limiting: Implement rate limiting to prevent denial-of-service attacks.
• Input validation: Validate all input to the API to prevent malicious attacks, such as SQL injection attacks.
• Error handling: Handle errors gracefully and avoid returning sensitive information in error messages.
• Security awareness: Train your staff on the importance of security and how to protect patient data.

By following these recommendations, you can help to ensure the security of your FHIR RESTful API system and protect sensitive patient data.