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Compared to other key corporate executives, CEOs appear to underestimate the IT security risks faced by their own organizations, according to a survey of C-level executives released today by the Ponemon Institute. The Ponemon survey (download PDF) of 213 CEOs, CIOs, COOs and other senior executives reveals what appears to be a perception gap between CEOs and other senior managers concerning information security issues. For instance, 48% of CEOs surveyed said they believe hackers rarely try to access corporate data. On the other hand, some 53% of other C-level executives believe that their company's data is under attack on a daily or even hourly basis. The survey also found that the top executives were less aware of specific security incidents at their companies than other C-level executives and are more confident that data breaches can be easily avoided. Ponemon found that CEOs tend to view data protection efforts as vital to maintaining good customer satisfaction levels and to the company's brand image. The other managers, however, were more likely to say that the most important role for data security efforts is to satisfy regulatory requirements. The survey also found that CEOs and other top managers differed in their opinion of who is responsible for protecting corporate data. While eight out of 10 respondents said they believe there is one person responsible for data protection in their organization, there was a sharp difference of opinion on just who that person was. More than half of the CEOs said that CIOs are responsible for protecting data at their companies; only 24% of other senior managers felt the same way. And 85% of respondents said someone else would be held responsible for a data breach. "On the issue of accountability, we found that while people acknowledged that data breaches were a problem, very few people felt that if [their company] suffered a breach, they would be held responsible," said Larry Ponemon, founder of the Ponemon Institute.

Compared to other key corporate executives, CEOs appear to underestimate the IT security risks faced by their own organizations, according to a survey of C-level executives released today by the Ponemon Institute. The Ponemon survey (download PDF) of 213 CEOs, CIOs, COOs and other senior executives reveals what appears to be a perception gap between CEOs and other senior managers concerning information security issues. For instance, 48% of CEOs surveyed said they believe hackers rarely try to access corporate data. On the other hand, some 53% of other C-level executives believe that their company's data is under attack on a daily or even hourly basis. The survey also found that the top executives were less aware of specific security incidents at their companies than other C-level executives and are more confident that data breaches can be easily avoided. Ponemon found that CEOs tend to view data protection efforts as vital to maintaining good customer satisfaction levels and to the company's brand image. The other managers, however, were more likely to say that the most important role for data security efforts is to satisfy regulatory requirements. The survey also found that CEOs and other top managers differed in their opinion of who is responsible for protecting corporate data. While eight out of 10 respondents said they believe there is one person responsible for data protection in their organization, there was a sharp difference of opinion on just who that person was. More than half of the CEOs said that CIOs are responsible for protecting data at their companies; only 24% of other senior managers felt the same way. And 85% of respondents said someone else would be held responsible for a data breach. "On the issue of accountability, we found that while people acknowledged that data breaches were a problem, very few people felt that if [their company] suffered a breach, they would be held responsible," said Larry Ponemon, founder of the Ponemon Institute.

Data security represents both a new market opportunity to sell insurance coverage and a new risk - especially for independent insurance agencies that may not be compliant with data security laws or have plans in place to protect their own companies from data breaches. While data security is an evolving issue, failing to protect data can have a huge financial impact on a company. The average total per-incident cost of a data security breach was $6.65 million, compared to an average per-incident cost of $6.3 million in 2007, according to the "U.S. Cost of Data Breach Study" conducted by data protection company PGP Corp. and information management research firm The Ponemon Institute. The PGP/Ponemon study indicated that data breach incidents cost U.S. companies $202 per compromised customer record in 2008, meaning that companies incur additional costs with an abnormal churn in lost customers. More than 84 percent of data breach cases in 2008 involved organizations that had more than one data breach. And, more than 88 percent of all cases in the study involved insider negligence. The cost of lost business continued to be the most costly effect of a breach, averaging $4.59 million or $139 per record compromised. Lost business now accounts for 69 percent of data breach costs, up from 65 percent in 2007, compared to 54 percent in the 2006 study. "After four years of conducting this study, one thing remains constant: U.S. businesses continue to pay dearly for having a data breach," said Dr. Larry Ponemon, chairman and founder of The Ponemon Institute. "As costs only continue to rise, companies must remain on guard or face losing valuable customers in this unpredictable economy." Includes video: Data Security Creating Insurance Agent Sales Opportunities

