Bringing work home is nothing new, but for one Oregon Health & Science University Hospital (OHSU) employee, it resulted in a significant data breach when a flash drive was stolen from the employee's house containing protected health and other personal information on over 14,000 patients and OHSU employees, as reported by a health information privacy watchdog.
Based on a statement OHSU put out concerning the breach, it appears the organization had taken steps to safeguard the information:
OHSU has several measures in place to protect patient information, including encryption software for computers, password protections and secure programs for managing patient information and tracking usage. The university also provides extensive training to all employees who have access to patient data. In addition, the university has enacted several layers of policy to help protect this information.
However, it remains to be seen whether those safeguards will stand up to scrutiny should the Office of Civil Rights investigate the situation and review with 20/20 hindsight OHSU's policies and procedures. When developing policies and procedures, covered entities under HIPAA, business associates and any other entity charged with protecting personal information should be thinking about not only whether their safeguards are reasonable and "compliant," but whether they will stand up to the applicable regulatory agency's scrutiny following a data breach.