dilbert Data Security

3 things a medical device vendor must do for security incident response

You are VP R&D or CEO or regulatory and compliance officer at a medical device company.

Your medical devices measure something (blood sugar, urine analysis, facial anomalies, you name it…). The medical device interfaces to a mobile app that provides a User Interface and transfers patient data to a cloud application using RESTful services over HTTPS.

Sound familiar?

The Medical device-Mobile app-Cloud storage triad is a common architecture today for many diagnostic, personal well-being and remote patient monitoring indications.

We have numerous clients with the Medical device-Mobile app-Cloud storage system architecture and we help them address 4 key security issue –

  1. How to ensure that personal data and user authentication data is not stolen from the mobile medical app,
  2. How to ensure that the mobile medical app is not used as an attack pivot to attack other medical device users and cloud servers,
  3. How to comply with the HIPAA Security Rule and ensure that health data transferred to the cloud is not breached by attackers who are more than interested in trafficking in your users’ personal health data,
  4. How to execute effective security incident response and remediation – its a HIPAA standard but above all – a basic tenet for information security management.

How effective is your security incident response?

The recent SANS Survey on Security Incident Response covers the challenges faced by incident response teams today—the types of attacks they detect, what security countermeasures they’ve deployed, and their perceived effectiveness and obstacles to incident handling.

Perceived effectiveness is a good way of putting it – because the SANS Survey on Security Incident Response report has some weaknesses.

First – the survey that is dominated by large companies: over 50% of the respondents work for companies with more than 5,000 employees and fully 26% work for companies with more than 20,000 employees.    Small companies with less than 100 employees – which cover almost all medical device companies are underrepresented in the data.

Second – the SANS survey attempts, unsuccessfully, to reconcile reports by the companies they interviewed that they respond and remediate  incidents within 24 hours(!) with reports by the PCI (Payment Card Industry) DSS (Data security standard) Association that retail merchants take over 6 months to respond.       This gap is difficult to understand – although it suggests considerable variance in the way companies define incident response and perhaps a good deal of wishful thinking, back-patting and CYA.

Since most medical device companies have less than 100 employees – it is unclear if the SANS findings (which are skewed to large IT security and compliance organizations) are in fact relevant at all to a medical device industry that is moving rapidly to the medical device-App-Cloud paradigm.

3 things a medical device vendor must have for effective incident response

  1. Establish an IRT.  (Contact us and we will be happy to help you set up an IRT and train them on effective procedure and tools).  Make sure that the IRT trains and conducts simulations every 3-6 months and above all make sure that someone is home to answer the call when it comes.
  2. Lead from the front. Ensure that the head of IRT reports to the CEO.   In security incident response, management needs to up front and not lead from behind.
  3. Detect in real time. Our key concern is cloud server security.    Our recommendation is to install OSSEC on your cloud servers. OSSEC sends alerts to a central server where analysis and notification can occur even if the medical device cloud server goes down or is compromised.
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