COIT20263 - Privacy and Security Policy for Health Information

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This report assesses the privacy and security of personal health information at NTN, an Australian nursing school. It addresses the need for robust information and network security, focusing on security policies like the Security Systems Development Lifecycle (SecSDLC) and the Personal Health Information Protection Act (PHIPA). The report emphasizes the importance of protecting patient data, maintaining confidentiality, and complying with relevant legislation to ensure the quality and reliability of NTN's health and telemedicine services. It also highlights the role of the Chief Information Security Officer (CISO) in implementing effective security measures and safeguarding patient trust through data protection.
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COIT20263 INFORMATION SECURITY
MANAGEMENT (HT2, 2018)

Assessment Item 1 – Written Assessment

Topic:
‘Privacy and Security of Personal Health Information Policy’
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1. Executive Summary
This report focuses on the protection of information regarding the personal health. The security

and privacy aspects are the major concern that has been covered in this report. There is the great

significance of the security policies that contribute to the enhancement of integrity and reliability

of the information. The security of the personal data and preventing its leakage is important for

achieving sustainability in the business environment. NTN that is an Australian nursing school

has appointed a staff for their school which provides training and internship to the students. The

Chief Information Security Officer (CISO) who leads the Information Security Division has

initiated a program for attaining information security. This report focused on ensuring the

security of the patient's health report by launching a security program. This assessment covers

the requirements of security as well as the privacy of the information and network in NTN and

support in enhancing learning related to security procedures that will be implemented for

attaining the purpose of this report. The Security system development lifecycle and Personal

Health Information Protection Act is also discussed in this report.

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Table of Contents
1.
Executive Summary.................................................................................................................2
2.
Introduction..............................................................................................................................4
3.
Discussion (Guidelines)...........................................................................................................5
3.1
About NTN....................................................................................................................... 6
3.2
Services offered by NTN.................................................................................................. 7
3.3
Need for information and network security......................................................................8
3.4 Information Security Policies
................................................................................................9
3.4.1 Security Systems Development Lifecycle (SecSDLC)
................................................10
3.4.2 Personal Health Information Protection Act (PHIPA)
.................................................11
4.
Conclusion............................................................................................................................. 15
5.
References..............................................................................................................................16
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2. Introduction
Personal health information contains the health records comprised of personal data of the

patients. This data includes name of the patients, history of his health and information related to

their health issues, their consultant doctor and so on. The security of the patient’s health

information is a major concern, the privacy and integrity of his data need to be ensured. This

report has covered a case study of the NTN, Australia which is a private nursing school there.

The health services provided by the NTN are in within the range of 200KM. The appropriate

protection of health information and implementation of legislation will be studied in this report.

The health and telemedicine service provided by the NTN to the society and the quality of those

services depends upon the data confidentiality and its protection as trust of the patient is build up

with the effective implementation of the security guidelines (
Spiekermann, 2012).
The objective of this report is to assess the security and privacy aspects of the personal health

data in the NTN School of nursing. The purpose is to attain the information and network security

through effective implementation of security policies. The communication and interaction

between the hospitals should also be kept secret. Therefore, the information and network security

are the major aspects discussed in this report for advancing the service quality of NTN by

following the security policies.

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3. Discussion (Guidelines)
Identification of the information about a person either in recorded or oral form is termed as

Personal health information. Globally it is a major issue to ensure the secrecy and integrity of the

personal health data. There are national security systems, social credit systems utilized for the

protection of data. There is the requirement of implementation of security guidelines and privacy

laws, security and confidentiality framework in order to ensure the protection of personal

identifiable data of the patients. The effectiveness in collection and processing of data supports

in ensuring the protection of data. The protection of information from loss and theft is important

in order to achieve data confidentiality and secrecy. There are security policies that support in

attaining the right extent of security as well as privacy of personal health information (
Rhodes-
Ousley, 2013)
.
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3.1 About NTN
A well-known private nursing school in Sydney, Australia that has its satellite sites situated in

Cairns and Darwin. Its services include giving training, internship and education to the nursing

school students. The connection is via the internet between the hospitals, main campus and other

sites of NTN. Using the concept of virtual reality, classroom studies are provided to the students

at other sites through the live-videos. It is a growing institution which is expecting more of the

people/students to join with them in the coming period (
Li and Slee, 2014).
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3.2 Services offered by NTN
The services that NTN provides are related to health-wellness and telemedicine. For providing

those services, it is having a team of nursing students as well as professional doctors. It is a

mobile team that moves from one place to another in the range of 200km for offering

consultations and other health services to the needy people. There is requirement of security and

privacy in enhancing their service quality. They use home-care vehicles through which they

interact with staff of the hospitals via network. They share the reports of the patients and the

protection of that information is an authority of the mobile teams as well as medical staff in

hospitals. In order to attain this, vulnerabilities related to network and information security

aspects should be evaluated and prevented. The threats to the systems should be detected earlier

in order to handle them in a more efficient manner (
Cheng and Lai, 2012).
For this purpose, NTN has decided to instigate and start a program that is in regard to the

information security. The staffs need to be employed who could take care of privacy and security

of personal health data of the NTN.