A third (34 per cent) of discarded hard disk drives still contain confidential data, according to a new study which unearthed copies of hospital records and sensitive military information on eBayed kit. The study, sponsored by BT and Sims Lifecycle Services and run by the computer science labs at University of Glamorgan in Wales, Edith Cowan University in Australia and Longwood University in the US, also found network data and security logs from the German Embassy in Paris on one purchased drive. Researchers bought 300 drives from eBay, other auction sites, second-hand stalls and car boot sales. A disk bought on eBay contained details of test launch routines for the THAAD (Terminal High Altitude Area Defence) ground to air missile defence system. The same disk also held information belonging to the system's manufacturer, Lockheed Martin, including blueprints of facilities and personal data on workers, including social security numbers. Lockheed Martin denies that the disk came from it. The arm manufacturer has launched an investigation that aims to uncover just how the sensitive data might have been wound up on the disk. Two discs bought in the UK apparently came from Lanarkshire NHS Trust, including patient medical records, images of X-rays and staff letters. Lanarkshire NHS Trust runs the Monklands and Hairmyres hospitals. In Australia, the exercise turned up a disk from a nursing home that contained pictures of actual patients and their wound photos, along with patient details. A hard disk from a US bank contained account numbers and details of plans for a $50bn currency exchange through Spain. Details of business transactions between the bank and organisations in Venezuela, Tunisia and Nigeria were also included. Correspondence between a member of the Federal Reserve Board and the unnamed banks revealed that one of the deals was already under scrutiny by the European Central Bank, and that federal investigators were also taking an interest. Yet anothe

"The United States House of Representatives took a major step this week toward enacting a national data breach notification law. H.R. 2221, the Data Accountability and Trust Act (DATA), cleared the House with a voice vote. In its current form, DATA requires businesses to notify customers and the Federal Trade Commission (FTC) if sensitive information has been exposed to a security breach. If the U.S. Senate can reconcile its own approach to data breach notification legislation with DATA, a new federal standard will emerge. If signed into law by President Barack Obama, a federal data breach ¬law would pre-empt the jumbled mass of dozens of state laws. "You'd be better served by federal legislation if the federal legislation has teeth and doesn't pre-empt the state's law," said California state senator Joe Simitian, speaking to executive editor Scot Petersen in September. "If there was a meaningful standard at the national level, I think many states would be happy to accept it." Aside from the data breach notification required by the HITECH Act, DATA would put into place the first national law of its kind. H.R. 2221 was sponsored by House Subcommittee Chair Rep. Bobby L. Rush of Illinois. The bill specifically states that: "Any person engaged in interstate commerce that owns or possesses data in electronic form containing personal information shall, following the discovery of a breach of security of the system maintained by such person that contains such data -- 1. notify each individual who is a citizen or resident of the United States whose personal information was acquired by an unauthorized person as a result of such a breach of security; and 2. notify the Federal Trade Commission."

Data breaches are running at record levels, according to the San Diego-based Identity Theft Resource Center, a non-profit that tracks cybercrime. ITRC says it recorded 342 data breaches from Jan. 1 through June 24, up 69% from the same period in 2007. But, like the origins and perpetrators of so many individual data breaches, mystery also lies behind the aggregated numbers. "I'm not sure that this says breaches are increasing," ITRC founder Linda Foley tells Digital Transactions News. "What we know is the reporting of breaches is increasing." A handful of states now require some disclosure of data breaches to authorities, Alaska being the most recent. And some companies that have been hacked are starting to report breaches voluntarily, Foley says. While data breaches can compromise all manner of personal and business records, they often involve credit and debit card data and bank-account information. ITRC lists five major categories of breached entities, with the so-called banking/credit/financial sector accounting for 10% of 2008's breaches. Businesses, which include physical and Internet retailers, insurance companies and other private enterprises, accounted for 36.8%. Schools accounted for 21.3%; government and military facilities, 17%; and health-care facilities, 14.9%. IRTC also categorizes breaches by how they happened, such as through hackings-break-ins into computers and related systems, insider thefts, data lost in physical transit, and by other methods. The number of 2008 hackings through late June in the banking/credit/financial category was 10-double the five for all of 2007. The estimated number of records compromised as a result was 227,864. In 2007, the reported number of compromised records at financial institutions through hackings was 83,500. But Foley says not to put too much stock in the records numbers because so many breached organizations don't know or fail to report the number of compromised records when they report a bre

