Sharing Cone-Beam CT Images Online

By Dr. Dan Grauer

When diagnosing and treatment planning interdisciplinary patients, have you ever sent your three-dimensional images to a colleague? Have any of your patients requested a copy of their records for a second opinion? Or maybe, a patient declines a radiograph because another orthodontist has recently taken a CBCT image of the patient? In all of these instances, you will need to communicate with the other office to initiate the transfer of CBCT images. The purpose of this blog is to describe different methods used to share patients’ CBCT records via online means.

Images acquired in your office are requested by a second orthodontist/dentist:

The first question that will need to be answered is whether the other office has the possibility of viewing and analyzing the images in three-dimensions. In a few instances, I have found myself trying to transfer a full three-dimensional file, when the second orthodontist just wanted a cephalogram and a panoramic radiograph. If this is the case, your software will probably allow you to create a synthetic cephalogram and panoramic radiograph that can be emailed through a HIPAA-compliant email account. If the second orthodontist requires a three-dimensional image, two case scenarios are possible:

Case scenario 1: Second orthodontist owns software to read and visualize CBCT images.

In this case, your software is able to export the CBCT Images in DICOM format (Digital Imaging and Communication in Medicine). DICOM files are large, and a file transfer application is needed. Once transferred, these can be imported into the software of the second orthodontist for visualization and analysis.

Case scenario 2: Second orthodontist does not own three-dimensional imaging software.

Under this case scenario, the second orthodontist would need both the CBCT images and a three-dimensional viewer. Three main options are available.

Option 1: If you own a CBCT machine, your software is generally able to create a file that includes both the image data and a basic viewer. The files created are large and can be transferred with a file transfer application.

Option 2: Anatomage offers the possibility of uploading your CBCT images to the cloud, and these can be accessed online through Anatomage’s application, which acts as a visualization tool. At this point the software is in Beta-version and can be accessed at www.anatomagcloud.com. You, as the generating office, will need to upload the images to the AnatomageCloud database and use this application to allow the second office to access the specific patient images. The access is granted with a link embedded in an email. After receiving authorization to access the images, the second office will be able to access the images online without the need of downloading them or installing any software.

Option 3: Dolphin Imaging software offers a complimentary viewer, https://www.dolphinusers.com/dolphin-imaging-viewer/. The receiving doctor can view 3D images by downloading and installing the Dolphin Imaging Viewer software. Files are transferred in DAZ file format. This file format is proprietary to Dolphin Imaging, and the files are created by the originating doctor through Dolphin Imaging 3D Software. This option 3 would work also in Case Scenario 1, when both doctors use Dolphin Imaging 3D software, but it is important to note that only the unprocessed images need to be transferred, such as the DICOM file; the viewer is part of the software downloaded by the receiving office.

Images acquired by other offices:

Images that you receive from other offices should be requested in DICOM format. This will permit you to be able to import these into your 3D software. If you obtain the file in a different format than DICOM (that often includes the viewer), the analysis and measurement possibilities are limited; this is because your 3D software most likely includes all the features that you may need while visualizing and measuring 3D Images. If both offices use Dolphin Imaging 3D Software, a proprietary format DAZ can be used to transfer and share images. The advantage of this approach is that all patient images, including both 3D and 2D images, are shared simultaneously.

In summary, with Cone Beam CT becoming more popular in practices, sharing 3D images with other treating doctors or practices requires some additional steps. The first step is to initiate the conversation with the second office to establish the best system to use to share images. The advantages of 3D images over traditional 2D images are beyond the scope of this blog, but once you become accustomed to a transfer and visualization system, the collaboration between doctors and patient care may improve.

Big Data Revisited

By Anthony M. Puntillo DDS, MSD

In August 2014, I wrote an introductory article for this blog entitled “What is Big Data and How is it Related to the Practice of Orthodontics?” As more orthodontic practices move to the digital collection of orthodontic treatment records (EHRs-photos, models, radiographs, treatment history) and more of our data is being stored in the “cloud”, there is a tremendous opportunity for us as a profession to access that data for the betterment of our patients and advancement of our specialty. Over the last ~3.5 years, however, there has been little visible traction by our researchers and leadership on this front. Meanwhile, there should be no doubt that corporate entities (DSOs and orthodontic vendors) understand the value of our data. Check out the recent cover article for Fortune Magazine (“Tech’s Next Big Wave: Big Data Meets Biology” -3/19/2018). The article notes that “The quest to retrieve, analyze, and leverage (medical) data has become the new gold rush.” If orthodontists are to hope to have any influence on how orthodontic treatment is delivered in the future, management of our patients’ data will be crucial. Technology has sped up every aspect of our lives. We must now start to give this issue the attention it desperately demands. But where should we begin?

