Disadvantages of Spreadsheets – Obstacles to Compliance in the Healthcare Industry

Most of the regulatory compliance issues we talked about concerning spreadsheets have been related to financial data. But there are other kinds of data that are stored in spreadsheets which may also cause regulatory problems in the future.

In the US, a legislation known as HIPAA or Health Insurance Portability and Accountability Act is changing the way health care establishments and practitioners handle patient records. The HIPAA Privacy Rule is aimed at protecting the privacy of individually identifiable health information a.k.a. protected health information (PHI).

Examples of PHI include common identifiers like a patient’s name, address, Social Security Number, and so on, which can be used to identify the patient. HIPAA covers a wide range of health care organisations and service providers, including: health plan payers, health care clearing houses, hospitals, doctors, dentists, etc.

To protect the confidentiality, integrity, and availability of PHI, covered entities are required to implement technical policies such as access controls, authentication, and audit controls. These can easily be implemented on server-based systems.

Sad to say, many health care organisations who have started storing data electronically still rely on spreadsheet-based systems. Those policies are hard to implement in spreadsheet-based systems, where files are handled by end-users who are overloaded with their main line of work (i.e. health care) and have very little concern for data security.

In some of these systems, spreadsheet files containing PHI may have multiple versions in different workstations. Chances are, none of these files have any access control or user authentication mechanism whatsoever. Thus, changes can easily be made without proper documentation as to who carried out the changes.

And because the files are normally easily accessible, unauthorised disclosures – whether done intentionally or accidentally – will always be a lingering threat. Remember that HIPAA covered entities who are caught disclosing PHI can be fined from $50,000 up to $500,000 plus jail time.

But that’s not all. Through the HITECH Act of 2009, business associates of covered entities will now have to comply with HIPAA standards as well. Business associates are those companies who are performing functions and services for covered entities.

Examples of business associates are accounting firms, law firms, consultants, and so on. They automatically need to comply with the standards the moment they too deal with PHI.

 

More Spreadsheet Blogs

 

Spreadsheet Risks in Banks

 

Top 10 Disadvantages of Spreadsheets

 

Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry

 

How Internal Auditors can win the War against Spreadsheet Fraud

 

Spreadsheet Reporting – No Room in your company in an age of Business Intelligence

 

Still looking for a Way to Consolidate Excel Spreadsheets?

 

Disadvantages of Spreadsheets

 

Spreadsheet woes – ill equipped for an Agile Business Environment

 

Spreadsheet Fraud

 

Spreadsheet Woes – Limited features for easy adoption of a control framework

 

Spreadsheet woes – Burden in SOX Compliance and other Regulations

 

Spreadsheet Risk Issues

 

Server Application Solutions – Don’t let Spreadsheets hold your Business back

 

Why Spreadsheets can send the pillars of Solvency II crashing down

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The Rights of Individuals Under The General Data Protection Regulation

The General Data Protection Regulation or GDPR is a European Union law reinforcing the rights of citizens concerning the confidentiality of their information, and confirming that they own it. We thought it would be interesting to examine the GDPR effective 25 May 2018 from an Irish citizen?s perspective. This article is a summary of information on the Data Protection Commissioner?s website, but as viewed through a businessperson?s lens.

How the Office Defines Data Protection

The Office believes that organisations receiving personal details have a duty to keep them private and safe. This applies inter alia to information that individuals supply to government, financial institutions, insurance companies, medical providers, telecoms services, and lenders. It also applies to information provided when they open accounts.

This information may be on paper, on computers, or in video, voice, or photographic records. The true owners of this information, the individuals have a right:

  • To make sure that it is factually correct
  • To the assurance that it is shared responsibly
  • That all with access only use it for stated purposes

Any organisation requesting personal information must state who they are, what the information is for, why they need to have it, and to whom else they may provide it.

Consumer Rights to Access Their Personal Information

Private persons have a right under the GDPR to a copy of all their information held or processed by a business. The regulation refers to such businesses as ?data controllers? as opposed to owners, which is interesting. They have to provide both paper and digital data, and ‘related information?.

