After the Instagram Ts&Cs palaver, an interesting piece on cloud service terms, conditions and acceptable use.
Of course almost all Health IT – related cloud services are based on infrastructure provided by one of the underlying vendors – Amazon, Rackspace, Azure, et al.
It is possible “…simply because a customer, a politician, or even a competitor claims there are issues with your — or your customers’ — activities” for the underlying vendor to shut down the service being provided – in the article, based on on allegations of DMCA transgression.
But Health IT – particularly clinical services – may have a comparable achilles heel – the certifications such as FDA 510(k) and EU CE Mark. It isn’t impossible for a given software product to be classified differently by different companies. For example, I know of two vendors selling effectively the same product – one of which has it classified as CE Class I, the other, Class IIa. The difference in effort between the two is not insignificant and depends entirely on legal opinion. It is possible (I don’t think it has happened) that the latter vendor has used the difference in legal opinion to pressure potential customers to avoid the possible risk should litigation come knocking, but then, it is up to individual hospitals to consider that as a possible hazard.
But for competing services in the cloud – a small word in the right ear that the cloud provider (at the level of Amzon, Microsoft or Rackspace) is hosting services that are incorrectly classified and may be open to legal action – would certainly generate a phone call to General Counsel. And action may well follow.
Simon Phipps in the article linked above suggests 3 mitigations of varying degrees of ‘implementability’. The third is part of what I would call Full Stack Redundancy – avoid single points of failure all through the hardware/software stack (at least where possible) – including cloud vendor. Its a tough ask, but hey:
Shoot for the moon. Even if you miss, you’ll land among the stars
I note a press release from the Information Commissioner’s Office publishing a code of best practice when it comes to data anonymisation, as well as the launch of a new body (UKAN) to promote said best practice.
While this is largely focussed on aggregate (e.g. statistical / epidemiology) practices, anonymisation (and more specifically, pseudonymisation) is an important topic in the conversation around the two big buzzwords of the day – ‘mobile’ and ‘cloud’
Mobile applications – particularly when combined with BYOD – has security issues. That much we all know, and there are solutions to those issues that are, by now, well understood, including encryption, virtualisation, compartmentalisation and zero-footprint-client. But these come with compromises and issues of their own. It would of course be simpler in terms of deployment and performance if native apps could be used without concerns over information security. This is where pseudonymisation has a benefit – on the way to the device, all identifiable data is replaced with ‘alternative identities’, with the relationship between the original and alternative only known to a trusted system (aka ‘the server’). On the way back, the original identity(ies) is restored and no privacy issues accrue.
But this may be more important ‘in the cloud’. Access to patient data through the NHS IGSoC process demands careful planning and implementation of best-practice security measures (rightly so), and it is virtually (if not downright) impossible to ship Persoanlly Identifiable Data (PID) to locations outside the UK. For the cloud, that is a problem. Very often, restricting the location of data to within the UK will mean many of the benefits of cloud are not realisable. In some cases, it means that the choice of infrastructure supplier is limited and in some situations – potentially valuable services made entirely irrelevant.
A cloudy service launched in the US, for example, will often choose an infrastructure provider based in the US. That isn’t much good for organisations in the UK who cannot store PID outside the UK. Pseudonymisation offers a way forward for those situations.
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