HHS & Breach Disclosure

by adam on February 6, 2013

There’s good analysis at “HHS breach investigations badly backlogged, leaving us in the dark

To say that I am frequently frustrated by HHS’s “breach tool” would be an understatement. Their reporting form and coding often makes it impossible to know – simply by looking at their entries – what type of breach occurred. Consider this description from one of their entries:

“Theft, Unauthorized Access/Disclosure”,”Laptop, Computer, Network Server, Email”

So what happened there? What was stolen? Everything? And what types of patient information were involved?

Or how about this description:

“Unauthorized Access/Disclosure,Paper”

What happened there? Did a mailing expose SSN in the mailing labels or did an employee obtain and share patients’ information with others for a tax refund fraud scheme? Your guess is as good as mine. And HHS’s breach tool does not include any data type fields that might let us know whether patients’ SSN, Medicare numbers, diagnoses, or other information were involved.

What can I say but, I agree?

Disclosures should talk about the incident and the data. Organizations are paying the PR cost, let’s start learning.


The incident should be specified using either the Broad Street taxonomy (covered in the MS Security Intel Report here) or Veris. It would be helpful to include details like the social engineering mail used (so we can study tactics), and detection rates for the malware, from something like VirusTotal.

For the data, it would be useful to explain (as Dissent says) what was taken. This isn’t simply a matter of general analysis, but can be used for consumer protection. For example, if you use knowledge-based backup authentication, then knowing that every taxpayer in South Carolina has had their addresses exposed tells you something about the efficacy of a question about what address you lived in in 2000. (I don’t know if that data was exposed in the SC tax breach, I’m just picking a recent example.)

Anyway, the post is worth reading, and the question of how we learn from breaches is worth discussing in depth.

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