The National Institute of Standards and Technology (NIST) released its proposed guidelines last week, which call for organizations to develop capabilities for continuous monitoring and enterprise-wide tracking of information to better measure the effectiveness of security policies and calculate risk of fraudulent activity.

This is a forward-thinking approach by NIST, and we believe this is a step in the right direction.

Securing information management systems is essential for the wellbeing of companies. The value of information within today’s organizations is unprecedented, and companies should prioritize investments in ways to better protect and manage their information from insider attacks and fraud. Unfortunately, due to vulnerabilities in organizations’ infrastructure, organizations average approximately 53 employee-related incidents of fraud annually, which translates to approximately one incident per week.

From data storage to file transfers, many companies have distributed information systems that control many different tasks related to content management; companies grant specific permissions to employees to access the information in these repositories. While nearly all employees will access this information in order to complete their work, there is a risk that someone could have more devious intentions. A single case of insider abuse can have detrimental consequences.

The NIST guidelines call for organizations to adopt a “trust-but-verify” approach to information security, granting access to employees while monitoring for suspicious activity. Continuous monitoring provides a full picture of an organization’s security posture, measures the extent to which the organization is threatened by a potential circumstance or event, and enables the organization to make informed decisions to address risk.

Companies can start securing their information now by taking three actions:

1. Audit your company’s current information management infrastructure to identify where information is being accessed, processed and stored. Because many companies have information spread across multiple systems, it is essential for you to understand all the access points and how different solutions are securing (or not securing) your organization’s important content and data.

2. Understand the privacy and security policies that are currently in place at your organization and identify where improvements can be made with the NIST guidance. By understanding the policies your organization currently has established and comparing that to the NIST guidance, you can identify areas where your information management systems could be more secure and your information better protected against insider fraud.

3. Compare information management systems that can help consolidate the monitoring and auditing practices outlined by NIST. Attachmate’s Luminet solution can help companies stop fraud and misuse of important information, gain compliancy with industry regulations without additional coding, and more easily create accurate, detailed audits of network access.

It is important for organizations to trust the people they hire, but it is also essential organizations take steps to protect themselves from the possibility of an insider attack on information. Be sure to check out the proposed NIST guidelines today to protect your information tomorrow.

-Christine Meyers, senior product marketing manager, Attachmate Luminet

Today’s next generation of fraud detection technologies can go a long way to supporting a HIPAA HITECH compliance effort and prevent privacy violations, misuse and abuse. Simply put, these systems provide visibility across multiple data channels to offer a comprehensive view of what is going on in your environment. Leading solutions offer screen-by-screen replay of user activity which offers “context to keystrokes” and provides the ability to look at each screen viewed by a particular user. Through this method, organizations can understand and capture the “why” of data access. Monitoring and alerting on specific events is also available. These solutions can actively target violations and unauthorized access.

More and more, leading healthcare institutions are migrating to the new fraud monitoring technologies. This new approach moves far beyond the logging and monitoring solutions that may “check a box” for compliance, but do little to address advanced audit requirements or fill in the “gaps” inherent in traditional logging systems. The benefits of monitoring data across applications and extending visibility beyond healthcare applications are essential to leading organizations seeking to protect patient privacy and their brand.

Let’s explore some of the areas that this new approach can assist with:

Common Healthcare Monitoring Scenarios

• Is a given user is logged in at multiple locations or while on vacation or absent from work? Accessing systems after hours?
• Is a particular user is accessing areas not appropriate for their job or function?
• Are physicians are accessing records outside their specialty?
• Are employees accessing high profile or VIP accounts inappropriately? Are staff members inappropriately accessing PHI within the institution?
• Are users accessing accounts more than 30 days after the date of service? Has key information on the account changed (address, services rendered, etc.)?