A recent data breach study commissioned by the state of Maine sheds light on the losses banks experienced as a result of the data breaches at TJX and Hannaford Brother's supermarkets. The state's banks said they incurred $2.1 million in expenses related to data breaches since January 1, 2007. The Hannaford breach had the largest impact, affecting 71 financial institutions and incurring $1.6 million in expenses according to the Maine Data Breach Study. Hannaford is based in Scarborough, Maine. The TJX breach accounted for $485,000 in expenses. The report was issued by the Main Bureau of Financial Institutions in November 2008. It studied the impact of data security breaches on Maine banks and credit unions. Fifty credit unions and 25 banks headquartered in Maine responded to the survey. Financial institutions reported more than 18 million records breached last year, according to the Identity Theft Research Center. The San Diego-based nonprofit found that data breach reports across five industry sectors jumped to 656 last year, up 47% from 2007. About 12% of the reports came from financial-services firms, up from 7% in 2007. In Maine, the Hannaford breach resulted in more than $318,000 in gross fraud losses, according to data reported by 22 financial institutions. More than 700 accounts were used to buy items fraudulently, although five of the 22 institutions that suffered a fraud loss did not report the number of accounts, according to the report. The Hannaford breach cost some banks as much as $58,000 to reissue credit cards to customers. Investigation expenses cost nearly $30,000 for some banks. Communication to customers cost nearly $28,000, some banks and credit unions reported. Fraud losses of nearly $45,000 were tied to the TJX data breach. The losses were reported by six financial institutions. The expenses for reissuing credit cards cost some banks as much as $32,000. Investigation expenses were as high as $21,000 for some banks. Communication to custom

"Legislation, which now moves to the Senate, requires data brokers to provide nationwide notice for certain data breaches and allows consumers to verify and to correct information held on them by data brokers. The U.S. House of Representatives approved legislation Dec. 8 requiring data brokers to establish procedures to verify the accuracy of information that identifies individuals in their databases and to allow consumers to access and request correction of incorrect information. The Data Accountability and Trust Act, approved on a voice vote, would also require data brokers to provide nationwide notice in the event of certain security breaches. The legislation now moves to the U.S. Senate."

Senate Judiciary Chairman Patrick Leahy (D-Vt.) has reintroduced a data breach bill that would set tougher rules for government agencies and private sector firms regarding consumers' personal information. This will be the third time around the block for the Personal Data Privacy and Security Act, which has cleared the Judiciary Committee, but never come to a vote on the Senate floor. The bill would preempt the more than 40 state laws laying out requirements for notifying consumers in the event of a data breach, a long-deferred legislative goal that has the general support of the IT industry. But Leahy's bill is about more than just data breaches. Among other things, it would set baseline security information standards for government agencies, something that the Obama administration has begun to work on with the early steps of an overhaul of the government's cybersecurity apparatus. "This is a comprehensive bill that not only deals with the need to provide Americans with notice when they have been victims of a data breach, but that also deals with the underlying problem of lax security and lack of accountability to help prevent data breaches from occurring in the first place," Leahy said in a statement. "Passing this comprehensive data privacy legislation is one of my highest legislative priorities as Chairman of the Judiciary Committee."

A group of U.S. companies, led by technology giants Microsoft, Hewlett-Packard and eBay, is set to outline recommendations for new federal data-privacy legislation that could make life easier for consumers and lead to a standard federal breach-notification law. The recommendations, which were developed by a group of industry players called the Consumer Privacy Legislative Forum, are set to be released at an upcoming privacy conference six weeks from now, according to Peter Cullen, Microsoft's chief privacy officer. The companies have been working for the past three years to encourage the adoption of federal consumer data-privacy laws and to answer the question of what federal legislation should look like, Cullen said in an interview. Other forum members include Google, Oracle, Procter & Gamble and Eli Lilly. One idea is that laws should make it easier for consumers to understand what they're getting into when they share their personal data with Web sites, Cullen said. "The whole focus on consent really puts an unfair burden on the consumer," he said. "My mom doesn't know what an IP address is." The recommendations will cover rules around data use and the ability of consumers to correct inaccurate data. And they will cover data breach notification, which is now covered by a patchwork of state laws. Simplifying breach-notification laws by creating a single federal standard is important, Cullen said Wednesday while speaking at a discussion of privacy policy in San Francisco. "It's not that there is no privacy law. There's actually too much privacy law," he said. "If you think about data-breach notification laws just as an example, there are 38 state laws, many of them very different." "We need to think about much more of a framework approach." Congress has passed some laws covering consumer data privacy, such as the 1996 Health Insurance Portability and Accountability Act (HIPAA), but existing laws do not comprehensively cover consumer privacy in general.

