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www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential
HIPAA workloads on AWS
Susovan Panja | Sr. DevOps EngineerPREPARED
BY:
www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential
</What is HIPAA ?>
Health Insurance Portability and
Accountability Act
❏ We are here to talk about the HIPAA compliance and not
about the act itself.
❏ What HIPAA compliance means to us as an industry.
❏ How can we achieve this (with AWS infra) ?
❏ Are we compliant ? How to measure this ?
www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential
</What is PHI?>
3
Protected Health Information
● Any health information that can be used to individually identify a person is considered as PHI.
● Information like diagnosis, prescriptions, treatment, national identification number, contact
number, emergency contact number, gender, ethnicity, names are considered as protected
information under PHI.
● Information like education details or employment records are not considered as PHI.
● You can go to the below link to see what all information is considered as PHI.
https://www.hipaajournal.com/what-is-considered-protected-health-information-under-hipaa/
www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential
</What is HIPAA compliance? >
4
● It is designed to ensure the availability and protection of PHI.
● It can be broken down into two rule sets:
HIPAA Security Rule: It demands that safeguards be implemented to ensure the confidentiality, integrity, and
availability of PHI
HIPAA Privacy Rule: It places limits on the uses and disclosures of PHI.
● It requires the entities to notify patients in case of a data breach that included their PHI as well as the OCR (Office
for Civil Rights) and the media if the breach affects more than five hundred patients.
● Health Information Technology for Economic and Clinical Health Act (HITECH) expanded the HIPAA rules in
2009. HIPAA and HITECH together establish a set of federal standards intended to protect the security and privacy
of PHI.
● Health Information Trust Alliance (HITRUST) Common Security Framework (CSF): The HITRUST CSF serves
to unify security controls from federal law (such as HIPAA and HITECH), state law, and non-governmental
frameworks (such as the PCI Security Standards Council) into a single framework that is tailored for healthcare
needs.
www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential
</AWS as HIPAA compliant service provider>
5
● There is no HIPAA certification for a cloud service provider (CSP) such as AWS.
● The Business Associate Addendum (BAA) is an AWS contract that is required under HIPAA rules to
ensure that AWS appropriately safeguards protected health information (PHI).
● Customers may use any AWS service in an account designated as a HIPAA account, but they should
only process, store, and transmit protected health information (PHI) in the HIPAA-eligible services
defined in the Business Associate Addendum (BAA).
● Just by utilizing HIPAA eligible services on AWS you product/service does not become
automatically HIPAA compliant.
● If you are selling your SaaS service to other companies/entities, you need a separate BAA with each
of them individually.
www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential
</How to achieve HIPAA compliance on AWS ?>
6
(Database
service): Multi-AZ
setup with read
replica in a
different AZ also
we can have read
replicas in
different region.
RDS
(Application
servers): Enable
Auto-Scaling
Group with AZ-
Rebalance.
EC2
S3 (for static files
/ frontend UI):
Multi region sync
buckets
S3 Use Cluster mode
with multi-AZ
Use Cluster mode
with multi-AZ
Elasticache
Use ALB in front of
app servers to
have uninterrupted
availability of your
service.
ALB
Availability
www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential
</How to achieve HIPAA compliance on AWS ?>
7
Security
● IAM: Use IAM to create users/roles with least privileges who can access your infrastructure.
● VPC/Subnets: Create custom VPC and private subnets and put your PHI processing/storing
resources inside private subnets (like app servers, database).
● NACL: Create NACL rules to filter what traffic can flow into your subnets.
● SG: Use S to restrict which resource can interact with which service.
● Encryption in Transit: Use secure endpoints (TLS enabled) for all services like S3, RDS, elastic-
cache, ALB, ALB to EC2, API gateways.
● Encryption at rest: The location where PHI information is stored should be encrypted too. Like S3
bucket, EBS volumes, RDS, elastic-cache (enable default encryption).
www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential
</How to achieve HIPAA compliance on AWS ?>
8
Enable VPC flow
logs, it provides us
a audit trail of
accepted or
rejected
connections.
VPC Flow logs
It records and monitors all
the changes made on your
infrastructure. Its enabled by
default but data retention is
only 7 days. The S3 bucket
used to store cloudtrail
should be encrypted.
Preferability the bucket
should be in another
account with very restricted
access.
It provides a
detailed view of all
the resources
associated with a
AWS account like
number of EC2
instances, RDS,
VPC, subnets etc.
Application logs
can be stored in
Cloudwatch Logs
for application
auditing purposes.
Cloudtrail AWS Config Cloudwatch Logs
Auditability
www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential
</Are we HIPAA compliant?>
9
Benchmarking our infrastructure
www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential
Thank You
www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©

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HIPAA Workloads on AWS (Amazon Web Services)