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3.3 Need for information and network security
The requirements for security and privacy have been realized by the NTN. The Chief

Information Security Officer (CISO) who handles the division of Information Security (IS) has

selected more staffs members in order to ensure the secure data transmission.

The information of the patients is in the report sent by the mobile teams to the staff members of

hospital. It is a responsibility of staff to keep the information secret and takes care of the

confidentiality of data.

Security is completely referred to the protection as it is needed to protect the privacy of health-

related data. The security of the electronic personal health record is a concern that requires the

regulatory strategies specific to the protection of that information (
Spiekermann, 2012).
The flexibility in implementing security policies, technology adoption and effective access

control measures help in ensuring the security of the personal data of the patients. The

communication made among the team members, staffs, patients all should be made reliable

where the leakage of information couldn’t be possible (
King and Raja, 2012).
The decisions related to data sharing should be made appropriately with an intention to achieve

privacy of the data. The information on the personal health of patients should not be disclosed

with their authorization. Their authorization should be required for accessing the data related to

their treatment, payment and other confidential data. Important decision should be taken by the

Chief Information Security Officer (CISO) in order to protect the information privacy of the

patient’s personal health records.

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3.4 Information Security Policies
These policies are the high-level standards which cover efficient security controls. The NTN

should issue a policy related to primacy information security that can ensure that all the staff

members and team members of NTN would take care of the accountability of patient's personal

data. They would comply with the guidelines and follow the security policies in order to assure

general privacy and security aspects in the services provided by them.

It is needed to preserve trust that could be attained through ensuring the confidentiality of data. It

is fundamental act and there are different policies in relation with that which should be

implemented by NTN (
Li, et. al., 2013).
Employing staffs for information security division actually helped in effective supervision and

monitoring in order to prevent data leakage and assure authorized access to that personal health

information of the individuals.

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3.4.1 Security Systems Development Lifecycle (SecSDLC)
SecSDLC support in analysing the existing security procedures. A preliminary analysis is

performed with the help of related controls and known risks. Legal issues should be analysed that

might influence the security system of NTN. Further risks involved in the development of

security system are managed effectively. It supports in testing and implementing the security

solutions of NTN that assure their effectiveness and help in achieving the desired privacy as well

as security aspects (
Fernández-Alemán, et. al., 2013).
Figure 1: SecSDLC Waterfall Methodology

(Source:
Communications of the ACM, 2012)
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3.4.2 Personal Health Information Protection Act (PHIPA)
It is to be said that while gathering, processing and using the individual’s information, the rules

of Medicine act, 1991 and Personal Health Information Protection Act (PHIPA) 2004 should be

followed.

The 4
th section of PHIPA states that;
The information that needs to be secure could be related to an individual's health, person

identification, payments or other and identifying this kind of data hampers the data security and

privacy. The rule is to protect that information through preventing controlling the disclosure of

information.

Disclosure of individual’s health information

The disclosure should only take place when there is the consent of either the patient or their

decision-maker or the rules are not violating in presenting the data. If it is needed by the law, it

should be disclosed.

PHIPA permits to disclose the data even without patient’s consent in some circumstances that are
provided below:

If it is for the healthcare prerequisites at the time of emergency or unexpected situations
In order to standardize the medical profession for performing the regulatory responsibilities then
the information could be disclosed.

It can be disclosed to a family person or friend.
With the adoption of technologies, the risk related to the data sharing is increased. The data

transmitted over the internet is not safe due to intervention by the intruders or hackers. The data

leakage hampers the confidentiality of the information. The use of a wireless connection network

has arisen several data breaches issues, unauthorized access to the systems, misuse of the

internet, erased health records are some of the major concern related with security and privacy.

The NTN College offers advancement in the use of technology with the intention to appropriate

safety and data security.

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There are certain principles of PHIPA that are mentioned below:
Principle 1: Accountability

NTN is responsible and liable for personal information and they have members in their

Information security division who are accountable for the college's conformity with privacy

guidelines. The team members, staffs of the hospital should take account of the protection of

personal information. They should implement laws to protect the data and should provide

training that guides about privacy strategies and procedures.

