I agree that de-identification is always preferrable if possible. The
"minimum necessary" principle. However, this puts some burdens on the
client to prepare a suitable dataset. Do they know how to do it
properly? I have not infrequently seen something like, "Oh, we omitted
the addresses; we just used the zip codes," which doesn't cut it with
HIPAA regs. (Besides which, outside of dense urban areas, zip codes are
mostly an administrative convenience with little sociodemographic value
in an analysis.)
So de-identification itself can be a statistical job. Have you been in
the position of helping the client to prepare the de-identified dataset
in the first place, to enable it to be taken off-site for analysis?
Perhaps that's a tenable middle ground.
Thanks.
--Chris Ryan
Timothy Kenney via American Statistical Association wrote:
> I have been working with PHI for decades from my consulting business and
> have observed significant increases in security requirements from
> both... -posted to the "Statistical Consulting Section" community
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> Apr 13, 2023 1:19 PM
> Timothy Kenney
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> I have been working with PHI for decades from my consulting business and
> have observed significant increases in security requirements from both
> the client and their sources. If you can bring the data in-house, I
> recommend requesting de-identified records that still suit the
> analytical requirements of your client. Otherwise, I agree with Chris
> Barker's suggestion, let your client handle security requirements on
> their platform which you can use for the required analysis.??
>
>
>
> ------------------------------
> Timothy Kenney
> Kenney IS Consulting, Inc.
> ------------------------------
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> -------------------------------------------
> Original Message:
> Sent: 04-12-2023 09:05
> From: Christopher Ryan
> Subject: solo statistical consultatnts and PHI
>
> In my "conventional" employment, I work with a lot of protected health
> information (PHI). The computers I work with it on are part of various
> organizational IT systems, with the attendant firewalls, malware
> protection, etc. These are, of course, of variable effectiveness--we all
> read the news about data breaches and system intrusions in many places.
>
> I take data privacy and digital security very seriously. Even behind
> those organizational defenses, I tend to use hardware-encrypted thumb
> drives (when one is necessary), whole-disk encryption where possible,
> public-key encryption, etc. Even have an air-gapped computer in one office.
>
> If things go to plan, I'll potentially be working with PHI in my solo
> consulting business--on my own computer, probably from home. How have
> other solo consultants handled this????? Again, I try to be serious about
> this. I run Linux at home with whole-disc encryption, have a VPN, and
> measures similar to the above. The difference is that there is no
> "corporate" IT department to take the hit if things go awry.
>
> And what is your approach to Business Associate Agreements" vis-a-vis HIPAA?
>
> I plan to get a "cyber-insurance" policy, along with typical E&O.
>
> Thanks for any insights.
>
>
>
> ------------------------------
> Christopher Ryan
> Clinical Associate Professor of Family Medicine
> SUNY Upstate Clinical Campus
> ------------------------------
>
>
>
>
> ??
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Original Message:
Sent: 4/13/2023 1:19:00 PM
From: Timothy Kenney
Subject: RE: solo statistical consultatnts and PHI
I have been working with PHI for decades from my consulting business and have observed significant increases in security requirements from both the client and their sources. If you can bring the data in-house, I recommend requesting de-identified records that still suit the analytical requirements of your client. Otherwise, I agree with Chris Barker's suggestion, let your client handle security requirements on their platform which you can use for the required analysis.
------------------------------
Timothy Kenney
Kenney IS Consulting, Inc.
------------------------------
Original Message:
Sent: 04-12-2023 09:05
From: Christopher Ryan
Subject: solo statistical consultatnts and PHI
In my "conventional" employment, I work with a lot of protected health information (PHI). The computers I work with it on are part of various organizational IT systems, with the attendant firewalls, malware protection, etc. These are, of course, of variable effectiveness--we all read the news about data breaches and system intrusions in many places.
I take data privacy and digital security very seriously. Even behind those organizational defenses, I tend to use hardware-encrypted thumb drives (when one is necessary), whole-disk encryption where possible, public-key encryption, etc. Even have an air-gapped computer in one office.
If things go to plan, I'll potentially be working with PHI in my solo consulting business--on my own computer, probably from home. How have other solo consultants handled this? Again, I try to be serious about this. I run Linux at home with whole-disc encryption, have a VPN, and measures similar to the above. The difference is that there is no "corporate" IT department to take the hit if things go awry.
And what is your approach to Business Associate Agreements" vis-a-vis HIPAA?
I plan to get a "cyber-insurance" policy, along with typical E&O.
Thanks for any insights.
------------------------------
Christopher Ryan
Clinical Associate Professor of Family Medicine
SUNY Upstate Clinical Campus
------------------------------
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