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2010-09-21 - (ISC)2 - Protecting patient privacy while enabling medical re…
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Presentation about maintaining privacy of patients, while harvesting aggregated data for improvement of patient treatment and scientiffic medical research.

Presentation about maintaining privacy of patients, while harvesting aggregated data for improvement of patient treatment and scientiffic medical research.

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  • These are the images we all get imprinted in our brain from pathology.This is in fact only a tiny portion of their work, the rest is dedicated to keep people of their tableThey are fighting a fight against the most deadly disseases in the world, including cancerIn most cases: a quicker and correct diagnoses greatly improves chances of survival (unlike House M.D.)
  • Non-identification makes opt-out more difficult
  • Unfortunatly, diagnosis is extremely complexThis raises questions that are crucial for a quick and correct diagnosis: for both prevention and correct diagnosis, there have to be statistics collected over the population.
  • “Upgrading” from a regular hospital to a university hospital or even a specialized hospital like the Antony van LeeuwenhoekMeans people move about 3 times....
  • Solution: reduce the resolution of data in order to protect patient privacy
  • Although we do have documented cases of opt-out, the level of information dumped on a patient does make you wonder...Some tumors are so rare that asking for them will result in 3 cases in the last 3 decades.
  • Although Technical Administrators can make themselves a part of the Application Administrators the technical implementation is such that it will be detected in the user management systems of the hosting party, and it will be logged.
  • Use two encrypted versions of the same text to break the cypher (please note that it really is a one-way hash...).
  • Use XML SEC (both AUTH and ENC)Chosen not to expose ZorgTTP to medical data....
  • Hash + Encryption
  • Please note that in the research database, the original Pseudonims are replaced by a number
  • When discussing design with developers, this role is unclear to many people.....
  • We need high availability for some systems, and just surviveability for somePlease note the location of the backups: it is at the remote location (i.e. not close to primary location)
  • Backups are challenging: it tends to cross the line unless you encrypt the database and its dumps

2010-09-21 - (ISC)2 - Protecting patient privacy while enabling medical re… Presentation Transcript