Data controller fees for this are discretionary within limits. The request may be denied under certain circumstances. The data controller may release information about children to parents and guardians, only if it considers a minor too young to understand its significance. Other third parties such as attorneys must prove they have consent.

Consumer Rights to Port Their Data to Different Services

Since the personal information belongs to the individual, they have a right not only to access it, but also to copy or move it from one digital environment to another. The GDPR requires this be ?in a safe way, without hindrance to usability?. An application could be a banking client that wants to upload their transaction history to a third party price comparison website.

However, the right to data portability only applies to data originally provided by the consumer. Moreover, an automated method must be available for porting. Data controllers must release the information in an open format, and may not charge for the porting service.

Consumer Rights to Complain About Personal Data Abuse

Individuals have a right under the General Data Protection Regulation to have their information rectified if they discover errors. This right extends to an assurance that third parties know about the changes – and who these third party entities are. Data controllers must respond within one month. If they decline the request, they must inform the complainant of their right to further remedial action.

If a data controller refuses to release personal information to the owner, or to correct errors, then the Data Protection Office has legal power to enforce the consumer?s rights. The complainant must make full disclosure of the history of their complaint, and the steps they have taken themselves to attempt to set things right.

Further Advice on Getting Things Ready for 25 May 2018

The General Data Protection Regulation has the full force of law from 25 May 2018 onward, and supersedes all applicable Irish laws, regulations, and policies from that date. We recommend incorporating rights of data owners who are also your customers into your immediate plans. We doubt that forgetting to do so will cut much sway with the Data Commissioner. Remember, you have one month to respond to consumer requests, and only one more month to close things out subject to the matter being complex.

IT Systems Implementation

Are you ready to find out how your newly accepted IT system fares in the real world? Although a rigorous Acceptance testing process can spot a wide spectrum of flaws in a newly constructed IT system, there is no way it can identify all possible defects. The moment the IT system is delivered into the hands of actual end users and other stakeholders, it is effectively stepping out of a controlled and secure environment.

Thus, it is during this phase wherein issues having direct impact on the business can arise.

It is our duty to ensure that the Systems Implementation phase is carried out as thoroughly, professionally, and efficiently as possible.

Thoroughly, because we need to include all relevant data and other deliverables, eliminate hard-to-detect miscalculated results, and substantially reduce the probability of business and mission critical issues popping up in the future;

Professionally, because it is the best way to address the sensitive process of turning over a new system to users who have gotten used to the old one;

And efficiently, because we want to minimise the duration over which all stakeholders have to adapt to the new system and allow them to move on to the process of growing the business.

Preparation

Louis Pasteur once said, “Luck favours the mind that is prepared.”

While we certainly won’t leave anything to chance, we do put substantial weight on the Preparation stage of Systems Implementation. We’re so confident with the strategies we employ in Preparation, that we can assure you of an utterly seamless Deployment and Transition phase.

By this we mean that issues that may arise during Deployment and Transition will be handled smoothly and efficiently because your people will know exactly what to do.

Here’s how we will prepare your organisation for Deployment:

  • Identify all key players for the Systems Implementation phase and orient them on their specific roles. We’ll make sure they know what possible hitches may come their way and how to deal with them.
  • Identify all end users and their corresponding functions, then assign appropriate access rights.
  • Draw multi-layered contingency plans to capture and address each possible concern that may crop up during Deployment.
  • Prepare a systematic step-by-step procedure and checklist for the entire Deployment stage. Both of them should have been copied from a similar procedure and checklist used in the Acceptance testing phase.
  • Make all stakeholders understand the conditions required before Deployment can commence.
  • Set the appropriate environment so that all stakeholders know what to expect and when to expect them the moment Deployment commences.
  • Prepare Technical Services and Technical Support personnel for the gruelling mission ahead.
  • Make sure all communication processes are well coordinated so that everyone affected will know who to contact and how to get in touch with them when a problem arises.
  • Plan and schedule training sessions so that they can be conducted “just in time”. Training sessions conducted way ahead of Deployment are often useless because the trainees tend to forget about what they learned when the time comes to apply them. Similarly, training sessions conducted way after Deployment also become useless because trainees are seldom able to internalise instructions delivered during crash courses.

