As Chief Information Officer of one of the largest hospitals in the country, the decisions around security that I make affect all areas of the hospital, all employees and ultimately, all patients.
Here are some of the pro-active actions Sunnybrook Health Sciences Centre takes in implementing processes to strengthen security.
To begin, I want to touch on investing in security and reporting incidents. It’s agreed that the healthcare sector is generally underreporting security incidents because we’re not systematically monitoring (this is similar to the state of adverse event reporting for patient safety, pre Baker Norton circa 2004).
At Sunnybrook, IT security accounts for 3 per cent of our total IT spend. We have invested in IPS technology, but not Security Information and Event Management yet. With increased detection capabilities, we expect the number of reported incidents to increase. We don’t believe that a larger number of reported incidents indicates an increase in the type and kind of attacks, but rather that our risk management program is working to better detect what’s already happening.
We are proceeding with increased and formalized risk monitoring across all IT processes - not just security – and expect that this will lower the underlying security risks and improve Service Level Agreement performance.
Legal or best practice breach accountabilities have not materially changed in the past three years, but increasing scale and scope of IT operations demands greater management visibility and control over IT processes. Appropriate design and operations management of IT projects and systems require integrated security and process controls (ITIL, CoBIT, ISO 27002, 27005, etc.). Hospitals are not subject to some government data management requirements (e.g. FIPPA), but this will likely change in 2011.
Security accountability
Today, system availability and accountability for personal health information under PHIPA remain primary security concerns. We are not currently quantifying breach losses and assume these losses and investigation costs are nominal compared to reported averages for commercial, or even government - but these costs will increase due to a focus on formalized risk monitoring and investigation.
Trusted user breaches (malicious and non-malicious) continue to occur. We are instituting access accountability strategies for IT staff and will look at increasing inappropriate access auditing for clinical staff. The overall theme here is “Trust, but verify.”
Our social networking policy was instituted in 2010. It’s a policy largely based on acceptable use, not on data loss prevention. We agree that data loss and compliance remain top concerns after system availability.
Secure web development was addressed this year as well, as PIA and TRA reviews are increasingly applied to all new systems. As reviews become more complex, project teams spend more time evaluating controls, designing to standards and remediating identified risks. ‘Privacy/security by design’ requires additional project resources not previously considered.
IT security, 2011
The creep of consumer mobile devices into enterprise is the biggest new threat vector, especially to data loss prevention. We’re managing through clear policy and strong technical controls. Smartphone vulnerabilities are being reviewed as consumer phones become corporately supported in 2011. FIPPA application to hospitals will also require review of IM considerations for lifecycle data loss management.
Sunnybrook currently has no formal data loss strategy, although we are expanding mobile and e-mail encryption, and will likely establish our data loss strategy as part of overall security risk program development in 2011.
Service level agreements for security technology deployment, monitoring, reporting and improvements are key; the major effort/expenditure is in the operations management of controls, not the decision to deploy or the technology selection itself. Vendors generally don’t have much to say about security ops management (e.g. Winmagic lifecycle management) and this remains a challenge.
A snapshot of best practices
- Get the security basics right and go from there
- Ensure IT management is focused on business risk, not just on technology
- Security assurance is about diligence on risk across the IT spectrum
Sam Marafioti is the Chief Information Officer at Sunnybrook Health Sciences Center.
About Sunnybrook Health Sciences Centre
Sunnybrook Health Sciences Centre is inventing the future of health care for the one million patients the hospital cares for each year through the dedication of its more than 10,000 staff and volunteers. An internationally recognized leader in research and education and a full affiliation with the University of Toronto distinguishes Sunnybrook as one of Canada's premier academic health sciences centres. Sunnybrook specializes in caring for Canada's war veterans, high-risk pregnancies, critically-ill newborns, adults and the elderly, and treating and preventing cancer, cardiovascular disease, neurological and psychiatric disorders, orthopaedic and arthritic conditions and traumatic injuries.
This week, TELUS and the Rotman School of Management released their third annual study on Canadian IT security. Please see this week’s blogs from TELUS’ Yogen Appalraju and Rotman’s Dr. Walid Hejazi for more information about the results or go to TELUS.com/securitystudy.

