Use A Table-Top Privacy Breach Fire Drill to Protect Your Practice
A table-top privacy breach fire drill is a cost-effective way to prepare for a privacy and security incident in your healthcare organization. You should have a written privacy breach incident response plan in your healthcare practice. Have you practiced your response plan lately?
A table-top privacy breach fire drill allows your incident response team to rehearse their skills in a controlled exercise.
Do you remember your school days when every month or two you had a fire drill? The fire alarm would go off and everybody would go out the doors and very calmly go down the stairs and out the doors and into their muster point.
We take the same approach with privacy breach fire drills. Fires can happen at different times, places, and for different reasons. Whey you change the scenario, you develop alternate strategies or playbooks to best respond to the fire.
A privacy breach incident playbook contains all the actionable steps to take when a privacy beach incident occurs. Your playbook will have many ‘plays’ or actions to take when different types of privacy breach incidents occur. You could also think of it as a recipe book. You have many types of recipes to select from. Identify the ingredients that you have on hand (or the characteristics of the latest privacy incident) and select the most appropriate recipe to resolve the incident.
Healthcare providers, owners, and privacy officers hear about big privacy breaches on the news and hope it won’t happen to them. It keeps them up at night…because they know that properly preventing or managing a privacy breach is critical to the continued success of their business. Implementing a table-top privacy breach fire drill will help!
Picture this. You call a meeting of your incident response team. This may include your privacy officer, computer network support or managed services provider lead, physician, dentist, or other healthcare lead, your media spokesperson, and clinic manager. The privacy officer distributes a privacy breach incident scenario summarized on one page.
The team members read the scenario and then discuss what steps that they would take to respond to the privacy breach incident.
Using the 4 Step Response Plan as your playbook guideline, the incident response team note-keeper documents the hypothetical steps that the team takes to respond to the breach. Record the decisions, the resources, and the questions that you explore in this scenario.
When the table-top exercise is complete, you now have a detailed action steps that you can take when a similar privacy incident occurs in your healthcare practice.
How To Use The Table-Top Privacy Breach Fire Drill Technique
The goal of a privacy breach fire drill is to develop your playbook so you can spring into action when a similar privacy and security incident occurs in your healthcare practice.
First, identify a scenario that could happen in your practice. Unfortunately, it’s easy to find an example about a privacy and security breach in the news. Grab a privacy breach example and pull out the bits and pieces of the information that might apply to your organization. When you select scenarios that could happen in your organization the exercise is more meaningful for you, and you will develop tools and templates that are going to help you in the event that a very similar privacy and security incident happens in your organization.
Let’s use the recent privacy breach incident that came from the province of Saskatchewan* when a cybersecurity attack that happened in their E-Health system. This attack may have started when an employee who had authorized access to the e-health system used a personal tablet to connect with a USB to the Saskatchewan health authority’s computer. This enabled a virus from that personal tablet to infect the computer system and ultimately the e-health system, allowing millions of files to be stolen. Strip the example down to its key points. Create additional details and assumptions where needed to give the team members enough information to discuss the scenario during the fire drill exercise.
Step 1 Contain The Breach
The first step in every incident is to spot and stop the breach. Make an assumption that the employee who connected the personal device to your computer is now seeing that message on the screen that says that there's a virus in the system. One of your incident team members plays the role of the employee and completes Step 1 of the privacy breach incident response form and notifies their supervisor or the privacy officer.
Another team member assumes the role of the privacy officer and explains what their next action steps would be.
Record each action that you consider. Document each policy, resource, phone number and email address that you would use in a real event. This creates the action steps in your playbook.
Step 2 Evaluate the Risks
Discuss the risks that could affect the computer systems. What tools do you need to evaluate the harm of this incident? How might this affect patient care and the privacy of patient information?
Contact your vendors and ask them to contribute to the risk assessment in this scenario.
Who else might you want to call on for assistance to investigate this incident?
You might want to revisit the news item for additional information about the actions that were taken that you might also need to explore.
In your playbook, record good leading questions to help you to investigate the incident and evaluate the risks of harm.
Step 3 Notification
Strategize who you would notify about the incident. Prepare written notification to the custodians, patients, regulators and even media statements. These become templates in your playbook that you can quickly implement in your real event.
Role-play your media spokesperson being interviewed on the evening news. It’s much better to practice now, before you are in a crisis.
Step 2 Prevent the Breach From Happening Again
This might be the most valuable step in the privacy breach fire drill. Complete the privacy breach incident worksheet and summarize this practice scenario. Consider how likely this scenario could happen in your practice. What type of training could be done now to prevent this from happening? What tools or training do your incident response team members need today to make it easier for them to monitor and prevent this scenario from happening?
Fire-Drills Lead to a Confident Response
At the conclusion of this fire-drill, your team is ready, energized, and have the tools that they need to make sure that they can respond to that privacy and security breach as quickly as possible. This absolutely is a great investment in your time. These table-top privacy breach fire drills are a great demonstration of your commitment as an organization to ensure that you are protecting the privacy confidentiality and security of health information.
I hope that this privacy tip to help you do your tabletop privacy and security breach fire drills will be a value to your organization.
Do you need help to create your privacy breach management plan – and a mentor to help you get it done?
Check out the 4 Step Response Plan – tips, tools, templates, and training to help you create your privacy breach management plan!
*Reference:
Saskatchewan IPC finds ransomware attack results in one of the largest privacy breaches in this province involving citizens’ most sensitive data. January 8, 2021 – Ron Kruzeniski, Information and Privacy Commissioner. https://oipc.sk.ca/saskatchewan-ipc-finds-ransomware-attack-results-in-one-of-the-largest-privacy-breaches-in-this-province-involving-citizens-most-sensitive-data/
