I am an independent software security consultant specializing in medical device security and HIPAA compliance in Israel. I use the state-of-the art PTA – Practical Threat Analysis tool to perform quantitative threat analysis and produce a bespoke, cost-effective security portfolio for my customers that fits their medical device technology.
There are over 700 medical device companies in Israel – all doing totally cool and innovative things from My Dario (diabetes management), to Syneron (medical esthetics), to FDNA (facial dysmorphology novel analysis at your fingertips) to Intendu (Brain Rehabilitation).
This is a great niche for me because I get to do totally cool projects and work with a lot of really smart people at Israeli medical device vendors helping them implement cost-effective security and privacy compliance + it’s fun learning all the time.
One thing I have learned is that there is very little connection between FDA medical device risk assessments and a software security risk assessments. This somewhat counter-intuitive for people who come from the QA and RA (regulatory assurance) areas.
Security is an adversarial environment very unlike FDA regulatory oversight.
FDA medical device regulatory oversight is about complying in a reliable way with standard operating procedures and software standards.
FDA believes that conformance with guidance documents, when combined with the general controls of the Act, will provide reasonable assurance of safety and effectiveness…
FDA recognizes several software consensus standards. A declaration of conformity to these standards, in part or whole, may be used to show the manufacturer has verified and validated pertinent specifications of the design controls. The consensus standards are:
- ISO/IEC 12207:1995 Information Technology – Software Life Cycle Processes
- IEEE/EIA 12207.O-1996 Industry Implementation of International Standard ISO/IEC12207:1995 (ISO/IEC 12207) Standard for Information Technology – Software Life Cycle Processes
Barry Boehm succinctly expressed the difference between Verification and validation:
Verification: Are we building the product right?
Validation: Are we building the right product?
Building the right product right is no more a guarantee of security than Apple guaranteeing you that your Mac Book Pro will not be stolen off an airport scanner.
Medical device security is about attackers and totally unpredictable behavior
Medical device security is about anticipating the weakest link in a system that can be exploited by an attacker who will do totally unpredictable things that were inconceivable last year by other hackers, let alone 20 years ago by an ISO standards body.
You cannot manage unpredictable behavior (think about a 2 year old) although you can develop the means for anticipating threats and responding quickly and in a focused way even when sleep-deprived and caffeine-enriched.
The dark side of security is often hubris and FUD.
For security consultants, there is often an overwhelming temptation to show clients how dangerous their security vulnerabilities are and use that as a lever to sell products and services. I’ve talked about hubris and FUD here and here and here and here and here. A good example of exploiting clients with security FUD are the specialty HIPAA-compliant hosting providers like Firehost that are masters of providing expensive services to clients that may or may not really need them.
However, I believe that intimidation is not necessarily a strategy guaranteed to win valuable long-term business with clients.
Instead of saying – “that is a really bad idea, and you will get hacked and destroy your reputation before your QA and RA departments get back from lunch“, it is better to take a more nuanced approach like:
“I see that you are transferring credentials in plain-text to your server in the cloud. What do you think about the implications of that?“. Getting a client to think like an attacker is better than dazzling and intimidating them which may result in the client doing nothing, hunkering down into his current systems or if the client has money – going off and spending it badly.
How did I reach this amazing (slow drum roll…) insight?
About 3 years ago I read a book called Search Inside Yourself and I learned an idea called – “Don’t take action, let action take you“. I try to apply this approach with clients as a way of helping them learn themselves and as a way of avoiding unnecessary conflict. The next step in my personal evolution was getting acquainted with a Zen Buddhist concept called Shoshin:
Shoshin (初心) means “beginner’s mind”. It refers to having an attitude of openness, eagerness, and lack of preconceptions when studying a subject, even when studying at an advanced level, just as a beginner in that subject would.
Shoshin means doing the exact OPPOSITE of what you (the high-powered, all-knowing, medical device security consultant) would normally do in the course of a security threat assessment:
- Let go of the need to add value – you do not have to provide novel security countermeasures all the time. Sometimes, doing the basics very well (like hashing and salting passwords) is all the value the client needs.
- Let go of the need to win every argument – you do not have to show the client why their RA (regulatory assurance) manager is making fatal mistakes in database encryption after she took some bad advice from Dr. Google.
- Ask the client to tell you more – ask what led them to a particular design decision. You may learn something about their system design alternatives and engineering constraints. This will help you design some neat security countermeasures for their medical device and save them some money.
- Assume you are an idiot – this is a corollary of not taking action. By assuming you are an idiot, you disable your ego for a few moments and you get into a position of accepting new information which in the end, may help you anticipate some threats and ultimately take your client out of potentially dangerous adversarial threat scenario.
Thank you to James Clear for his insightful post – Shoshin: This Zen Concept Will Help You Stop Being a Slave to Old Behaviors and Beliefs
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