Table of contents exchange of letters with the minister executive summary


A clear policy on measures to secure the confidentiality, integrity



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Report of the COI into the Cyber Attack on SingHealth 10 Jan 2019
44.1 A clear policy on measures to secure the confidentiality, integrity
and accountability of electronic medical records must be
formulated
1027. The HITSPS is silent on the issue of measures (generally) to protect the confidentiality, integrity and accountability of EMR.
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The HITSPS relates only to a narrow subset of sensitive information and even then, provides very little detail on control measures for sensitive information.
1028. Given the importance and sensitivity of the PII contained in EMR, it is important to have a comprehensive policy document that applies to the protection of EMR. This policy must document and make clear the measures that are in place to protect the EMR. We elaborate on some key measures that should be addressed in the policy, in the following sections.
44.1.1
Role-based access for front-end users
1029. The policy should provide for limits on access, and provide screening controls so that only authorised staff can access patient data. Role-based access Confidentiality means the property that data or information is not made available or disclosed to unauthorised persons or processes. Integrity means the property that data or information have not been altered or destroyed in an unauthorised manner.
93 45 CFR (US) § 164.306: Security Standards General rules, of the US. Health Insurance Portability and Accountability Act of 1996 (HIPAA), that provides data privacy and security provisions for safeguarding medical information.
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COI investigations did not uncover any other policy document covering this issue either.



COI Report – Part VII
Page 356 of 425

control helps to restrict EMRs to users who are made members of a certain role according to their responsibilities (e.g. doctor, nurse, clinician etc) or corporate position. Role-based access is already in place, but the classes of persons to whom access is granted, the extent of the access granted, should be reviewed as part of the wider post-Cyber Attack review. The Committee notes SingHealth’s perspective that the “implementation of IT projects is meant to serve, support and
improve patient care, and that an appropriate balance will have to be struck
when assessing the feasibility of IT projects”.
1030. The policy must establish clear access controls including a)
Role-based security that restricts access to information based on pre-established categories of patients, duties and documents based on specific job requirements of the user and b) Tagging of sensitive data with status indicators that enable restriction of identified patients and encounters to only those with permissions to access such data.
1031. In short, the policy should follow the principle of least access – that is, staff should have access only to the resources they need to perform their daily tasks, and no more. Access to confidential data should be on a strict, need-to- know basis. Further, there should be no general access to patient data – staff should only be able to access the data when they need it fora specific purpose, and the scope of the data accessed should be tightly controlled to include only data essential to the completion of the task.
44.1.2
Database-level access by administrators, developers and support team
1032. Security measures should not only be geared towards external attackers – there is areal risk of patient data being compromised by insiders too. We recommend that the need for administrators, developers and support team to access patient data be reviewed. IHiS should aim for the least number of people possible to have access to the database. To the maximum extent possible,



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