If we are to tackle this challenge, there are many complex questions that will need to be answered. Our patients’ privacy is not the least of these. Even with our busy professional and personal lives, I imagine it has been hard for most to miss the recent public flogging of Mark Zuckerburg and Facebook. Both he and his company were taken to task by Congress and the media when they revealed that the personal data for 87 million of their customers had been inappropriately accessed by an outside research company. As a result of these disclosures, politicians are threatening regulations for their industry – think HIPAA for Silicon Valley. There are more than 2.5 million people who annually seek orthodontic treatment. As we look to find the best ways to utilize our patient’s treatment data to improve their care, we must make certain that it is being done in a way that is respectful of all patients’ privacy. While privacy may be where we start, there are other, even more difficult issues that need to be addressed.

The complexity of the Big Data issue will require the input from the brightest minds both from within and from outside of our profession. To that end, the Great Lakes Association of Orthodontists has put forth a resolution to this year’s American Association of Orthodontists House of Delegates. Resolution 18-18 GLAO (http://hod.live.aaoinfo.org/resolution2/18-18-glao-big-data-task-force-and-records-repository/) requests that our Association President appoint a Big Data task force. I would encourage you to review the resolution and let your representatives (HOD Delegates) know your feelings. While this issue is certain to require a significant investment of time, talent and financial resources, we cannot afford to leave this investment to outside sources. Those who control the data will control the future.

Is your Password Already Floating Around on the Internet?

By Steve McEvoy, Technology Consultant

Passwords are a pain. You need them when you turn your computer on, open your practice management software, access your email and when you access most any other Internet service like Gmail, Pandora, Dropbox, Facebook, etc. Keeping track of all of them is a hassle, and it is human nature to look for shortcuts – many people often use the same password for multiple sites.

Hackers are constantly looking for ways to steal information. Information is the new ‘gold’ on the Internet. The mention of ‘hacker’ conjures up images of a mysterious character lurking in a dark room, presumably hard at work trying to guess your username and password to gain access to your information. While this may still be the case in some situations, the hackers are smart folks, and they have moved on to where the real gold is. Rather than hacking us one person at a time, they are going after the websites where all of our collective online information lies.

Do you have an online account with any of these sites? LinkedIn, Yahoo, Dropbox, Adobe, Target, Home Depot, Comcast, Bell, Equifax or Experian? What all these sites (and many others I haven’t listed) have in common is that they were hacked, and some of the valuable information stolen included your username and passwords for their site. Ten’s of millions of usernames and passwords have been stolen. The hackers have realized that putting their efforts into breaking into a website yields much more information about you than trying to hack you directly.

How do you know if your username and password was breached?

Can you rely on the hacked website to notify you? Some sites, when they discover they have been hacked, implement a mandatory password change the next time you attempt to access the site. Has this ever happened to you? You log in to a website, and it immediately prompts you to verify your identity and change your password? It did for me a while back when I was using Dropbox. What they didn’t point out was that they had been breached, and for some period of time hackers could have accessed my data.

Can you even rely on the websites to know when they have been hacked? How would they know? It’s not like a traditional crime where you might see the broken window. Companies that aren’t making security a principal focus may be completely unaware of the breach and your user information for that site might be already out in the wild.

Troy Hunt is a security expert at Microsoft, he’s one of the white hat hackers on our side. He had the great idea to compile a list of all the available hacked accounts he could find. He scoured the ‘dark web’ to get copies of the information being sold by successful hacks (there is a thriving retail market for this fueled by BitCoin). He found nearly 5 billion accounts (that’s a B, not an M) from 265 known breaches. Then he created the website “Have I been Pwned” (www.haveibeenpwned.com). That’s not a typo, “pwned” is a slang online gaming term that roughly means “I own you” or “I conquered you” just like a hacker may have. His website is free to all. You can go to the site, enter the username that you may often use online (for example most people use their email address) and it will tell you if it knows your username was leaked in one of the breaches it knows about. I tried it with mine and found my information was leaked in the Adobe and Dropbox breaches.

You can also enter a password to see if the password is already in the known hacked password list. In the example shown here, I am testing the password that Invisalign Intraoral scanners use by default. Pwned.

A word of caution. Should we really trust that whoever is behind the website isn’t recording all the passwords tried? What if they get hacked? My advice is to be careful here and NOT test any of your CURRENT passwords you use where you have precious information kept (like your online bank account password). I know this is counter-intuitive, this is the first password you want to test to see if it’s safe.

Remember the bad habit that people have using the same username and password at multiple sites? If that’s you, and the hackers have got your username along with the password when they hacked one of these sites, I can guarantee you that these are the first things they are trying at other websites to see if they can get in (perhaps your bank). If the usernames and passwords are the same, they get immediate access without even needing to take a second guess. It happens all the time.

Consider all this carefully. Check the email you use typically for a user account at HaveIBeenPwnd.com. Perhaps check a password you use all the time. If you discover you have been pwn’d, change your passwords at all the sites that share that username immediately.

