Saturday, April 13, 2024

An Effective Information Governance System Should Include All Except

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Like other businesses, aging services providers generate large amounts of data. These data files change throughout the workday.

Data can be lost, corrupted, compromised or stolen through hardware failure, human error, hacking and malware. Loss or corruption of data could result in significant business disruption.

TechTarget Editor Anne Steciw13 advises entities covered by the Health Insurance Portability and Accountability Act of 1996 to have a contingency plan in place.

This plan must ensure that the entity:

  • Will have continued access to electronic protected health information in the event of a system failure.
  • Has an ePHI data backup plan, a disaster recovery plan, and an emergency mode operation plan.
  • Has a plan for moving sensitive health care data without violating HIPAA privacy and security requirements.

Steciw suggests that organizations follow these steps to meet HIPPA requirements:

  • Examine different data replication strategies available to determine which best suits your organization.
  • 6.4.1. Data Backup

    Ready, a national public service campaign to educate and empower Americans to prepare for and respond to emergencies, has developed a helpful guide to data backup and recovery, which it suggest should be an integral part of an organizations business continuity plan and information technology disaster recovery plan.14

    According to Ready, developing a data backup strategy involves: Developing the Data Backup Plan

    6.4.2. Disaster Recovery Plan

    Other Administrative Options To Protect Privacy And Confidentiality

    risks may be exacerbated for HDOs that have large numbers of remote on-line terminals. HDOs will need to implement comprehensive, state-of-the-art administrative, personnel, physical, and technological security safeguards of special interest are employment agreements and security systems design. Whatever confidentiality policies HDOs adopt or are imposed by law, HDOs must be able to implement them and assure their effectiveness.

    Employee agreements would, at a minimum, require employees to observe guidelines related to hard-copy reports, diskettes, and downloaded data and would instruct them about the dangers of altering, destroying, or revealing data and the penalties attached to infractions. For employees such steps include: requesting only reports needed for a given job notifying a security administrator of changes in duties safeguarding confidential materials sharing information only with authorized users using only approved user codes and passwords when requesting system access not sharing such codes and passwords with anyone, employee or not disposing of reports and materials in a secure manner logging off and securing equipment when leaving a terminal and reporting data and system misuse.

    How To Develop A Data Governance Policy

    Beyond the business representatives on the data governance committee, the policy-making process should include legal, compliance and risk management executives, plus IT and security leaders and the chief data officer — or, if an organization doesn’t have a CDO, the executive charged with overseeing enterprise data.

    They should help determine who is responsible for different data assets, the business risks associated with those assets and what regulatory requirements apply to the organization’s data, as well as what the requirements entail for compliance efforts. Once those assessments are done, the data governance committee should use the information in developing the data governance policy’s rules and procedures.

    The following are some specific steps typically taken by data governance proponents and then the committee and members of a data governance team as part of creating a governance policy:

  • Create an inventory of data assets, and do an assessment of data usage, data quality and existing data management practices to identify issues that a governance program could address.
  • Use that information to develop a business case for data governance to get executive support and funding for the program.
  • Name a data governance manager, and create a governance team to support the program.
  • Form the data governance committee, which should include top executives or other representatives from all departments and business units.
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    Principle : Communicate Extensively

    Extensive communication from the project team is critical for a successful information management initiative. This communication ensures that staff have a clear understanding of the project, and the benefits it will deliver. This is a pre-requisite for achieving the required level of adoption.

    With many projects happening simultaneously , coordination becomes paramount. All project teams should devote time to work closely with each other, to ensure that activities and outcomes are aligned.

    In a complex environment, it is not possible to enforce a strict command-and-control approach to management . Instead, a clear end point must be created for the information management project, and communicated widely. This allows each project team to align themselves to the eventual goal, and to make informed decisions about the best approaches.

    For all these reasons, the first step in an information management project should be to develop a clear communications message. This should then be supported by a communications plan that describes target audiences, and methods of communication.

    Project teams should also consider establishing a project site on the intranet as the outset, to provide a location for planning documents, news releases, and other updates.

    Increasingly Many Organisations Are Focusing On The Business Agility And Profitability Benefits Of An Effective Information Governance Programme By Clearly Understanding The Value Of The Information You Have And Setting In Place The Processes And Procedures To Securely Access It When And Where Required An Organisation Can Unlock The Potential Of Their Information In Areas Such As Business Analytics And Collaboration


    Here is our list of key benefits:

    Information Governance turns that data into business information by setting the policies and procedures to ensure that there are as few instances of that information as possible, that it is securely accessible to the people who need it and it is removed from the organisation as quickly as possible to meet regulatory compliance.

    Information Governance enables fast and thorough e-Discovery by allowing only appropriate information to be easily identified and accessed. What could take a team of lawyers many months to complete can be accomplished with a fraction of the manpower and costs.

    As the regulatory environment changes and grows, gathering data for an audit can be achieved simply and efficiently. Record retention can be automatically built into the process, as can effective information security procedures to minimise business risk.