  • 1. Privacy and scientific research
    Enabling the battle against cancer while maintaining patient privacy
    Jaap van Ekris
    21 September 2010
  • 2. Jaap van Ekris
  • 3. Agenda
    What is Pathology
    Who is PALGA
    The privacy challenge
    A case of rebuilding central infrastructure
    Open ends...
    Slide 2
  • 4. Pathology as seen on TV...
  • 5. Stichting PALGA
    Foundation founded in 1971
    An official medical registration, as described in Dutch Privacy laws
    Helps pathologist connect to colleagues on a case-to-case basis, since medical relevancy for diagnosis is measured in decades
    Enabler for statistical medical research from Universities that can be observed through pathology reports
    Supports national policy development through: Dutch Cancer registration, Cervical and Breast Cancer Screening Programs, Health Care Evaluation and Epidemiological Research Survey
    National coverage since 1990
    Patients can opt-out through responsible pathology lab
    Slide 4
  • 6. Example scientific questions
    How effective is the cervix cancer screening program?
    Is there an effect of innoculations and specific types of cancer?
    Is there a relation between being born in the 1944 hunger winter and risk of colon cancer?
    Is there a relation between living in specific geographic locations or regions and the risk of cancer?
    What is the chance of a type of cancer re-occuring after treatment?
    Is there an increased risk of having another type of cancer when surviving a specific type of cancer?
    Slide 5
  • 7. Our privacy challenge
    We do notwant to know the patient’s identity
    Directly (name, adress, etc.)
    Indirectly (by combining information)
    We do want to correlate medical diagnosis across the lifetime of a subject:
    Patients change hospital when an illness escalates
    Current “health waiting list mediation” increases patient mobility
    People move
    Medical relevancy is about 20 years
    Slide 6
  • 8. Indirect identification is challenging
    Correlating information to real people by combining seemingly innocent information
    Researchers in the US have been able to corrolate real people with “innocent” information found on the internet using the US public survey data
    In the Netherlands we have less people per postal code than US citizens per zipcode
    Some illnesses or combination of illnesses are extremely rare
    Slide 7
  • 9. Organisational measures
    Patients can opt-out per investigation through pathology lab
    External privacy commission evaluates every request made. Judging:
    legality of a request
    balance between the medical relevancy and the potential impact on patient privacy
    privacy of the pathology employees and labs
    All personnel is screened and under non-diclosure contract (even external ones)
    Operational guidelines that aim to escalate requests that on hindsight might harm patient privacy
    Operational guidelines to prevent sharing any information that can be used for indirect identification
    Processes are audited every year
    Slide 8
  • 10. Slide 9
    Why rebuild?
    Technology used was 12 years old, without means to upgrade
    Contained End of Life technology on crucial spots (like file processing)
    Software was tied to dying hardware, reaching technical End Of Life
  • 11. Why completely re-engineer?
    Despite being fully compliant with privacy laws, we thought we could do better:
    Stronger pseudonimisation through a Trusted Third Party prevented mistakes (key collisions did occur too often)
    Create a better foundation for potential future requirements
    Better separation between maintenance personnel and operational users
    Better separation of concerns
    Isolate high-availability systems better
    Easier intermediate step towards national electronic patient files (EPD)
    Slide 10
  • 12. A first scetch
    Slide 11
  • 13. Fundamental design principles
    Patient identifying information is pseudonomised at the source
    All communication is encrypted and authenticated
    Any information is need to know basis only
    If you really need to know:
    You will only have to access to the data when absolutely necessary
    We log every access and every move on the data
    Only crucial information will be duplicated
    Slide 12
  • 14. Implications of this design
    Operational users will be granted access only to those databases they really require for their work, through controlled interfaces
    Application administrators:
    Will use adminstrative interface for day-to-day operations, blocking any data access
    Will only see data when they need to in order to troubleshoot issues
    Technical administrators will never see medical data at all
    Slide 13
  • 15. An overview
    Slide 14
  • 16. Seperation of goals
    Needed for a separation of concerns, as well as realizing availability demands
    Needed in order to prevent potential weakening of the pseudonyms
    We hope to turn off the direct patient care system someday...
    Slide 15
  • 17. Trust and encryption
    Slide 16
  • 18. Technical solution: pseudonimisation
    Remove patient identifying information without losing the ability to reconstruct a chain of medical episodes through history
    One-way hash of all patient-identifying information at the source
    Is nearly collision-proof identifyer for the coming future
    Is protected against name enumeration attacks
    Centralised systems don’t know the underlying algorithm, just see it as an externally controlled key
    Use different pseudonimization algorithms for different goals
    Slide 17
  • 19. Privacy effects
    Slide 18
  • 20. Role of ZorgTTP
    Second pseudonimisation of patient identifiers used for scientific research
    Allows for collaboration between medical registrations, providing there is legal clearance and the go-ahead privacy commission
    Provides a trusted route for medical researchers with identifying data, providing clearance of the privacy commission
    ZorgTTP is never exposed to medical data, only to “meaningless” identifiers
    Slide 19
  • 21. Aiming for targetted availability
    Slide 20
  • 22. A seperation of powers...
    Application management
    Access to database (only if required)
    Monitor application progress
    Responsible for data quality
    Technical management
    Management OS
    System backup management
    Responsible for user management
    Responsible for secure logging actions application management
    Slide 21
  • 23. Most challenging aspects
    Moving from old to new pseudonimisation without creating a permanent route for attacking current pseudonimisation
    Destruction of old data, especially on backups
    Moving hosting centers and to a new solution, without any disruption in service
    Slide 22
  • 24. Conclusion
    System is designed to conform to NEN7510
    Reduced identifying information as much as possible, without making the resulting data useless
    Minimised exposure of sensitive medical data
    Slide 23
  • 25. Open Ends
    We are there for 99%, still fighting for the last 1%
    Logging without creating information overload is challenging
    Decryption of data without being able to eavesdrop is extremely difficult
    Slide 24
  • 26. It is a delicate dynamic balance...
    Computing power increases, and thus the posibilities of indirect identification
    People themselves have become less stringent with personal information on the internet (Facebook, Twitter), unintentionally opening doors for indirect identification
    We all learn about new potential ways to attacks on privacy
    The public debate about what is considered an acceptable level of privacy still rages on
    Slide 25
  • 27. 26
    Safeguarding life, property and the environment
    www.dnv.com