What Your Email Address Says About You

By Steve McEvoy, Technology Consultant

Sending business emails ending with @Netcom.com, Aol.com, Earthlink.com and soon Yahoo.com are tell-tale signs you aren’t keeping up. People notice and may ask you if you are still driving the ‘72 Ford Pinto as well.

Using personal accounts from your Internet Service Providers (ISP) also looks old school like Comcast.net, TimeWarner.com, RoadRunner.com, SBCGlobal.net.

There is no rule making us keep up, or against driving a ‘72 Pinto, but I’d argue if you are in a marketing battle for new patients, this is just one small aspect you can easily improve.

For work, you really should have an email for your practice’s domain.   DrSmith@SmithOrtho.com or DrJones@SmileDental.com, for example. People expect this, and when they see FlyingPigs65@aol.com, you send a subtle message that isn’t positive.

You might certainly have a private, personal email account as well, but even for that, you should consider using something like BobSmith@gmail.com or JaneJones@Office.com.

This should also apply to any of your staff using email on behalf of the practice.

There may be other motivating reasons as well. Companies offering email services for free (AOL and YAHOO) that aren’t thriving financially in their core business won’t be putting development resources into keeping products current, safe and secure.  The news is full of stories about hacked email accounts and ransomware which typically makes its way into your computer via email. Companies like Google, Microsoft, and Apple have reputations to maintain and will have the resources to keep up.  If you are going to use a free email service, I might suggest you look to one of the major players.

Changing your primary email account is always a major hassle, and this is likely what has kept you from making the switch.  Setting up a new email account, and merely forwarding all the email from your old account indefinitely isn’t the right solution. Your old email account can still be hacked, and the company can still go out of business.

The steps generally are:

  • Setup your new email account – and take this opportunity to make sure the password is a hard one. I’d suggest you setup two-factor authentication with it as well.
  • Link your new account to your PC, phones, tablet, etc.
  • Using your old email, notify EVERYONE in your contact list that you are changing your email to the new one effective immediately.  You can do this in one mass email, but be smart about it and put all the recipients in the BCC list so they don’t see everyone else you emailed the list to. Make yourself the only official To:
  • Configure your old email account to forward to your new one (for a while).
  • After a month, check your old account to see if anyone you know is continuing to use the old account, then contact them directly to start using the new address.
  • After another month, turn off the forwarding from your old account and delete it at the vendors. Gone forever, but no risk of hacking.

You can also always enlist some help from your IT person, they should be well familiar with the process.

Am I legally responsible if I receive a patient referral from another dentist and it is sent to me unsecured?

By: Charlie Frayer, JD, MS, HCISPP, CIPP, CIPM

DISCLAIMER: Protected Trust cannot and does not provide legal advice, and the following question(s) and response(s)—like everything else we publish—are not intended as legal advice or opinion. If you need legal assistance, you should contact an attorney licensed to practice law in your jurisdiction.

For the purpose of this answer, we assume that “sent” means “emailed.” Yes, it is possible that you could be responsible if something bad happens to the patient’s electronic protected health information (ePHI) contained in the email referral, but only if it happens after you receive it.

Under HIPAA, a health care provider is called a “covered entity”. The HIPAA Privacy Rule defines “treatment” to include, “…the referral of a patient for health care from one health care provider to another.” The Privacy Rule also states that, “A covered entity is permitted to use or disclose protected health information…[f]or treatment…”. Therefore, under the scenario you describe, neither the referring dentist nor you are violating HIPAA by merely sending (disclosing) or receiving a patient’s ePHI as part of a referral. Given this good news, the core question now becomes, “Does a covered entity violate HIPAA by sending (or receiving) ePHI in an “unsecured” manner?” Again, the answer is mostly good news, but BE VERY CAREFUL AND READ THE REST OF THIS RESPONSE!!!

First, we have to know what makes ePHI “unsecured” vs. “secured”. Then, we need to know whether HIPAA requires ePHI to be secured (seems like a silly question, but you’ll probably be surprised). And, lastly, if HIPAA does not require ePHI to be secured, then what risks do you have if you face by choosing to leave it unsecured?

Unsecured vs. Secured ePHI
The HIPAA Breach Notification Rule states that, “Unsecured protected health information means protected health information that is not rendered unusable, unreadable, or indecipherable to unauthorized persons through the use of a technology or methodology specified by the Secretary [of HHS] in the guidance issued…”. The HHS guidance emphasizes the use of encryption to make ePHI secure. So, technical details aside, the simple answer is that “unsecured” means unencrypted, and “secured” means encrypted.