    Information Governance outlines at a strategic level how that information will be made available to business users. It sets out how unstructured information from both inside and outside the company can be combined with the structured data held in corporate databases to drive business agility.

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    Principles Of Corporate Governance

    More from: Business Roundtable

    The following post is based on a Business Roundtable publication.

    Business Roundtable has been recognized for decades as an authoritative voice on matters affecting American business corporations and meaningful and effective corporate governance practices.

    Since Business Roundtable last updated Principles of Corporate Governance in 2012, U.S. public companies have continued to adapt and refine their governance practices within the framework of evolving laws and stock exchange rules. Business Roundtable CEOs continue to believe that the United States has the best corporate governance, financial reporting and securities markets systems in the world. These systems work because they give public companies not only a framework of laws and regulations that establish minimum requirements but also the flexibility to implement customized practices that suit the companies needs and to modify those practices in light of changing conditions and standards.

    We believe that this concept of shareholder responsibility and accountability willand shouldbecome an integral part of modern thinking relating to corporate governance in the coming years, and we look forward to taking a leadership role in discussions relating to these important issues.

    Data Governance Policy Templates

    Many organizations have posted their data governance policies online. Most of them are government agencies or academic institutions, but their policies may be able to serve as models for a governance policy in a business. Templates for creating a data governance framework that are available from educational and professional organizations, such as the Data Governance Institute and DAMA International, may also be able to help guide policy development. Some data governance software vendors also offer templates and methodologies for creating a governance framework.

    Although such templates can help organizations plan their approach to creating a data governance policy, some consultants have cautioned against relying on them — at least exclusively — because a strong, well-crafted governance policy must meet the individual needs of each organization.

    Continue Reading About data governance policy

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    Covert Acquisition And Use Of Data For Illegal Or Unethical Purposes

    Another problem involving acquisition and use of medical information occurs covertly through illegal or unethical means. Examples include information brokers who tap into computerized systems by using false names or by bribing database employees to supply information about celebrities or the names of individuals with certain characteristics. In health care institutions, there is also a risk that employees will browse through medical records out of curiosity .

    The character of the threat to confidentiality posed by the aggregation of databases is altered. Celebrities have long been vulnerable to loss of privacy through both paper and computerized searches as documented by Rothfeder . The new vulnerability posed by computerized searches is to those who until now have been anonymous. That is, information brokers seek to identify information not about an identified individual but about the identities of individuals with given characteristics .

    Although harm from this source is likely to occur rarely in comparison with others, the harm can be great because so many individuals are affected. Further, the data holder can be severely damaged in the public’s eye. One goal for an HDO must be to assure the public of reasonable, if not absolute, safety.

    Why Information Security Governance Is Needed

    Algorand Community Governance All Hands: Instructions for Would-Be Governors

    Why is IT governance important

    • Financial payoffs

    Benefits of information security governance

    • Increased predictability and reduced uncertainty of business operations
    • Protection from the potential for civil and legal liability
    • Structure to optimize the allocation of resources
    • Assurance of security policy compliance
    • Foundation for effective risk management.
    • A level of assurance that critical decisions are not based on faulty information
    • Accountability for safeguarding information

    Question to engage institutional leaders

    Thought provoking questions that institutional leaders can ask to determine the state of their security governance efforts.

    • Questions to uncover information security issues
    • Does the head of security/CISO routinely meet or brief institutional leaders?
    • When was the last time top managers got involved in security-related decisions?
    • Do managers know who is responsible for security?
    • Would people recognize a security incident? Would they know who to call?
  • Questions to find out how managers addresses information security issues
  • Is the institution clear on its position relative to IT and security risks?
  • How much is spent on information security?
  • What percentage of staff had security training last year?
  • Questions to assess information security governance practices
  • Are managers confident that security is being adequately addressed in the enterprise?
  • Are managers aware of the latest information security issues and best practices?
  • Questions for managers
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    Relevance Of Existing Laws To Hdos

    The committee examined existing law-constitutional, statutory, and common law-for its relevance to HDOs and its adequacy for protecting patient privacy. The committee also examined the way these laws might affect the design, establishment, and operation of HDOs.

    It concludes that most of this body of law is unlikely to apply to HDOs. With the exception of laws regulating information considered sensitive, existing laws regulate recordkeepers and their recordkeeping practices they do not regulate on the basis of either the content or the subject matter of a record. Current law thus seeks to regulate the information behavior of health care providers, government recordkeepers, insurers, consumer reporting agencies, quality assurance organizations, and researchers. For this reason, it is important to understand how HDOs are likely to be viewed by the legal system-that is, in what legal context their recordkeeping will be seen.

    What Is Information Security Governance And What It Is Not

    IT security governance is the system by which an organization directs and controls IT security . IT security governance should not be confused with IT security management. IT security management is concerned with making decisions to mitigate risks governance determines who is authorized to make decisions. Governance specifies the accountability framework and provides oversight to ensure that risks are adequately mitigated, while management ensures that controls are implemented to mitigate risks. Management recommends security strategies. Governance ensures that security strategies are aligned with business objectives and consistent with regulations.