  • 1. www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential HIPAA workloads on AWS Susovan Panja | Sr. DevOps EngineerPREPARED BY:
  • 2. www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential </What is HIPAA ?> Health Insurance Portability and Accountability Act ❏ We are here to talk about the HIPAA compliance and not about the act itself. ❏ What HIPAA compliance means to us as an industry. ❏ How can we achieve this (with AWS infra) ? ❏ Are we compliant ? How to measure this ? www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
  • 3. www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential </What is PHI?> 3 Protected Health Information ● Any health information that can be used to individually identify a person is considered as PHI. ● Information like diagnosis, prescriptions, treatment, national identification number, contact number, emergency contact number, gender, ethnicity, names are considered as protected information under PHI. ● Information like education details or employment records are not considered as PHI. ● You can go to the below link to see what all information is considered as PHI. https://www.hipaajournal.com/what-is-considered-protected-health-information-under-hipaa/ www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
  • 4. www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential </What is HIPAA compliance? > 4 ● It is designed to ensure the availability and protection of PHI. ● It can be broken down into two rule sets: HIPAA Security Rule: It demands that safeguards be implemented to ensure the confidentiality, integrity, and availability of PHI HIPAA Privacy Rule: It places limits on the uses and disclosures of PHI. ● It requires the entities to notify patients in case of a data breach that included their PHI as well as the OCR (Office for Civil Rights) and the media if the breach affects more than five hundred patients. ● Health Information Technology for Economic and Clinical Health Act (HITECH) expanded the HIPAA rules in 2009. HIPAA and HITECH together establish a set of federal standards intended to protect the security and privacy of PHI. ● Health Information Trust Alliance (HITRUST) Common Security Framework (CSF): The HITRUST CSF serves to unify security controls from federal law (such as HIPAA and HITECH), state law, and non-governmental frameworks (such as the PCI Security Standards Council) into a single framework that is tailored for healthcare needs. www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
  • 5. www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential </AWS as HIPAA compliant service provider> 5 ● There is no HIPAA certification for a cloud service provider (CSP) such as AWS. ● The Business Associate Addendum (BAA) is an AWS contract that is required under HIPAA rules to ensure that AWS appropriately safeguards protected health information (PHI). ● Customers may use any AWS service in an account designated as a HIPAA account, but they should only process, store, and transmit protected health information (PHI) in the HIPAA-eligible services defined in the Business Associate Addendum (BAA). ● Just by utilizing HIPAA eligible services on AWS you product/service does not become automatically HIPAA compliant. ● If you are selling your SaaS service to other companies/entities, you need a separate BAA with each of them individually. www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
  • 6. www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential </How to achieve HIPAA compliance on AWS ?> 6 (Database service): Multi-AZ setup with read replica in a different AZ also we can have read replicas in different region. RDS (Application servers): Enable Auto-Scaling Group with AZ- Rebalance. EC2 S3 (for static files / frontend UI): Multi region sync buckets S3 Use Cluster mode with multi-AZ Use Cluster mode with multi-AZ Elasticache Use ALB in front of app servers to have uninterrupted availability of your service. ALB Availability www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
  • 7. www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential </How to achieve HIPAA compliance on AWS ?> 7 Security ● IAM: Use IAM to create users/roles with least privileges who can access your infrastructure. ● VPC/Subnets: Create custom VPC and private subnets and put your PHI processing/storing resources inside private subnets (like app servers, database). ● NACL: Create NACL rules to filter what traffic can flow into your subnets. ● SG: Use S to restrict which resource can interact with which service. ● Encryption in Transit: Use secure endpoints (TLS enabled) for all services like S3, RDS, elastic- cache, ALB, ALB to EC2, API gateways. ● Encryption at rest: The location where PHI information is stored should be encrypted too. Like S3 bucket, EBS volumes, RDS, elastic-cache (enable default encryption). www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
  • 8. www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential </How to achieve HIPAA compliance on AWS ?> 8 Enable VPC flow logs, it provides us a audit trail of accepted or rejected connections. VPC Flow logs It records and monitors all the changes made on your infrastructure. Its enabled by default but data retention is only 7 days. The S3 bucket used to store cloudtrail should be encrypted. Preferability the bucket should be in another account with very restricted access. It provides a detailed view of all the resources associated with a AWS account like number of EC2 instances, RDS, VPC, subnets etc. Application logs can be stored in Cloudwatch Logs for application auditing purposes. Cloudtrail AWS Config Cloudwatch Logs Auditability www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
  • 9. www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential </Are we HIPAA compliant?> 9 Benchmarking our infrastructure www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©
  • 10. www.sourcefuse.com | Copyright © 2018 SourceFuse | Private and Confidential Thank You www.sourcefuse.com | Copyright 2019 SourceFuse | Private and Confidential©

Editor's Notes

  1. Lambda Step Functions SQS Cloudwatch RDS (Postgres) X-Ray
  2. Lambda Step Functions SQS Cloudwatch RDS (Postgres) X-Ray