HIPAA: Encryption Is NOT Required…What?!?
That’s the title of one of our blog posts from Feb.-Mar. 2016—republished by AAO, which we highly recommend that you read immediately (here or here). Although you would be crazy to not use encryption when emailing ePHI—because the risks are enormous, it is true that HIPAA does not literally require encryption (again, read our blog post here or here right now). Rather, what the federal government decided to do was strongly encourage the use of encryption by making it a get-out-of-jail-free card (apologies to Parker Bros.). Under the HIPAA Breach Notification Rule, you must notify certain persons and/or entities whenever you have a breach (e.g., a loss or theft) of unsecured (unencrypted) ePHI. For example, depending on the breach details, HIPAA requires notifying not only the affected patients, but also the federal government (HHS) and prominent members of the media. But—and here’s the GREAT NEWS—if you have a breach of secured (encrypted) ePHI, you do not have to notify anyone. Why? Because the loss or theft of encrypted ePHI—which cannot be read without the key(s)—is not considered a breach at all. So, encryption=no breach=no notifications=no problems for you.

Risks of NOT Encrypting ePHI Emails
If you’ve already read the above-mentioned blog post—and, if you haven’t, stop now and do so immediately (here or here), then you already know the frightening list of risks you face for not using encryption. In summary, in the event of a breach of ePHI:

No Encryption = Notification(s)

Notification(s) = Investigations, Fines, Lawsuits, PR Disaster, and Lost Business

Investigations, Fines, Lawsuits, PR Disaster, and Lost Business = Wasted $,$$$,$$$.

Our Recommendations

  1. Never email ePHI without using Protected Trust Healthcare Email Encryption.
  1. Require all of your fellow covered entities (e.g., health care providers and insurers), other business associates, and patients to use Protected Trust Healthcare Email Encryption.

IMPORTANT REMINDER: As a Protected Trust client, all of these third-party persons and entities can communicate securely with you, free of charge, and forever. No catch!

  1. To comply with HIPAA, make sure everyone in your office has their own Protected Trust Healthcare Email Encryption account (shared accounts are not permitted by HIPAA).

HIPAA: Encryption is NOT Required…What?!?

By Charles E. Frayer[1], JD, MS, HCISPP, CIPP, CIPM

Introduction
cfrayer
No, that headline is not a misprint. Contrary to common assumptions—and what many email encryption providers may tell you, Congress, in its infinite wisdom (stop laughing, please) decided that the Health Insurance Portability and Accountability Act (HIPAA) should not—and, therefore, it does not—require the use of encryption to secure your patients’ private medical data (aka, electronic Protected Health Information or ePHI).

WARNING: IF YOU STOP READING NOW AND SIMPLY DECIDE THAT YOU DO NOT NEED ENCRYPTION, YOU MAY WAKE UP ONE DAY TO THE WORST FINANCIAL AND PUBLIC RELATIONS NIGHTMARE IMAGINABLE. SO, READ ON…

Required vs. Addressable: What’s the Difference?
In HIPAA, Congress adopted two types of implementation specifications—“required” and “addressable.” Those labeled “required” must be implemented or it will be deemed an automatic failure to comply with the HIPAA Security Rule. On the other hand, those labeled “addressable” must be implemented only if, after a risk assessment, the covered entity (that’s you, if you’re a Health Care Provider, a Health Plan, or a Health Care Clearinghouse) has determined that encryption is a reasonable and appropriate safeguard for managing risks to the confidentiality, integrity and availability (CIA) of ePHI. A brief sidebar about the CIA triad: confidentiality protects against unauthorized disclosure; integrity protects against unauthorized modification or destruction; and availability protects against disruptions to access and use of ePHI. Okay? Now, back to our story…

However, if you determine that encryption is not reasonable and appropriate (think about this carefully), then you must document your rationale for that decision and do one of the following: (a) implement an equivalent alternative to encryption that is reasonable and appropriate; or (b) if safeguarding ePHI can otherwise be achieved, then HIPAA even allows you to choose not to use encryption or any equivalent alternative measure, provided that you also document the rationale for this decision.[1] Shocking, isn’t it? Yes, Congress effectively (is that an oxymoron?) allows you to do nothing, provided you can and do back it up.

Now, if you’ve thought about that carefully, you’re probably wondering something like, “What if HHS audits me and they don’t agree with my carefully documented rationale for deciding that encryption is not reasonable and appropriate to protect my patients’ private medical data?” Perfect question! And therein lies the problem. It is difficult (impossible?) to even imagine a situation for which it would be “reasonable and appropriate” to decide not to use encryption to protect ePHI (remember, that lowercase “e” stands for “electronic”). So, even though HIPAA does not literally require encryption, it effectively requires encryption because there is no reasonable and appropriate alternative for protecting ePHI.

In other words, when it comes to using encryption to protect ePHI, there is little (if any) difference in Congress labeling it as “addressable” rather than “required” because not using encryption is simply too risky for your patients’ ePHI and, therefore, even riskier for your business.

Encryption: HIPAA’s Data Breach Safe Harbor
Under the HIPAA Breach Notification Rule, there are essentially two types of ePHI—unsecured (i.e., unencrypted) and secured (i.e., encrypted). Under HIPAA, every breach of unencrypted ePHI requires you to provide time-bound notifications to: (1) affected patients; (2) the Secretary of HHS (i.e., the federal government); and/or (3) prominent local/state media outlets. This, of course, will put you at risk of federal and/or state investigations, fines, possible lawsuits, and the worst kind of public relations disaster imaginable, which will almost certainly result in lost business.