Principle 2: Identifying the cause of gathering personal health information (PHI)

At the time of collection of personal data, the essential role is to identify the reason that why the

information is being collected. The purpose identification is important in order to know the

reason behind accessing the data. The authorized persons have the genuine reason that supports

in detecting the fake one.

Principle 3: Permission for the gathering, utilisation and disclosure of data

It is required to keep the individual aware that their information is being used, processed or

disclosed due to whatever the reason is. This principle needs ‘consent’ and ‘knowledge’ in order

to let the person reasonably understood the cause of accessing their personal data. NTN should

issue rule which is related to the release of personal data to another person that includes the need

for their consent.

Principle 4: Restricting the collection of personal information

The data collected should be limited as per the requirements which need to be fulfilled. This

principle involves the permission in relation to the personal data collection that must not have

included any fraud or cheating.

Principle 5: Limiting the usage, disclosure and retention of data

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The information should only be used or disclosed only for fulfilling the purpose for which it is
required to disclosed or it could be accessed with there is the consent of patient to access their

personal health information (
Al Ameen, et. al., 2012).
Principle 6: Ensuring privacy of PHI

The accuracy and privacy of PHI should be ensured. NTN will regularly update PI with intention

to accomplish the target for the personal data is gathered. The information collected should be

accurate, up-to-date without any intervention of its integrity and privacy.

Principle 7: Ensuring safeguard for PI

There are organizational measure, security measures and physical measures which are the

essential methods for the protection of personal information that help in ensuring safeguard

(
Wilkowska and Ziefle, 2012).
Principle 8: Openness related to PI strategies, policies and guidelines

The procedures and practices in relation to the management of personal health data should have

openness. The information should be provided in an easy and understandable form.

Principle 9: Individual access to their information

An individual should be able to challenge the integrity and security of the personal data and then

appropriate amendment will be required. The NTN should make the required changes and ensure

the completeness of the personal information of the patients.

Principle 10: Challenging compliance with the security policies

Addressing a challenge related to conformity with the all mentioned principles are involved in

this one. NTN should process feedbacks related to their security strategies and implements the

same. This procedure of complaint should be very simple and easily approachable to the people

(
Abdelhak, et. al., 2014).
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4. Conclusion
It has been concluded with this report that security policies and guidelines cover the integrity and

reliability aspects of the personal information of the patients. The appropriate protection and

security of electronic data related to personal health need to have restricted access. This report

had covered the features related to security and privacy concerns of the personal health data and

provided security policies with an intention to attain data confidentiality. The security measures

had been taken in order to restrict unauthorized access to information. The data security policy is

implemented and a regular technical as well as non-technical assessment regarding the

implementation of standards is performed with the intention to understand the influence of

business functionalities and variations in the environment on the security of digital health

records. The vulnerabilities associated with the data integrity and security is well assessed and

steps have been taken for preventing the privacy risks to the personal data of the patients.

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5. References
Abdelhak, M., Grostick, S. and Hanken, M.A., 2014.
Health Information-E-Book: Management
of a Strategic Resource
. Elsevier Health Sciences.
Al Ameen, M., Liu, J. and Kwak, K., 2012. Security and privacy issues in wireless sensor

networks for healthcare applications.
Journal of medical systems, 36(1), pp.93-101.
Cheng, F.C. and Lai, W.H., 2012. The impact of cloud computing technology on legal

infrastructure within internet—focusing on the protection of information privacy.
Procedia
Engineering
, 29, pp.241-251.
Fernández-Alemán, J.L., Señor, I.C., Lozoya, P.Á.O. and Toval, A., 2013. Security and privacy

in electronic health records: A systematic literature review.
Journal of biomedical
informatics
, 46(3), pp.541-562.
King, N.J. and Raja, V.T., 2012. Protecting the privacy and security of sensitive customer data in

the cloud.
Computer Law & Security Review, 28(3), pp.308-319.
Li, M., Yu, S., Zheng, Y., Ren, K. and Lou, W., 2013. Scalable and secure sharing of personal

health records in cloud computing using attribute-based encryption.
IEEE transactions on
parallel and distributed systems
, 24(1), pp.131-143.
Li, T. and Slee, T., 2014. The effects of information privacy concerns on digitizing personal

health records.
Journal of the Association for Information Science and Technology, 65(8),
pp.1541-1554.

Rhodes-Ousley, M., 2013.
Information security: the complete reference. McGraw Hill
Education.

Spiekermann, S., 2012. The challenges of privacy by design.
Communications of the
ACM
, 55(7), pp.38-40.
Wilkowska, W. and Ziefle, M., 2012. Privacy and data security in E-health: Requirements from

the user’s perspective.
Health informatics journal, 18(3), pp.191-201.
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