Handling HIPAA Compliance with Your Data Access

November 15, 2017

About Me

• Infrastructure and security architect

• Database Administrator / Architect

• Former Incident Response team lead

• Certified Information Systems Auditor (CISA)

• SQL Server security columnist / blogger

• Editor for SQL Server benchmarks at Center for Internet Security

My Contact Information

K. Brian Kelley

Email: kbriankelley@acm.org

Twitter: @kbriankelley

Infrastructure/Security Blog: http://truthsolutions.wordpress.com

Personal Development Blog: http://gkdba.wordpress.com

5 Key Questions1. Who has access to my electronic PHI, and how do I audit the activity?

2. How do I define a secure baseline and maintain it across my SQL Server environment?

3. How can I implement repeatable processes to help maintain the security standards?

4. How do I audit permissions, logins, and object and data changes on my SQL Server?

5. What is the best way for me to ensure not only ongoing compliance with the HIPAA,

HITECH, and Omnibus Rule regulations but also help maintain reasonable security

across my SQL Server databases?

Source: https://www.idera.com/resourcecentral/whitepapers/security-and-compliance-solutions-for-hipaa

Search Engine Keywords: IDERA HIPAA

Agenda

• Repeatable Processes (#3, #5)

• User Security (#4)

• Secure Configuration (#2, #5)

• Auditing Access (#1, #4)

Some of what SQL Server brings to bear to comply

with HIPAA are found in features only available in

Enterprise Edition. What you will need Enterprise

Edition for:

• Extensible Key Management

• Transparent Data Encryption (TDE)

What was added to Standard Edition, starting with

SQL Server 2016 SP1:

• Always Encrypted

• Database-level (Fine-grained) Auditing

Repeatable Processes

Repeatable Processes

• Organizational Issue: Change Control

• Workflows must be consistent

• Documentation must be maintained

• Exceptions must be reported

“If there’s no evidence for a control, it’s not a control.”

What SQL Server Can Do

• User security to restrict access

• Data Definition Triggers:

• Enforce when changes can be made

• Enforce what types of changes can be made

• Schema Change History report

• SQL Server traces

• Extended Events

User Security

Login Security

The Best Practice:

1. All logins are via AD domain user accounts

2. All logins are placed in security groups (preferably domain security groups)

3. Security groups are granted login ability to SQL Server

If You Follow This Best Practice (and you should…)

• Auditing and alerting must be present against Active Directory and OS

• Track changes to groups which provide access into the DB

• Track changes to groups which provide administrative rights to OS

• Track changes to users with privileged access:

• Through any applications

• Into SQL Server itself

Server Level Access

• Use Server-Level Roles for privileged access:

• sysadmin

• User-defined role with granular security

• Don’t use securityadmin

• Permissions to watch for:

• CONTROL SERVER

• IMPERSONATE

Database Level Access

• Use roles for granting access

• Minimal permissions (principle of least privilege)

• Test permission scenarios (and have test results)

• Take into account how privileged accounts have implicit access

Secure Configuration – SQL Server

Starting with a Secure Configuration

• Build server template with baseline security configuration

• Deploy server using template

• Scripted SQL Server install with minimal features

• After install scripts to harden SQL Server

Policy Based Management

• Can target groups of SQL Servers

• Most settings available to all components of SQL Server

• Enforce or detect change to configuration

• Can choose how to implement enforcement

Other Ways to Maintain

• Custom Scripts

• 3rd Party Products

• Periodic Checks. Don’t Rely on initial setup and

PBM

– ALWAYS audit security

– Server settings important for compliance requirements

Secure Communication

• Don’t assume network is secure, even if it’s “internal.”

• Most larger organizations have large capture capability.

• Even if PHI data is encrypted in transit, other key information available.

• Secure communications with SQL Server:

• Server certificate – SSL / TLS

• IPSEC (OS level)

Secure Configuration - Data

Encrypting Data at Rest

• Easy Button: Transparent Data Encryption

• OS Options:

• Encrypting File System (not recommended)

• Bitlocker

• Don’t forget about backups

• TDE – native backups encrypted automatically

• Encrypted backups new feature as of SQL Server 2014

• Every major 3rd party solution supports backup encryption

• Storage personnel may argue against it. Auditors will be on your side.

Encrypting Data in the DB

• TDE and OS file level encryption don’t apply within SQL Server

• SQL Server has built-in encryption options if home grown

• Key management is a problem

• If SQL Server manages the keys then admins can see the data

• Always Encrypted is another option for home grown solutions

• Verify PHI data is encrypted

Speaking of Key Management

• With TDE, key management is crucial to recover the DB.

• Built-in encryption has key management challenges as well.

• Test your recovery scenarios extensively.

• Consider Extensible Key Management (EKM) solutions.

Auditing Access

Default Trace and Server Traces

• Default Trace runs by default

• Rolling capture of particular events

• Does capture schema change events

• Build Your Own Trace

• Use prior to Extended Events

• C2 audit mode

• Technically a trace

• Writes significant amounts of data

• Not recommended

• Deprecated

Extended Events

• Can audit for anything you should need

• Can be made as lightweight as possible

• Does require legwork to get right

• Doesn’t send information to OS event logs by default

• Easier solution: Audit objects

Audit Objects

• Two levels:

• Server

• Database (fine-grained)

• Track events at both levels

• Database level events:

• Can also grab SELECT queries (who is accessing the data)

• Don’t assume all access is through the application(s)

• Targets:

• File system

• Application event log

• Security event log (recommended)

What We Looked at Today

• Repeatable Processes (#3, #5)

• User Security (#4)

• Secure Configuration (#2, #5)

• Auditing Access (#1, #4)

Further “Print” Resources:IDERA whitepaper:

https://www.idera.com/resourcecentral/whitepapers/security-and-compliance-solutions-for-hipaa

Microsoft SQL Server Compliance whitepaper:

https://www.microsoft.com/en-us/download/details.aspx?id=6808

Experis Finance whitepaper:

http://www.experis.us/Website-File-Pile/Whitepapers/Experis/FIN_HIPAA-Complaince-with-SQL_050211.pdf

Securing SQL Server, Third Edition

Denny Cherry (book published by Syngress)