But there is good news…no…GREAT NEWS!!! Under the Breach Notification Rule, encrypted ePHI that is “breached” (e.g., lost, stolen, or accidentally/intentionally sent to the wrong recipient) is not considered a breach at all because ePHI that is encrypted cannot be read or otherwise used without the key(s) required to decrypt it. Consider some of the risks of emailing your patients’ ePHI unencrypted versus sending it via encrypted email, as follows:

Screen Shot 2016-02-18 at 4.27.19 PM

So, if you use it, encryption is your lawful HIPAA-endorsed safe harbor against everything you want to avoid in the event of a breach of ePHI. Going back to our previous segment, even if you somehow came up with that rarest of all situations—where using encryption to protect ePHI was not reasonable and appropriate, you still need to use it because doing so gives you a complete “out” when the worst of all possible ePHI scenarios—a data breach—occurs (i.e., you get to simply walk away).

In summary, although HIPAA does not literally require encryption, Congress nonetheless has effectively mandated its use because (i) it is all but impossible to think of a real-world situation where encrypting ePHI is not reasonable and appropriate; and (ii) if you choose not to use it, you are exposing your business to a plethora of regulatory, legal, public relations, and/or financial risks that are easily avoidable—by simply using encryption.

[1] Charlie Frayer is a Michigan licensed attorney and Florida Authorized House Counsel serving as General Counsel and Chief Privacy Officer at Protected Trust, LLC, the leading provider of Simple Email Encryption with 24×7 free and unlimited support via phone, email, and chat.

[1] See: 45 CFR § 164.306(d)(3) detailing the difference between “Addressable” and “Required” implementation specifications at http://www.ecfr.gov/cgi-bin/retrieveECFR?n=sp45.1.164.c#se45.1.164_1306;

45 CFR § 164.312(a)(2)(iv) labeling encryption and decryption as “Addressable” at http://www.ecfr.gov/cgi-bin/retrieveECFR?n=sp45.1.164.c#se45.1.164_1312; and
the HHS HIPAA Encryption FAQ at http://www.hhs.gov/hipaa/for-professionals/faq/2001/is-the-use-of-encryption-mandatory-in-the-security-rule/index.html

Sending Sensitive Patient Data via E-mail

Foto-StudOnBy Dr. Andreas Detterbeck

The communication between clinicians via E-mail is fast, easy, cheap and widely used. But sending an unencrypted E-mail is as safe as sending a postcard. So, numerous parties have full access to E-mail-correspondence at all time. Violations against the patient privacy could cause dramatic consequences – depending on national laws, some of these solutions may even result in prosecution of the clinician (see HIPAA).

There are many commercial solutions to encrypt your communication, but if you are firm and experienced in using computers – you should at least know how to download and install software – there is no need to rely on any company. You don’t have to worry about high fees or losing your correspondence if your preferred encryption-business crashes. In this blog I want to suggest a few ways how to encrypt your E-mail communication easily and (almost) free of charge:

screenshot

Encryption of E-mail Communication by S/MIME
If I don’t want that my mails can be read by anyone except the receiver of the mail I have to convert the text in some sort of coded or encrypted form. Because it is not easy to invent an encryption of your own and sharing that idea with your communication partner a standardized tool would be very helpful. And this is where the Secure/Multipurpose Internet Mail Extensions (S/MIME) come in: S/MIME offers encryption and signing of E-mails in a standardized and reproducible way. Most current E-mail programs and free Webmail providers support this process.

Subsequent I will give a step by step introduction how to implement S/MIME in your mailing process:

  1. First of all you have to make sure you are using an E-mail program with S/MIME support (Mozilla Thunderbird, Microsoft Outlook and many more)
  2. Next you have to buy or even just create a certificate from a big commercial or non-commercial certification authority (CA). You may find some references here.
  3. Now comes the hardest step – but don’t worry you’re almost done:
    Deposit this personal-certificate in your E-mail program with S/MIME support. This process is very different depending on which program is used. Here are two useful how-to-links for the most common software:

Microsoft Outlook
Mozilla Thunderbird

  1. Users who have completed these steps are then ready to send digitally signed E-mails and receive encrypted messages (You sign a message when you want to prove that the mail comes from you and no modification of the text has been done during the transit).
  2. If users want to send encrypted E-mails of their own – and not only receiving encrypted mails – the receiver needs to have an S/MIME certificate, too.

For security reasons, your user certificate will normally remain valid for one or two years and is available from the CA for a small fee or even free of charge.

Conclusion
Maybe you think this sounds all strange to me and way too much work is required. There has to be an easier, less cumbersome solution.

But we don’t have the easy solution yet.

Of course you can pay a company for securing and encrypting your communication, but what happens if the company is insolvent or they decide to wind down the operations. What happens to your documents? There are providers that will allow you access to your data, but this may not be the case for all providers, so make sure this is the case before you sign up.

