When your organization is building a security program, clear direction must come from the Executive level to guide management and staff in implementing the right solutions. Without a greater understanding of the organization’s direction, management lacks the proper knowledge to make decisions in the best interests of the organization. In much the same way, a security program needs the proper structure of controls in place to guide the organization at the lower levels of the workforce.
A security control is “any administrative, management, technical or legal method that is used to manage risk.”1 Once your organization has identified areas of need, whether because of security or compliance concerns, controls are the tools used to correct the problem or fill the gap. These tools can consist of staff members, physical or technical measures, procedures, or governance. As Kim Sassaman explains, “Implementation of information technology security controls is how the Security Program is put into operation.”1 When deciding on a control to deploy, the decision needs to be part of a risk analysis or risk management process; each type of control must exist for a specific reason, hopefully filling multiple needs at once.
Some examples of controls include door locks, ID badges, firewalls, encryption, policies, procedures, and oversight committees. One of the most glaring results of the OCR KPMG Audit Program was that nearly 80% of Covered Entities were lacking a formal risk analysis, the very first step in determining the proper controls for your organization!2 And if you haven’t heard about some of the most recent data breaches, many of them have been caused by a lack of encryption or media disposal controls. These issues and more can be resolved with a proper security program supported by security controls outlined in organization policies.
Contact RISC Management if you need help developing a security program or implementing controls. Remember, the first step is always a Risk Analysis. If you don’t identify, analyze, and document your risk, you’ll never effectively manage it.
- Implementing Information Security in Healthcare: Building a Security Program
- “Preparing for HIPAA Compliance Audits.” Healthcare Info Security Website