BCBS of Tenn. Breach: Lessons Learned

Howard Anderson writes:

In the wake of an information breach affecting nearly 1 million people, executives at BlueCross BlueShield of Tennessee have many lessons to share and plenty of advice to offer.

On Oct. 2, 2009, someone stole 57 unencrypted hard drives from servers at a call center the insurer had recently closed. So far, there have been no arrests, nor any evidence of fraud committed, the company reports.

[…]

Among the actions the Tennessee plan has taken and the lessons it has learned are:

  • Adding a layer of physical security to protect servers is a prudent step.
  • Encryption should be applied widely, including on servers.
  • Appointing a chief security officer helps to ensure coordination of all security efforts.
  • Organizations should carefully assess how long to store information.
  • In preparing a breach notification plan, be sure to prepare a pre-selected list of vendors that can help with various tasks.
  • Train customer service representatives to deal with breach-related questions from the public.
  • Communicate frequent updates on breach investigations through the media and a Web site.

Read more on HealthInfoSecurity.com.  Interestingly, one of the lessons that I think everyone should have learned from this incident is not included in their list:  think about recording calls for quality assurance purposes and ensure you have a way to retrieve PII and PHI if need be — and securely destroy such data on a frequent and regular basis.   BCBS spent extraordinary time trying to figure out what was on the audio tapes.   Of course, if strong encryption is used, some of that might not be necessary.

Previous coverage of the BCBS Tennessee breach can be found in these earlier blog entries.

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