In healthcare, one of the most pernicious issues is accidental access of PHI rather than outright fraud (although fraud is still an issue). Take for example, improper record access in healthcare. While certainly a HIPAA violation, few would consider the desire to “sneak a peek” at an admission file fraud. Even so, these violations cost hospitals hundreds of thousands of dollars in fines annually and the resulting personnel action results in loss of staff and productivity. Fortunately, there is a better way.

Developing A Rules Based Approach

Continuous monitoring of user activity provides a comprehensive view of who, did what, when, and often even provides insight into why a particular activity occurred. Capturing data in this manner and applying a rules based approach to identifying risks and possible abuse, misuse and error in data can significantly improve audit performance.

Auditing Needs We Commonly Encounter and Assist With

• Developing a baseline of activity across a healthcare organization and using that to uncover and target areas at higher risk for patient privacy violations.
• Monitoring third-party activities, including call centers and claims processors and service providers, for a higher than baseline occurrence of out of band activity.
• Monitoring access to medical record, specifically highly sensitive material such as HIV test results where the inappropriate disclosure of such information may cause a patient harm.
• Identifying employees or other providers who demonstrate patterns of unauthorized access. Providing visibility into record access of VIP, high profile or opt out patients.
• Examining employee or provider look ups along high risk patterns: same last name, same street address, same zip code, etc.
• Enabling review of physician access and review of employee as patient access (employees as patients create a potential for misuse and/or abuse often out of concern or curiosity).
• Reviewing and auditing access by remote users. Providing the ability to review external third-party record access as well as the ability to monitor third-party activity for fraud, out-of-band approvals or requests and access appropriate to role.

Monitoring and Data Capture During a “Break Glass” Emergency

In many healthcare provider settings, there is the potential for a “break-the-glass” emergency which refers to an instance where it becomes necessary for individuals to violate access protocols to provide lifesaving or critical care. In these scenarios, it is essential to capture, document and retain user activity and information access for future audit and review. With enterprise fraud management solutions in place, this special audit trail is automatically created, encrypted and digitally signed. The records are retained in a sealed repository preserving the records as required.

Possible scenarios where this data capture may be required include a) account problems such as a locked password due to failed entry attempts or lack of a user account (visiting clinician required to assist during an emergency), b) authentication problems such as an authentication system failure, or c) an emergency situation forces personnel to respond in a way that exceeds their authorization.

During such a situation, it is essential that the entire activity trail is captured and preserved for later review. With monitoring in place, no paper logging is required. Today’s enterprise fraud management technologies can even trigger alerts when such a scenario occurs. Having an automatic, comprehensive audit trail has the potential to limit any required disclosure to the actual event and activity rather than a “worst case” access scenario.

Responding to Emerging “Accounting of Disclosure Requirements”

Lastly, an additional area to consider is responding to patient requests for information surrounding PHI access. Current proposed Federal legislation would require that healthcare providers and their affiliates respond to requests for information with a detailed accounting of all access to a patient’s PHI going back three years. Many forward looking institutions are seeking a way to respond to this new proposed requirement as well as state disclosure laws governing PHI. Many Enterprise Fraud Management systems are designed to handle these information requests at the press of a button and can capture the history of information access across multiple systems. Having these systems in place can mean countless saved hours in responding to these requests.

In Conclusion:

Leading healthcare institutions seeking to get more out of their audit and compliance efforts should be exploring next generation solutions and not relying exclusively on incomplete or inadequate logs.

Enterprise fraud and workplace policy abuse come in many forms, and every business is at risk.

 Unfortunately, it’s not always obvious when workplace fraud occurs. Perpetrators are often insiders – long-time employees or trusted staff members who have access to sensitive information.

 The very idea that these people would cheat you can be hard to accept. It may even be tempting to think, “It could never happen here.” But it could. And the less you do to prevent it, the more likely it is to occur.

 Workplace fraud could mean failed compliance audits, hefty fines, or irreparable damage to your brand. It could also mean a serious blow to your bottom line.

 So don’t let others profit unethically at your expense – take steps to stop them. Here are four common types of workplace fraud and some suggestions for avoiding an all-out fraud nightmare.

