The other day I posted an overview of the new OpenClinica Optimized Hosting offering. Since then we have received requests for more detail on how we secure the data in a customer’s OpenClinica instance against unauthorized access. This is obviously a very important topic!
The particular questions were asked in the context of HIPAA–particularly the HIPAA Security Rule–and the answer below is framed in this context. But even if HIPAA is not relevant to you (because you have no PHI in your OpenClinica instance, you’re not part of a covered entity, or you’re outside the U.S.), the safeguards described below are generally applicable best practices and can be applied in the context of most security compliance/regulatory regimes.
In general the requirements of the HIPAA Security Rule can be summed up as:
- Ensure the confidentiality, integrity, and availability of all e-PHI you create, receive, maintain or transmit;
- Identify and protect against reasonably anticipated threats to the security or integrity of the information;
- Protect against reasonably anticipated, impermissible uses or disclosures; and
- Ensure workforce compliance.
Adhering to these requirements is generally demonstrated via a risk analysis that determines reasonable and appropriate security measures for protecting ePHI, and implementing administrative and technical safeguards consistent with the risk analysis (see http://www.hhs.gov/ocr/privacy/hipaa/understanding/srsummary.html for more info). These safeguards may include:
- Implement security measures that reduce risks and vulnerabilities to a reasonable and appropriate level.
- Limit uses and disclosures of PHI to the “minimum necessary.”
- Appropriate training, authorization, and supervision of workforce members who work with e-PHI
- Regular review and evaluation
- Implement technical policies and procedures that allow only authorized persons to access electronic protected health information.
- Ensure that e-PHI is not improperly altered or destroyed. Electronic measures must be put in place to confirm that e-PHI has not been improperly altered or destroyed.
- Implement technical security measures that guard against unauthorized access to e-PHI that is being transmitted over an electronic network.
So how do we do this? Many of these safeguards have long been in place as part of the SOPs and other controls we have for our staff and suppliers. The OpenClinica application itself enforces controls such as password policies, audit history, role based access control, and user access log. On top of these safeguards, what’s notable with OpenClinica Optimized Hosting are the specific controls surrounding this new hybrid/cloud-based hosting environment. Below are excerpts of our new Standard Operating Procedure associated with OpenClinica Optimized Hosting. The full SOP and supporting documentation are available as part of a compliance audit.
Excerpt from SOP-SA002 – Managing Hosted OpenClinica
7.1.1 Access to any customer instance is limited, via login credentials, to authorized customer users for the web interface only. Customers have no access to the server itself [except through defined application and programmatic interfaces].
7.1.2 All OpenClinica employees are granted access only to computer and networking areas necessary to perform their duties.
7.1.3 Each customer’s installation is separate, and cannot be accessed from any other customer installation.
7.1.4 Connection to a hosted instance is encrypted by means of secure socket layer.
7.1.5 Application server and database server are secured via firewall, hardened to remove nonessential access credentials, and strong password compliance.
7.1.6 Hosted systems are constantly monitored for latencies and intrusion.
7.2.1 Installation qualification is performed on initial setup of the OpenClinica Optimized Hosting environment image, and documented in an IQ Report. Qualification items are checked by inspection, review of vendor documentation, or direct testing as appropriate; items are specified in the Installation Qualification Protocol.
7.2.2 Installation qualification for each customer instance is performed when configuring that instance, and is documented in an IQ Report. Qualification items are checked by inspection, or direct testing as appropriate.
We conduct qualification of our own IT practices and our data center provider to assure security, reliability, availability, performance, and data protection within our hosted services. Items reviewed include:
- Data Center physical security procedures
- Data center HVAC, power conditioning, and fire suppression systems
- Disaster prevention and disaster recovery processes
- Back-up and data retention procedures
- Network redundancy
- SSL certificate (encryption)
- System and network monitoring (for latencies, intrusion, and failure prediction)
- Load balancing
Our data center has a SAS 70 Type II security certification, a well known security certification that originated from financial industry compliance requirements and aligns well with the requirements of the clinical trials industry. We regularly audit their policies and procedures in the context of our quality system, including review of the SAS 70 Type II audit report they provide. Our data center assures secure and reliable operation in part by maintaining appropriate physical resources at the facility. Fire suppression, conditioned power, and redundant HVAC all protect computing equipment against damage from extreme conditions, while physical access security and surveillance guard against unauthorized intrusion. The full report is available for our customers to review as part of a compliance audit.
The above are some highlights of our multi-tier strategy to ensure the highest level of security of critical clinical data while maintaining accessibility and ease-of-use. Like any good security strategy, we treat it within the company as a dynamic function, subject to regular review and assessment. We recognize our strategy must always be evolving to respond to emerging threats and new requirements. At the end of the day it is the combination of process and technology controls, and subjecting these controls to continual scrutiny, that leads to strong security.
– Cal Collins