Deployment

There are two sets of issues to keep an eye on during Deployment:

  1. Issues directly related to the technology itself, e.g. application functionality and data integrity, and
  2. Issues emanating from the end users, i.e., their unwillingness to use the new system. One reason may be because they find the interface and procedures too confusing. Another would be due to other inconveniences that come with adapting to a new set of procedures.

Despite all the meticulous scrutiny employed during Acceptance testing, there are just some problems that are made obvious only during Deployment. Issues belonging to the first set are dealt with easily because of the plans and procedures we put in place during the Preparation stage. As an added measure, our team will be on hand to make sure contingency plans are executed accordingly.

While the second set of issues is often neglected by many IT consultancy companies, we choose to meet it head on.

We fully understand that end users are most sensitive to the major changes that accompany a new system. It is precisely for this reason why our training activities during Deployment are designed not only to educate them but also to make them fully appreciate the necessity of both the new system and the familiarisation phase they will need to go through.

The faster we can bring your end users to accept the new system, the faster they can refocus on your company’s business objectives.

Here’s what we’ll do to guarantee the smoothest Deployment process you’ve ever experienced.

  • Employ the procedure and checklist formulated during the Preparation stage.
  • Ensure all end users are well acquainted with any additional tasks they would need to perform (e.g. filling up manual logs).
  • Assess which legacy systems can still be used alongside the new technology and which ones have to be retired.
  • Supervise the installation and optimal configuration of all supporting hardware and software to make sure the likelihood of errors originating from them are brought to near-zero levels.
  • Supervise the installation and optimal configuration of the products themselves.
  • Carry out data migration tasks if necessary.
  • Organise and oversee parallel runs to check for data and report inconsistencies.
  • Conduct training sessions in a professional and well-timed manner to eliminate end-users’ feelings of agitation and to take advantage of memory absorption and retention duration as with regards to their assigned duties and responsibilities.

Transition

Do you often feel uneasy whenever the reins to a newly purchased IT system are handed over to you? Perhaps there are some issues that you feel haven’t been fully settled but, at the same time, find it too late to back out, having already invested so much time and resources.

Alright, so maybe the thought of “backing up” never crossed your mind. However, the concern of being “not yet ready” is raised by many organisations towards the tail end of most Deployment stages. This usually drags the Deployment stage into a never-ending process.

Our team of highly experienced specialists will make sure you reach this point with utmost confidence to proceed on your own.

To wrap up our comprehensive IT Systems Implementation offering, we’ll take charge of the following:

  • Verify that all deliverables, including training materials and other technical documentation, are accomplished and expected outcomes are realised.
  • Make sure all technical documentation are placed in a secure and accessible location.
  • Institute best practices to ensure the IT system becomes fully utilised and to reduce its exposure to avoidable risks.
  • Establish open communication lines with the Technical Support team to enable quick resolution of issues.
  • Ensure complete knowledge transfer has been fully achieved so that your people will spend less time calling Technical Support and more on operations contributory to business growth.
EcoVaro ? ESOS Solution on a Cloud

The UK?s Energy Saving Opportunity Scheme ? and all others in the EU stable – is bound to generate huge quantities of data beyond the reach of processing on standalone computers. This leaves some companies in the mandatory sector between a rock and a hard place. They already have to divert scarce talent to draft compliance reports. Now they face purchasing equipment with big data processing power.

The more astute are turning to cloud computing solutions like EcoVaro in increasing numbers. They are also keen to benefit from remote secure backup. .

Increasing migration to public clouds has caused a growth in niche big data consultants. EcoVaro is one of these. We want to do more than simply open up a port and leave you to become familiar with our technology. We service a growing group of companies who want us to analyse their energy usage reports, and isolate the main demand drivers so they know where to start saving.

We are consumer-centric energy consultants with the emphasis on corporates and sme?s. We offer more than just big data processing facilities. We also help set up your dashboard and are full of practical ideas you can use to start trimming energy costs right away. So please treat us as your affordable energy partner who really wants to help.

Finally, contact EcoVaro for a discussion.

Contact Us

  • (+353)(0)1-443-3807 – IRL
  • (+44)(0)20-7193-9751 – UK

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