For use in daily clinical practice, I definitely recommend E-mail encryption by S/MIME. It is an IT standard since 1995 and a long term support is presumably. At least the corresponding doctors should have any form of secure communication.

Do not forget: The use of cryptography before sending patient data via E-mail is mandatory! If you are not sure how to encrypt your E-mail communication it is better to relinquish sending private patient data via the internet.

This blog-entry is based on:

Electronic transfer of sensitive patient data.
Detterbeck A, Kaiser J, Hirschfelder U.
Int J Comput Dent. 2015;18(1):45-57.
http://www.ncbi.nlm.nih.gov/pubmed/25911828

CryptoWall Virus Affecting Practices

By Steve McEvoy, Technology Consultant

steveMWe are seeing a fast spreading outbreak of a new virus called CryptoWall affecting many practices.   Similar to the Cryptolocker virus that emerged last year, this virus seeks to encrypt all your precious data on your computer, and hold it for ransom (asking you to send them $500 USD in Bitcoin to get the decryption key).

What makes this virus so alarming is that as of a few days ago ZERO out of nearly 50 antivirus programs were able to detect it. None.

How to protect yourself

Eventually the Antivirus programs will catch up and learn how to detect it, but at this point in time you need to rely on your own wits and acting responsibly.

So far the virus has been arriving as an attachment to an email message (usually a ZIP or PDF file). We’ve seen it claiming to be airline ticket confirmations, monthly statements from the power company, shipping receipts, etc. Avoid ANY email with attachments that you are not 100% expecting. If you receive an email that you are unsure of – DON’T OPEN IT – and contact the sender by other means and confirm that they did send it to you.   Reading the email doesn’t infect your PC, only opening the attachment will.

Signs that you are infected

2The virus needs time to tackle the encryption.   The longer it goes undetected, the more of your data it can encrypt.   You will notice the PC running much slower than normal (since it is using the computers processing power to encrypt your files). You may see files named DECRYPT_INSTRUCTION.TXT and DECRYPT_INSTRUCTION.HTML on the desktop, documents, pictures, mapped drives or any location where you have data saved.

1

What to do if you suspect an infection

Open the DECRYPT_INSTRUCTION.HTML file and note the time remaining to decrypt your data (they only allow you a short period of time to send them the money before they destroy the data permanently). Once you have that information TURN OFF THE PC. The longer it remains online the more data it can encrypt. Do not attempt to run scans and clean the system, this only buys it more time to encrypt data. Do not connect any external drives to restore backups of data as it will attempt to encrypt your backups when it sees the drives. Contact your IT person IMMEDIATELY for their assistance in recovery.

Encrypting your Laptop

By Steve McEvoy, Technology Consultant

steveMDepending on your interpretation of the HIPAA regulations your Practice’s HIPAA policy (you have one right?) might mandate that Protected Health Information (PHI) on portable electronic devices within your Practice should be encrypted.

Let me interpret that last sentence into English – If there is any chance that you have any information related to your patients on your laptop, it’s probably a good idea to encrypt the laptop to keep the attorneys and HIPAA Nazi’s away in the event that it is stolen or lost.   You probably have your own personal data on the laptop too, so this is good for several reasons.

I would expect that if I could canvas all of you reading this article that 90+% have PHI on your laptop in some form (as minor as an email message) and less than 1% of you will have your laptop data encrypted. I expect that most laptops that get stolen or lost now don’t get reported and the Doctors are just silently hoping it doesn’t get discovered.

You want to encrypt your laptop, but how do you accomplish this?   I’d like to be able to tell you the how to is simple “Just do this…” but I can’t.   Depending on your equipment you have to consider your options. If you invest the time to read through the article below the conclusions at the bottom will get you started on getting this done.

The Background that Matters

Encryption is basically a process where data stored on a computer is scrambled in a pattern using an encryption key.   The process is complicated, but renders the information useless to anyone unless they possess the key.

There are various levels of encryption, you might have heard of it described as 128 or 256 bit encryption.   This is referring to the length of the key.   A key is a string of 0’s and 1’s (binary language) and the bits mentioned describe how many characters there are.   For example, 8 bit encryption would be 2 to the power of 8 possible combinations of 0’s and 1’s, so 256 possible keys if you do the math.   If you used 8 bit encryption it would be pretty easy to just try each of the 256 keys to unlock your data.   Now consider that 128 bit encryption has 3.438 possible keys, specifically 340,282,366,920,938,463,463,374,607,431,768,211,456. That is a lot!   256 bit encryption has 1.1577 possible keys, and is generally considered unhackable (unless you’re the NSA). Fun fact – many banking websites now use 2048 bit encryption!