"The Identity Theft Resource Center (ITRC) reported its annual breach data for 2009 last week, and for the first time malicious attacks were more frequently identified as the source of those breaches than human error. In its "2009 Data Breach Report," the ITRC found 498 publicly disclosed breaches last year, down from 657 the year before. The downturn could have resulted from changes in breach disclosure, rather than a real drop-off in system compromises, the organization says. Interestingly, paper breaches now account for 26 percent of data leaks, up 46 percent compared to 2008. Malicious attacks outnumbered breaches attributed to human error for the first time in the three years the report has been compiled. The business sector accounted for 41 percent of data breaches, up from 21 percent the year before. Approximately 222 million records were compromised, the organization says -- and about 130 million of those came from the single breach at Heartland Payment Systems. Out of 498 breaches, only six reported they had either encryption or other strong security features protecting the exposed data, the ITRC says . "

Expect more action from the FTC on data privacy breeach

As if banks didn't have enough on their plates with compliance and regulation on the federal front, come May 1, they will have to be mindful of strict new rules coming from the Commonwealth of Massachusetts around data security. The Massachusetts Data Security Regulations are perhaps like no other in terms of their depth and scope. During a teleconference, attorneys from the privacy and data security practice of the law firm Goodwin Procter (Boston) described this very detailed, all-encompassing set of rules designed to keep consumers' personal data safe. They go beyond the rules of other states and the federal government that simply require companies to notify their customers of theft of their personal information. "Personal information," for the purposes of the regulation, is described as someone's first and last name or first initial and last name, in combination with Social Security Number, driver's license number or financial account number. At its core, the regulation states that companies, including banks, that handle the personal data of a Massachusetts resident must show they have in place a comprehensive, written information security program with heightened security procedures around how this information is handled. The rules also extend to entities' service providers and the degree to which they too much show they comply with the Massachusetts rules of handling data on residents. Companies have until May 1 to amend their vendor contracts to reflect this and until Jan. 1, 2010 to certify their vendors comply. Furthermore, companies must comply with these rules even if they do not have a single office in the Bay State or if they are in an already heavily regulated industry, like financial services. As long as customers in businesses' databases reside in Massachusetts, those companies are affected by the rules. According to partner Deborah Birnbach, this is some of the most intrusive legislation as it relates to the operation of businesses. "It requires

You systems administrator knows more about you than you think.

More than one-third of information technology professionals abuse administrative passwords to access confidential data such as colleagues' salary details or board-meeting minutes, according to a survey. Data security company Cyber-Ark surveyed more than 400 senior IT professionals in the United States and Britain, and found that 35 percent admitted to snooping, while 74 percent said they could access information that was not relevant to their role. In a similar survey 12 months ago, 33 percent of IT professionals admitted to snooping. "Employee snooping on sensitive information continues unabated," Udi Mokady, CEO of Cyber-Ark, said in a statement. Cyber-Ark said the most common areas respondents indicated they access are HR records, followed by customer databases, M&A plans, layoff lists and lastly, marketing information. "While seemingly innocuous, (unmanaged privileged) accounts provide workers with the 'keys to the kingdom,' allowing them to access critically sensitive information," Mokady said. When IT professionals were asked what kind of data they would take with them if fired, the survey found a jump compared with a year ago in the number of respondents who said they would take proprietary data and information that is critical to maintaining competitive advantage and corporate security. The survey found a six-fold increase in staff who would take financial reports or merger and acquisition plans, and a four-fold increase in those who would take CEO passwords and research and development plans.

"Can personal medical data that has been stripped of its identifiers to protect privacy later be used to identify a specific person? That is the question that the Health and Human Services Department is hoping a research contractor can answer. HHS intends to hire a contractor to demonstrate either the "ability or inability" to re-identify data from a data set that has been de-identified under the Health Information Portability and Accountability Act (HIPAA) Privacy Rule, according to a Jan. 4 notice on the Federal Business Opportunities Web site. De-identification and re-identification of patient data have become hot issues in the discussion about how to protect patient privacy while advancing adoption of electronic health records. The Obama administration is distributing at least $17 billion in incentive payments to doctors and hospitals who buy and use digital systems for medical data."