1. Accounting mischief

 If your accounts are vulnerable, employees can use them to their advantage. Think “skimming” small amounts of money from the tops of checks or taking unreported cash payments.

 When the amounts are small, this type of fraud can be hard to detect. And if you never perform any audits, it could be virtually untraceable. While internal audits are an option, they’re often difficult to conduct. Slinging together data in an attempt to create a complete audit trail can quickly become a nightmare.

 On the other hand, by bringing in external auditors, you’ll be able to keep your accounts in check. Make external audits routine, and you can prevent accounting fraud before it even starts.

2. Exchanged credentials

 Or falsified ones. With counterfeit documents, records, or licenses, scammers may seek employment at your organization. They may also use someone else’s credentials to gain access to your office or work facility.

 Don’t forget: In hiring, even one fake reference represents a serious case of fraud.

 Always call professional references, verify credentials, and conduct background checks of each new hire. After all, you should be confident in the employees who represent your organization, not suspicious of them.

3. Unauthorized data access

 The use of false credentials can also help employees access data that was never theirs to consume.

 When this happens, the privacy of your patients or customers – not to mention confidential business information – could be in jeopardy. And what if employees don’t even need to use false credentials? What if they’re accessing sensitive information because it’s already easy to do so without being caught?

 That’s why you must implement data-handling policies that specify who has access to what. Also establish a system for verification before anyone can access sensitive material. Things like passwords and account numbers should never be shared and, if possible, should be changed often.

4. The address swap

 This is what happens when an employee changes the address to which a check is sent – presumably to his or her own – and then changes it back.

 To combat this kind of fraud, conduct regular reviews of all purchases. Consistent audits of accounts and contracts will also help protect you. While you don’t want to create a culture of surveillance that makes employees feel like Big Brother is lurking behind every corner, audits and reviews should create an atmosphere of accountability.

 Because when employees are accountable for their actions, you’ll enjoy greater security.

 For more information about Enterprise Fraud Management, be sure to check back here on Insider Fraud Spotlight!

Recently, on the heels of the ISSA International Conference, noted authority Michael Angelo raised the question of ethics in security. It is a topic that comes up from time to time and never ceases to fascinate me. In his recent blog posting, Michael writes “Ethics is a particularly interesting topic as the security industry is always concerned about addressing issues in a constantly changing environment. It is easy to follow a set of ethics if the environment is consistent, however if the environment changes will those ethics still apply or do they need to evolve?”

Over the years, we’ve seen huge shifts in the issue of ethics and security. The spectrum of recent dialog ranges from securing end points and the interests of enterprise all the way to hacktivism. The core tenants of privacy, security and personal responsibility are all represented in the current debate. I was heartened to see the diversity of opinion expressed by our community. It shows that we are examining critical issues, considering the implications of choice and the why of new technologies rather than mindlessly favoring the technical possibilities

Michael concludes his article by stating, “In the 70’s corporate and professional ethics demanded secrecy around all aspects of security. The corporate and professional ethics from the 70’s have gradually evolved to enable us to disclose information and work together on solutions so that we can not only survive but we can innovate and surpass our individual boundaries. In the end it is important to remember that while our environments are evolving we must re-examine our ethics and see if they also need to evolve.” I, for one, whole heartedly agree.

Here are some other positions on the issues of ethics in security:

ISACA: Auditors Ethics for Continuous Monitoring and Continuous Auditing: http://www.isaca.org/Journal/Past-Issues/2008/Volume-3/Pages/Auditor-Ethics-for-Continuous-Auditing-and-Continuous-Monitoring1.aspx

SANS: The Legal System and Ethics in Information Security: http://www.sans.org/reading_room/whitepapers/legal/legal-system-ethics-information-security_54

Dell SecureWorks: Crossing the Line: Ethics for the Security

http://www.secureworks.com/research/articles/other articles/ethics/