I’ve heard rumors that the number of bits used matters to HIPAA, but I have NOT been able to confirm for myself.   The rumor goes that 128 bit is NOT good enough for safe harbor. ‘Safe harbor’ meaning that if you lose it you don’t have to report it. It suggests that 256 bit is good enough for safe harbor.     Personally I think any level of encryption will keep your data safe since no one is likely to invest the time or effort to decrypt Dental records. They are going to take your stolen laptop, reload Windows and resell it on eBay or Craigslist for a quick buck.

If we agree that we want encryption and we’ll go with 256 bit, now what? It gets tricky here, so hang in with me.

Your two choices for Encryption

The encryption process (taking your data and mashing it up using the encryption algorithm with your key) takes computing power.   Something has to actually ‘do’ all that work.   That something can be one of two methods generally:

  • Software based encryption that has a little program plugged into Windows that is converting all the information on the fly, and thus this method uses some of your laptops CPU power and memory to get it done.
    • This is great because it is a solution that can work on any computer, in particular those that don’t have the special hardware.
    • On older laptops this can make them feel even slower (noticeably so) and can turn it from marginal to use to no fun at all to use.   Some older laptops just can’t deal with the load. I’ve seen it make a cheap 5 year old laptop nearly unusable.
    • There is some cost to this usually, ranging from free to perhaps $130.
  • Hardware based encryption is a solution where there is a special encryption chip (either on the hard drive storing the data or within the laptop) to do all the thinking. This method doesn’t borrow any resources from your laptop’s CPU or memory.
    • This is great since it won’t slow down your computer, even if it’s an older model.
    • Even new computers or hard drives don’t all have this hardware standard – you need to look for it.   When you order a new Dell or HP business laptop you need to select a hard drive with Opal security.   The cost increase is minimal, typical $20 to $50.

Software encryption is appealing to many since Microsoft began to include BitLocker for free in specific versions starting with Windows Vista.   There are only two versions of Windows Vista/7 that do include it, Ultimate and Enterprise editions. Unfortunately the vast majority of Windows 7 out there is Home or Professional editions. You can do an ‘In Place Upgrade’ of Windows 7 Professional to Ultimate, but it costs ~$130.   The good news comes in Windows 8 – Microsoft now includes BitLocker as standard in both the Pro and Enterprise versions of Windows 8.   So, if you have Windows 7 Ultimate, Enterprise or Windows 8 Pro version on your laptop enabling software encryption is as easy as going to Control Panel and clicking on BitLocker and following the prompts.   Allow from a few hours to 2 days for the initial encryption to complete (knowing you need to leave the laptop alone and plugged in for that period).   Pay close attention to the performance impact after BitLocker is setup. If you can’t notice the difference you are in great shape. If performance sucks afterwards, you can always turn it off and go back to normal again.

It is possible to replace your old slow hard drive with a new drive that includes hardware encryption.   A fancy super-fast Solid State Drive (SSD) with Opal security can be had for as little as $114 now (I am a big fan of the Samsung 840 Pro, and others like Intel make good units). The move to SSD will likely speed up your laptop substantially in general so it might be worth it on its own. Remember to factor in the cost of having your IT person help you copy your old drive to the new one and enable the encryption.

Just because you have an Opal compliant drive installed doesn’t mean it’s turned on.   Something has to work with it to turn it on and provide a key.   Unfortunately Windows 7 Ultimate and Enterprise editions can ONLY do software encryption – they have no idea about Opal drives or what to do with it. The good news is that Windows 8 BitLocker now has the intelligence to work with Opal drives and can control it for you. So, Windows 7 BitLocker you will get Software encryptions only, Windows 8 you can get Software or Hardware if your drive is compliant.

There are more Software encryption options than Windows BitLocker. As with many Microsoft features, BitLocker is sort of the bare bones of what is needed.   Third party companies such as Dell and Sophos have add-in applications for Windows that can do the same thing as BitLocker, maybe even better with less of a performance impact.   Dell Data Protection Encryption (DDPE) is available in several versions, but for about $50 you can add it to any version of Windows and turn on Software OR hardware encryption if you drive is compliant.

Auditing

None of these personal solutions may be truly 100% HIPAA compliant. If you believe that there needs to be a constant level of electronic auditing to be able to prove that your laptop was encrypted at the moment of loss, you need a better solution. DDPE for example has an ‘Enterprise’ level license that will include this kind of auditing, but at a cost. The individual license cost only goes up marginally, to perhaps $80, but you need to have an armada of Server software running somewhere that does the auditing process and an IT person to set it all up.

Personally I think this is overkill, and if your Practice’s HIPAA policy states that you shall BitLocker 256 bit encrypt, and you do it, just write a letter to yourself (or from your IT person) that states that “On this date we enabled 256 bit Bitlocker encryption on Laptop with serial number 1234, and stored the encryption key in this safe place” and sign it. Keep this document someplace safe.   You could add a periodic audit to this on an annual basis where you check that BitLocker is enabled (remember that it can be as easily turned off as it was to turn on) and document that you checked on the specific date.

Caveats

Really, really, really read this section and follow its suggestions. It’s based on the school of hard knocks I have personally attended.