Individuals have been at risk of having their personal information stolen and used to commit identity-related crimes long before the emergence of the Internet. What the Information Age has changed, however, is the method by which identity thieves can access and exploit the personal information of others. One method in particular leaves hundreds of thousands, and in some cases tens of millions, of individuals at risk for identity theft: large scale data breaches by skilled hackers. In this method, criminals remotely access the computer systems of government agencies, universities, merchants, financial institutions, credit card companies, and data processors, and steal large volumes of personal information on individuals. Such large scale data breaches have revolutionized the identity theft landscape as it relates to fraud on existing accounts through the use of compromised credit and debit card account information. Large scale data breaches would be of no more concern than small scale identity thefts if criminals were unable to quickly and widely distribute the stolen information for subsequent fraudulent use (assuming, of course, that the breach would be quickly detected). Such wide-scale global distribution of stolen information has been made possible for criminals with the advent of criminal websites, known as "carding forums," dedicated to the sale of stolen personal and financial information. These websites allow criminals to quickly sell the fruits of their ill-gotten gains to thousands of eager fraudsters

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Internet scams, phishing, identity theft and other attacks that exploit your personal data are always a threat when you shop online, set up an email account, use a credit card, manage an online bank account or carry your Social Security card. There is hope, however, for fighting these threats, and you can start by taking back control of all of your personal data. The 50 tips and tools in this list will help you understand how these scams originate, how to protect yourself online and offline, and how to track down your personal data on the Internet. Web Privacy Protect yourself and your data online by choosing a secure Web browser, understanding the dos and don'ts of wireless security, and correctly managing passwords.

Until now, lawsuits seeking to recover significant damages based on the loss of, or unauthorized access to, sensitive personal information have not been especially successful for plaintiffs. Most companies suffering data breaches have escaped by offering affected consumers inexpensive credit monitoring services. But two recent cases show plaintiffs a way to expose many previously safe companies to substantial claims for damages. Any company that thinks there are no risks in employing less than best practices for data privacy and security needs a wake up call. The headlines are all too familiar. Some well known consumer services company (or less known wholesale data processor) announces that millions of individual records containing names, Social Security numbers, account numbers and other sensitive information were left in a dumpster, saved to a stolen, unencrypted laptop, or stored on a misplaced USB drive or backup tape. The press is terrible, the company's stock takes a temporary plunge, and sometimes the Federal Trade Commission enters into a consent decree where the company promises to never do it again. But when affected individuals or groups of consumers tried to sue for damages, they seldom recover significant amounts. These cases have not often succeeded because the plaintiffs have been unable to prove actual pecuniary losses resulting from the security breach. Sure, if identify theft occurs the affected individuals can suffer significant emotional trauma, loss of time, etc. But Courts have been unwilling to award damages for anxiety, fear, and other emotional harm that can result from a data breach, for the risk of future identify theft, or for actual identity theft when the plaintiff could not prove that the theft occurred as a direct result of a data breach at a particular source. Most companies facing claims based on data breaches have been able to settle cheaply by offering to provide credit monitoring services, which most consumers do not use, resu

Current government rules do too little to protect the privacy of people's personal health information and also hinder the use of health data in medical research, a panel of experts reported on Wednesday. A committee of the Institute of Medicine, which provides advice to U.S. policymakers, urged Congress to take an entirely new approach to protecting personal health data in research. Federal standards for protecting privacy of personal health data under the Health Insurance Portability and Accountability Act of 1996, or HIPAA, are not doing the job, the panel said. Congress and the Obama administration are planning major changes this year to the U.S. health care system. Regarding the privacy rules, Congress should either start from scratch or thoroughly overall HIPAA's privacy provisions, the panel said. Better data security is needed, with greater use of encryption and other security techniques, the panel said. Encryption should be required for laptops, flash drives and other devices containing such data, it said. "Both privacy and health research are important. And we feel that we can strengthen privacy protections for people who participate in research while also allowing important research to proceed without unnecessary impediments," Dr. Bernard Lo of the University of California San Francisco, a member of the panel, told reporters. HIPAA governs how personally identifiable health information can be used and disclosed by health plans, health care providers and others. The intention is to protect personal health information while permitting the flow of information for health-related research and medical care. Lo said HIPAA has burdensome and confusing procedures for people to consent to have their health data used in medical research, dissuading people from taking part in such research.