    NIST describes IT governance as the process of establishing and maintaining a framework to provide assurance that information security strategies are aligned with and support business objectives, are consistent with applicable laws and regulations through adherence to policies and internal controls, and provide assignment of responsibility, all in an effort to manage risk.

    Enterprise security governance results from the duty of care owed by leadership towards fiduciary requirements. This position is based on judicial rationale and reasonable standards of care . The five general governance areas are:

  • Govern the operations of the organization and protect its critical assets
  • Protect the organization’s market share and stock price
  • Govern the conduct of employees
  • Protect the reputation of the organization
  • Staff are aware and trained
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    Hdos As Governmental Entities: General Confidentiality Protections In Public Law

    The governmental or private status of an entity that maintains or uses personal record information is particularly significant for recordkeeping. Constitutional principles, legislative charter, statutory law, and regulations must be considered separately.

    Constitutional Law

    If an entity has a governmental status, whether federal or state, constitutional privacy standards apply to the entity’s handling of personal information. As noted earlier, various provisions of the U.S. Bill of Rights are aimed at protecting citizens from governmental abuse, and privacy rights are derived from limited case law . For federal or state constitutional protections to apply, an HDO would have to be operated by a governmental entity or pursuant to a governmental charter.

    Legislative Charter

    Even if HDOs are not operated by federal governmental entities, constitutional information privacy standards can affect their operations in two ways. First, HDOs may well operate under a state legislative charter. If that charter were to require the submission of personally identifiable medical record information , this statutory requirement provides a basis for a challenge on constitutional privacy grounds, just as did the reporting requirements in Whalen.

    Freedom of Information Acts

    Fair Information Practices

    The Act of 1974 incorporated the five elements of the Code of Fair Information Practices as eight principles that are manifest as specific requirements :

    Confidentiality Of Research Uses Of Hdo Databases


    Through expenditures for medical research, the government and private sector indirectly contribute to third-party intrusions. Although epidemiological research was originally concerned with the causes and prevention of infectious diseases and focused chiefly on populations, such research has expanded to include chronic, noninfectious diseases with low rates of occurrence . Progression of such ailments may be slow, and because their causes are frequently insidious, their study often requires medical surveillance of a substantial population at widely disparate times.

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    Principle : Mitigate Risks

    Due to the inherent complexity of the environment within organisations , there are many risks in implementing information management solutions. These risks include:

    • selecting an inappropriate technology solution
    • time and budget overruns
    • technical issues, particularly relating to integrating systems
    • failure to gain adoption by staff

    At the outset of planning an information management strategy, the risks should be clearly identified. An approach must then be identified for each risk, either avoiding or mitigating the risk. Risk management approaches should then be used to plan all aspects of the project, including the activities conducted and the budget spent.

    For example, a simple but effective way of mitigating risks is to spend less money. This might involve conducting pilot projects to identifying issues and potential solutions, rather than starting with enterprise-wide deployments.

    Ahima’s 8 Principles Of Information Governance

    To help healthcare organizations better manage their information as a strategic asset, the American Health Information Management Association has released new guidelines on information governance.

    The guidelines outline eight principles by which a healthcare organization’s information should be managed:

  • Principle of accountability: One member of the organization’s leadership will be responsible for information governance.
  • Principle of transparency: Information governance will be conducted in an open, verifiable manner.
  • Principle of integrity: Information management will maintain the reliability of the data.
  • Principle of protection: All information will be kept secure.
  • Principle of compliance: The information governance program will follow all applicable laws, standards or policies.
  • Principle of availability: The information governance strategy will ensure data is accessible to stakeholders.
  • Principle of retention: Information will be stored as long as necessary based on legal, financial, operational or other requirements.
  • Principle of disposition: Any information the organization no longer needs will be disposed of in a safe and legal manner.
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    International Networks Enabling Exchange

    Beyond the examples outlined above, various exchange networks and infrastructure have been established globally.

    Uses of Information Exchange

    Watch the HIMSS TV deep-dive on interoperability.

    Ultimately, the goal is to be able to share and access information that informs an individuals full, longitudinal health story. By having and understanding the complete and accurate picture of an individuals healthincluding their preferences and other determinants of healthincludes a number of benefits. Clinicians can better inform care and decision making, patients can become active participants in their care plans, and health IT developers and implementers can leverage evidence to create and adopt systems that support clinical processes and improve care delivery.

    A number of benefits can be realized for exchange stakeholders, including:

  • Care coordination: Care coordination often involves a variety of stakeholders, including patients, caregivers and care teams across settings in the management of a patients health. This is a dynamic process that requires data movement across platforms and among service providers in real time to successfully manage care.
  • Improving business and administrative processes: Having access to health information can eliminate time-consuming tasks within a health system, including processing of intake information, coordination across care teams and reporting needs associated with various regulatory requirements.
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