Backup

If you enable encryption on your laptop I guarantee you this will cause a nightmare for your IT person down the road if you have a hardware failure (like a drive failure, Windows corruption due to spyware or virus, etc). I have lived this multiple times.   Without encryption, IT people have a substantial bag of tricks to try and recover fragments of data from your dead or dying hard drive (most of the time we can get part or all of your data back). With encryption, the drive thinks your IT person is just a bad guy and works to prevent access.   So, all those precious family photos or lectures you’ve prepared are at risk of complete loss.

You need a regular backup of your laptop data. We all know you should be doing this already, but rarely does anyone take the time to do it.   If you are, kudos to you!

My suggestion is to invest in an Internet Backup solution for your laptop in order to keep a near real-time backup copy of your data on your drive.   Other than the initial setup (which is very easy), you don’t need to do anything else. It will just run in the background anytime you are connected to the Internet.   The solutions are cheap now from companies like Carbonite, Mozy and Oak Tree Storage. A personal plan from Carbonite with unlimited storage is just $5 per month now, less than a quad shot vente latte at your favorite coffee shop. [One of you is going to ask “Is an Internet Backup HIPAA Compliant?” and that is a good questions but I don’t have space to answer here in detail other than “Probably Yes”]

Make sure your backup is complete BEFORE you turn on the encryption. An Internet backup might take from a few hours to a few weeks to complete the initial sync depending on how much data you have.

Don’t Lose your Key!

Regardless of what method of encryption you enable, all of the solutions are going to need to store a copy of the encryption key. Some solutions might use a special chip on your laptop called a Trusted Platform Module (TPM chip), and others might want you to attach a USB thumb drive.   If you use a thumb drive, just get a drive specifically for this purpose (they cost as little as $10 now) and then store the USB drive in a safe place (like a safe or lock box). Label the drive what it’s for “Encryption Key for my Laptop” and DON’T carry this drive around or use it like a regular USB key for your files, etc.   Think about it, if you lose the key someone has a critical part of your encryption process.   You might be able to make a copy of the encryption key file in several safe places (like a folder on your laptop that is then sucked up in the Internet backup).

Don’t keep the only copy on your laptop thinking that the encrypted drive is the safest place.   When the drive fails, your IT person will be asking you for a copy and you will be stuck with your keys locked in the car essentially. Another reason you might need a copy on USB key is that some laptops can sense ‘tampering’ and will lock themselves down if they think someone is trying something fishy to hack the encryption. The only way to unlock the drive and get your laptop functioning again will be to present the encryption key.

Encrypt it All or Don’t Bother

Some solutions offer you a way to have just an encrypted folder or similar setup where only a portion of the laptop hard drive is encrypted. It wouldn’t take much of a lawyer to tear you apart on this, essentially requiring you to prove that there was no possibility of there being PHI on the unprotected portion of the drive. Don’t use a half measure – use a solution that encrypts the entire drive.

A Password is Essential

There isn’t much point to encrypting your laptop if you don’t have a good password on your Laptop.   Imagine if your laptop was set to just automatically login without stopping for a username and password.  The thief would have direct access to your data without even needing to consider hacking the encryption.  Make sure you have a strong password.   Check out our previous Blog post on this.

What about Mac’s?

I am no Mac expert so I won’t try to be. A little research with Google points out that the latest versions of the Mac OS now include FIleVault2 (it appears that all you need to do is just enable it).   It will fully encrypt you Mac hard drive at the 128 bit level.   I don’t know if this is Software or Hardware encryption. I am not sure how this will play with Mac’s setup with BootCamp partitions, but I suggest you do a little research or enlist your Mac genius of needed. I’d still advise that you make sure you have a full regular backup in place.

What Would I Do?

Ok, you’ve suffered through the entire article to get to this. Here’s what I would do based on a few scenarios:

  • If I had an older laptop I was ready to replace – get a new laptop with Opal drive included and Windows 8 Pro and then enable BitLocker
  • If I had a decent existing laptop on a Windows version that already included BitLocker, I would just enable Software encryption and know the performance hit will be a little bit but not enough to matter
  • If I had a decent existing laptop on a version of Windows that did NOT include BitLocker and I didn’t want to replace the drive and OS (due to the hassles) I would get a third party encryption application like Dell Date Protection Engine (DDPE) or Sophos and setup software encryption.
  • If I had a decent existing laptop and was willing to upgrade the hardware and OS, I would get a new fancy SSD with Opal drive and then install Windows 8 Pro and use BitLocker to control it.
  • For any of these solutions I would add the Do-It-Yourself auditing to document the setup was completed and periodically review that it’s still enabled.
  • I would be sure to keep one copy of the encryption key on a USB drive in my safe, and another copy in a folder on my encrypted drive that would also get backed up by my Internet Backup plan.

If I had done one of these scenarios and my laptop was lost or stolen, I would rest easy that the data was safe.