The $50,000 in penalties that the Office for Civil Rights (OCR) recently imposed on a health care provider in Idaho was due in part to allegations that the HIPAA covered entity had not conducted a risk assessment as required under the HIPAA privacy and security regulations. Of course, HIPAA is not the only law that requires a risk assessment. State laws, such as the Massachusetts data security regulations, contemplate and require a risk assessment in order to establish reasonable safeguards for personal information.
In short, this process involves examining what information the organization maintains, the nature of that information, how it moves through the organization and to/from its vendors, and the organization’s current set of safeguards in order to determine the vulnerabilities to that information in terms of privacy, security, accessibility and integrity. This process is critical to ensuring that privacy and security policies are appropriate for the organization. There are a number of resources to assist you in getting started – here are a couple:
Organizations that have performed risk assessements need to periodically re-evaluate their prior efforts based on changes in their business. So, whether your organization has not conducted a risk assessment, or it has been a few years since your last assessment, or there have been substantial changes in your business, this may be as good a time as any to make this a priority.