How to achieve HIPAA compliance in AWS
by Rackspace Technology Staff
Originally published in Nov 2016, at the Onica blog here.
When trying to achieve HIPAA compliance in any environment, there are some basics that an organization should implement to comply with regulations. This article offers some suggestions and best practices on how to achieve and maintain HIPAA compliance in Amazon Web Services (AWS®).
Key points on HIPAA compliance in AWS
Achieving HIPAA compliance in any environment requires some basic organizational implementations to comply with regulations. The following suggestions and best practices help you achieve and maintain HIPAA compliance in Amazon Web Services (AWS).
- Encrypt whenever possible
- Log everything
- Audit everything
- Understand your data
- Enforce general security policies
Encrypt whenever possible
AWS services such as Elastic Block Storage (EBS), Simple Storage Service (S3), Relational Database Service (RDS), and many others allow you to encrypt the data-at-rest. It is important to encrypt whenever possible, whether you expect a system to have Protected Health Information (PHI) or not. At times, developers create duplicate databases or data sets to test with, and these could contain PHI. For the low cost of Key Management System (KMS), it is worth the peace of mind to encrypt anything and everything. Learn more here.
Attach a secondary volume to the EC2 instance, mark the new volume as *encrypted*, and attach it to your EC2 instance. After you create the volume, attach it to your EC2 instance. Draft and enforce a policy that requires developers to use only the secondary drive because it is encrypted. If you're wondering about the back end, you should know Elastic Compute Cloud (EC2) uses EBS on the back end.
S3 allows you to encrypt the data-in-transit and at-rest. To do so, modify the S3 bucket policy with the appropriatepolicy, find an example here. By doingso, S3 encrypts any data pushed. If the pushed data isn't encrypted, S3 denies the transfer. You can see how to force encryption
while pushing data to S3 here.
KMS is the system used to encrypt the data-at-rest for EBS, S3, and many other services within AWS. This service charges a very minimal fee per `GET` request. You can see the pricing page here.
Your systems should record any user changes to the system within the logs. If you haven't enabled logging, many changes can go by unnoticed and untracked. When an audit for HIPAA compliance takes place, the auditors will request samples of the logging that your organization has in place. If the logs don’t exist, it can be a huge mistake that could cost your organization its compliance status. To achieve logging within the AWS infrastructure, take a look at AWS Config here. AWS also offers a service to store your logs in a centralized place through Cloudwatch®. Check out Cloudwatch Logs for this feature here.
Treat logs like an ancient museum artifact. No one should be able to modify or touch them, and only certain people should be able to view them. You can achieve this through IAM policies if you store logs within Cloudwatch Logs.
Auditing is one of the most important pieces of HIPAA compliance in AWS. If a user modifies your system and there is no auditing in place, the changes can go unnoticed but recorded.
A user could open up sensitive ports to the internet allowing external attacks, and the security department would never know. Having logging in place is a good start, but auditing those logs and alerting on sensitive actions is just as important as the logging itself. If the logs are there, but no audits happen, then what use are the logs?
For changes to your AWS environment, you can use AWS Config® with Lambda to notify you of events that interest your security department. AWS Config has a pre-built rule that notifies an SNS topic (if configured) of any security group changes.
Understand your data
Having your log data is useful. Understanding your log data is just as important, if not more important. If your
logs are there, but no one knows what’s in the logs or what log records what actions, how can auditing take place How will your security department know what logs to monitor for specific actions?
Log everything, but carefully. Carefully identify what you want and need to log. For example, you might not need to know every time a file an application writes a file to `/tmp/`, but you would want to know when someone installs a new package.
Enforce general security policies
In the number of audits we've done, we noticed that many customers were not using password policies or enforcing IAM access key rotation. AWS IAM has a built-in feature that requires all user passwords to have a certain number of characters, a digit, a special character, and an upper-case character when created. Configure the AWS IAM password policies to keep your passwords in compliance with HIPAA regulations.
It is also good practice to enforce a policy to rotate AWS IAM access keys every 365 days. There is no automated AWS way to do this, but writing your own Lambda script to scan your IAM access keys nightly and alert you on expired ones is a good start.
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