Archive: Mar 2012

Evaluating Managed Service Providers’ PCI DSS Compliance

You need a managed service provider to outsource information technology services for your organization, but since you are in the payment card industry, they will need to be PCI DSS compliant. So you Google the service you need, compile a list of possible vendors, review their website and see that critical PCI DSS logo, so you are good-to-go, right? Maybe. The PCI Data Security Standard (“DSS”) is a set of information security standards published by the PCI Security Standards Council (“SSC”) for companies that store, process or transmit cardholder data. The PCI DSS includes twelve requirements that companies are required to implement in order to be PCI DSS compliant. When considering PCI DSS compliant service providers it is critical to understand which of their service offerings have been validated as PCI DSS compliant and which requirements were included in the assessment. If I had a nickel for every time a client said “they are PCI DSS so we are OK” I could buy a gallon of gas.

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Impact of the HITECH Act on HIPAA Compliance

The Health Insurance Portability and Accountability Act of 1996 ("HIPAA") introduced Privacy and Security regulations to protect protected health information (“PHI”). HIPAA was primarily directed at healthcare providers, health care clearinghouses or health plans (such as an insurance company), which are referred to as covered entities (“CE”). As part of the American Recovery and Reinvestment Act of 2009 the Health Information Technology for Economic and Clinical Health Act (“HITECH”) expanded the reach and penalties related to HIPAA compliance. Two of the key areas where HITECH impacts companies’ HIPAA compliance relate to the requirements of Business Associate (“BA”) and the requirement for federal breach reporting requirements for HIPAA CE’s and BA’s.

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Impact of the HITECH Act on HIPAA Compliance

The Health Insurance Portability and Accountability Act of 1996 ("HIPAA") introduced Privacy and Security regulations to protect protected health information (“PHI”). HIPAA was primarily directed at healthcare providers, health care clearinghouses or health plans (such as an insurance company), which are referred to as covered entities (“CE”). As part of the American Recovery and Reinvestment Act of 2009 the Health Information Technology for Economic and Clinical Health Act (“HITECH”) expanded the reach and penalties related to HIPAA compliance. Two of the key areas where HITECH impacts companies’ HIPAA compliance relate to the requirements of Business Associate (“BA”) and the requirement for federal breach reporting requirements for HIPAA CE’s and BA’s.

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ISAE 3402 – A Global Standard for a Global Marketplace

As companies emerge in an ever growing global economy newly adopted accounting principles and standards allow potential clients insight into the prospective organization.  The new globally accepted framework, International Standards for Assurance Engagements (ISAE) No. 3402, Assurance Reports on Controls at a Service Organization creates transparency and more clarity when reporting on controls at service organizations.  SAS 70, the standard used globally by many practitioners, was superseded because it had been showing its limitations for a number of years, due in large part that it was a U.S. based standard and was not always meeting the ever-growing and complex reporting requirements for international service organizations.

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