New HIPAA Rules: Impact on Business Associates

As I read the “Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules under the Health Information Technology for Economic and Clinical Health Act and the Genetic Information Nondiscrimination Act; Other Modifications to the HIPAA Rules” recently released by the Department of Health and Human Services, I struggled to think how to summarize the 563 page PDF document into a meaningful summary for A-LIGN’s clients.  The title alone is a paragraph long.  A large part of the document is minutia that is not relevant for the everyday conversation on how to protect electronic protected health information (“ePHI”) but there are some key points and clarifications that are made which I believe should be understood by our clients.  As a provider of audit, compliance and security services primarily to companies defined as service organizations or service providers, I will focus on two key points that impact service organizations that handle ePHI, applicability and liability.

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PCI Security Standards Council Releases New Information Supplement on Cloud Computing

In February the PCI Security Standards Council (the “Council”) released a new information supplement related to the application of the Payment Card Industry Data Security Standards (“PCI DSS”) requirements in the Cloud. The goal of the information supplement is to assist Merchants and Cloud Service Providers (“CSP”) maintain PCI DSS compliant environments and also to guide the Qualified Security Assessors (“QSA”) that are tasked with performing the validation assessments.

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PCI Security Standards Council Releases New Information Supplement on Cloud Computing

  By: Gene Geiger, Partner of A-lign Security and Compliance Services In February the PCI Security Standards Council (the “Council”) released a new information supplement related to the application of the Payment Card Industry Data Security Standards (“PCI DSS”) requirements in the Cloud. The goal of the information supplement is to assist Merchants and Cloud Service Providers (“CSP”) maintain PCI DSS compliant environments and also to guide the Qualified Security Assessors (“QSA”) that are tasked with performing the validation assessments.

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Preparing your Collection Agency for the CFPB Examination

By: Neil Gonsalves, Director at A-LIGN OVERVIEW On October 24, 2012 the Consumer Financial Protection Bureau (CFPB) published a rule that would allow the CFPB to federally supervise the larger consumer debt collectors/collection agencies. One of the main objectives of the CFPB Examination is to ultimately help ensure that consumers that are affected by the debt collection process are treated fairly. The CFPB’s supervision authority over these debt collectors/collection agencies took effect on January 2, 2013. Under the rule, any firm that has more than $10 million in annual receipts from consumer debt collection activities are subject to the CFPB’s supervisory authority. The CFPB may adopt a risk based approach focusing on debt collectors/collection agencies that pose a heightened risk to consumers based on information available from regulators, complaints, litigation, and media among other sources.

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Ask A-LIGN: What is the difference between a SOC logo and a SOC seal?

By: Scott Price, Managing Partner of A-LIGN  Answer: Misuse of Service Organization Control (SOC) terminology is a common mishap in the marketplace. When it comes to the use of the SOC logo or seal, many tend to assume the terms mean the same thing (six of one, half a dozen of the other), but in reality they are classified as entirely different entities. Let me explain…

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Ask A-LIGN: What is the difference between a Penetration Test and a Vulnerability Assessment?

A square is a rectangle but a rectangle is not a square. That saying always confused me in school and reminds me of the confusion in the market place between vulnerability assessments and penetration tests. A penetration test is a vulnerability assessment but a vulnerability assessment is not a penetration test. As I speak to organizations that want to test the security of their technology infrastructure I ask “Do you want a vulnerability assessment or a penetration test?” I receive responses ranging from “aren’t they the same” to “I don’t know you tell me”. There are key differences between the two depending upon the purpose of the project.  I would like to outline the purpose of the two projects and when you would select each.

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Ask A-LIGN: What is the difference between a Penetration Test and a Vulnerability Assessment?

By: Gene Geiger, Partner of A-LIGN Security and Compliance Services  A square is a rectangle but a rectangle is not a square. That saying always confused me in school and reminds me of the confusion in the market place between vulnerability assessments and penetration tests. A penetration test is a vulnerability assessment but a vulnerability assessment is not a penetration test. As I speak to organizations that want to test the security of their technology infrastructure I ask “Do you want a vulnerability assessment or a penetration test?” I receive responses ranging from “aren’t they the same” to “I don’t know you tell me”. There are key differences between the two depending upon the purpose of the project. I would like to outline the purpose of the two projects and when you would select each.

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Ask A-LIGN: Is SSAE 16 a Certification?

Answer: No, SSAE 16 is not a certification. Here’s why: It is incorrect to say that you are SSAE 16 certified, because there is not a certification awarded to you after the engagement. The appropriate wording would be to state, “we have received an unqualified (Type 1 or Type 2) SSAE 16 report as a result of a service auditor performing an audit in accordance with SSAE 16 on the services within the scope of our review.” Once we have issued a final report to our clients, we will then issue the AICPA SOC Logo Guidelines form. The guidelines will explain exactly who can use the logo, how to use it appropriately, and when you must end the use or display of the logo.

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A-LIGN 2013 Community Commitment

A-LIGN is proud to employ some of the most talented professionals in the industry who also dedicate their skills and talents to our community. Giving back to the community is a quality we value highly for all employees and in an effort to make volunteering more accessible, A-LIGN will now offer ‘community service days’ for all employees interested in participating. A-LIGN is allowing one business day out of the month for employees to volunteer at any charity of their choosing.

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