The HIPAA Blind Spot
"The HIPAA Blind Spot" in the context of cybersecurity refers to a range of often-overlooked vulnerabilities and risks that can lead to non-compliance and data breaches, despite an organization having a seemingly robust security program. These blind spots typically exist in areas that are not directly under the control of the organization's central IT or security teams.
The most common and critical components of the HIPAA blind spot are:
Third-Party Vendor Risk: This is arguably the most significant blind spot. Healthcare organizations rely on a vast ecosystem of third-party vendors and business associates—from billing companies and cloud storage providers to electronic health record (EHR) systems and data analytics firms. While organizations may secure their own systems, they often lack visibility into the security posture of their vendors. Suppose a vendor experiences a breach due to weak security practices. In that case, the ePHI they manage on behalf of the healthcare organization is at risk, leading to a HIPAA violation for both parties.
Shadow IT: This refers to the use of unauthorized software, applications, or services by employees without the knowledge or approval of the IT or security department. Examples include employees using unapproved cloud storage services, messaging apps, or personal devices to handle or transmit ePHI. These tools often lack the necessary security controls, such as encryption, access controls, and audit trails, making them easy targets for cybercriminals and creating a significant, unmonitored risk to patient data.
Misconfigurations and Unknown Assets: The blind spot also includes misconfigured IT assets that are exposed to the public internet but are not on a known asset inventory. This could be an outdated application running on an unknown subdomain, an improperly configured cloud storage bucket, or an exposed database. These assets may not be monitored by internal security tools, creating a perfect entry point for attackers to bypass defenses and access sensitive information.
Legacy Systems and Outdated Software: Many healthcare organizations rely on older, legacy systems that are difficult to patch or update. These systems often contain known vulnerabilities that have been patched in newer versions; however, the organization may be unaware of or unable to address the associated risk. Attackers can easily exploit these weaknesses to gain a foothold in the network.
Addressing the HIPAA blind spot requires a proactive approach that goes beyond internal network security. It involves implementing robust third-party risk management programs, establishing clear policies for approved software, and using external assessment tools to gain a comprehensive view of the organization's public-facing attack surface.
ThreatNG directly addresses "The HIPAA Blind Spot" by providing a comprehensive, external perspective that uncovers and assesses risks often missed by internal security tools. It achieves this through its unauthenticated, outside-in approach, which mimics a hacker's view of an organization's digital footprint.
External Discovery and Assessment
ThreatNG performs purely external unauthenticated discovery to find an organization's publicly exposed assets and digital risks. This is crucial for identifying unknown assets that form a core part of the HIPAA Blind Spot.
External GRC Assessment: This capability provides an ongoing, outside-in evaluation of an organization's Governance, Risk, and Compliance (GRC) posture, mapping all discovered findings directly to relevant frameworks, such as HIPAA. This enables organizations to identify and proactively close external security and compliance gaps.
Example 1: Unknown Assets: ThreatNG's discovery capabilities may identify an exposed API on a subdomain created by a developer without the knowledge of the central IT team. The External GRC Assessment would flag this as a risk because APIs often handle ePHI and must have strict access controls and audit logging, which is relevant to HIPAA requirements.
Example 2: Third-Party Vendor Risks: The platform can identify files in open cloud buckets belonging to a third-party vendor. This is a critical blind spot that violates HIPAA's Access Control rule by allowing public access to sensitive data. ThreatNG's assessment highlights this as a direct risk that needs to be remediated to maintain compliance.
Example 3: Misconfigured Infrastructure: ThreatNG's assessments can identify that a subdomain with a login page is missing a Content Security Policy (CSP). A missing CSP is a security weakness that must be addressed as part of an organization's risk management strategy under HIPAA.
Investigation Modules and Intelligence Repositories
ThreatNG's investigation modules and intelligence repositories provide granular detail on external threats, shedding light on risks that internal tools can't see.
Domain Intelligence: This module identifies risks associated with an organization's domain names, a common blind spot.
Subdomain Takeovers: It can detect when a subdomain points to an unclaimed service, allowing an attacker to hijack it to serve malicious content or impersonate the organization. This is a serious threat to ePHI as it can lead to phishing or unauthorized access.
Domain Name Permutations: The module identifies registered lookalike domains, also known as "typosquatting," which can be exploited in phishing and social engineering attacks to deceive individuals who handle ePHI. This is a measurable threat vector that must be included in a HIPAA risk analysis.
Sensitive Code Exposure: This module scours public code repositories, such as GitHub, for exposed credentials, API keys, or ePHI. The discovery of code secrets is directly relevant to HIPAA, as exposed credentials can lead to unauthorized access and data breaches.
Dark Web Presence: ThreatNG monitors the dark web for mentions of an organization or for compromised credentials. The discovery of compromised credentials is a direct threat to ePHI, as it can lead to unauthorized access, and it requires activation of an incident response plan.
Intelligence Repositories: ThreatNG's DarCache repositories provide continuously updated intelligence.
Ransomware Events: The DarCache Ransomware repository tracks over 70 ransomware gangs. Ransomware must be assessed as a critical risk to the confidentiality, integrity, and availability of ePHI.
Vulnerabilities: The DarCache Vulnerability repository provides context on vulnerabilities that are actively being exploited in the wild, such as those listed in the KEV catalog. This helps an organization prioritize remediation efforts on vulnerabilities that pose an immediate and proven threat.
Complementary Solutions
ThreatNG's external insights can be used to improve the effectiveness of internal security solutions, creating a unified defense against HIPAA Blind Spots.
Complementary Solutions: ThreatNG can provide a list of discovered login pages and other public-facing applications. These findings can be used to configure a Web Application Firewall (WAF) to enforce stricter access controls and prevent common web attacks, a key control for HIPAA.
Complementary Solutions: The platform's discovery of publicly exposed private IP addresses can be used to inform an internal network security tool or a SIEM. This allows the internal team to cross-reference the external findings with their internal network diagrams and system logs to investigate potential unauthorized access attempts.
Complementary Solutions: When ThreatNG identifies that a subdomain is vulnerable to a takeover, that information can be sent to a Threat Intelligence Platform. The platform can then use this data to alert other security tools and incident response teams about a potential threat before it is actively exploited. This proactive approach supports HIPAA's requirements for Security Incident Procedures.