The software vendor's commissioned research will be revealed during a panel discussion with leaders from the California Office of Privacy Protection, Intel, and MySpace. Wednesday, Jan. 28, 2009, is Data Privacy Day, and to mark the occasion, Microsoft is participating in a panel discussion in San Francisco with privacy experts from the California Office of Privacy Protection, the Center for Democracy and Technology, Intel (NSDQ: INTC), and MySpace. Better this week than last, when Heartland Payment Systems and Monster.com disclosed major malware-driven data breaches that promise privacy headaches or worse for affected account holders. It is such incidents that worry Peter Cullen, Microsoft (NSDQ: MSFT)'s chief privacy strategist, because of the impact they can have on consumer trust. "Trust is becoming increasingly important," he said. That's why Data Privacy Day exists. Microsoft and other organizations recognize that without trust, the online economy only gets worse for everyone. Cullen explained that Data Privacy Day represents a global opportunity for organizations and individuals to come together to discuss how to better educate consumers about data privacy issues. One way to advance the discussion, Cullen said, was to commission some research, which Microsoft did in two cities, in California and Texas. "We wanted to understand how different segments of consumers, from teens to professionals to boomers, thought about privacy," he said. "There were some rather interesting results that came out of this." "Our hypothesis is that across these three segments, there would be different ways of thinking about these things," said Cullen. "We were really surprised to learn there's a large degree of similarity in the way people think about privacy."

It was only a matter of time! Auditor accuracy being examined in lawsuit may signal change in PCI and other compliance processes.

When CardSystems Solutions was hacked in 2004 in one of the largest credit card data breaches at the time, it reached for its security auditor's report. In theory, CardSystems should have been safe. The industry's primary security standard, known then as CISP, was touted as a sure way to protect data. And CardSystems' auditor, Savvis Inc, had just given them a clean bill of health three months before. Yet, despite those assurances, 263,000 card numbers were stolen from CardSystems, and nearly 40 million were compromised. More than four years later, Savvis is being pulled into court in a novel suit that legal experts say could force increased scrutiny on largely self-regulated credit card security practices. They say the case represents an evolution in data breach litigation and raises increasingly important questions about not only the liability of companies that handle card data but also the liability of third parties that audit and certify the trustworthiness of those companies. "We're at a critical juncture where we need to decide . . . whether [network security] auditing is voluntary or will have the force of law behind it," says Andrea Matwyshyn, a law and business ethics professor at the University of Pennsylvania's Wharton School who specializes in information security issues. "For companies to be able to rely on audits . . . there needs to be mechanisms developed to hold auditors accountable for the accuracy of their audits." The case, which appears to be among the first of its kind against a security auditing firm, highlights flaws in the standards that were established by the financial industry to protect consumer bank data. It also exposes the ineffectiveness of an auditing system that was supposed to guarantee that card processors and other businesses complied with the standards. Credit card companies have touted the standards and the auditing process as evidence that financial transactions conducted under their purview are secur

CSOs in healthcare organizations know that the Health Information Technology for Economic and Clinical Health (HITECH) Act, signed into law in February 2009, includes new privacy requirements that experts have called "the biggest change to the health care privacy and security environment since the original HIPAA privacy rule." These include: New requirements that widen the definition of what Personal Health Information (PHI) information must be protected and extend accountability from healthcare providers to their business associates; Lower thresholds, shorter timelines, and stronger methods for data breach victim notification; Effective immediately, increased and sometimes mandatory penalties with fines ranging from $25,000 to as much as $1.5 million; More aggressive enforcement including authority to pursue criminal cases against HIPAA-covered entities or their business associates. No doubt, the HITECH Act raises the stakes for a data breach. But regulations aside, data breaches can hurt your organization's credibility and can carry huge medical and financial risks to the people whose data is lost. We've managed hundreds of data breaches and helped thousands of identity theft victims. Through this we've learned firsthand that compliance doesn't necessarily equal low risk for data breach. For the well being of the business and patients, healthcare organizations and their partners need to take the most comprehensive approach to securing PHI.