[google-appengine] Re: HIPAA requirements vs. AppEngine security guidelines

2009-07-08 Thread nathanr



On Jul 8, 12:23 am, Jeff Enderwick jeff.enderw...@gmail.com wrote:
 I say go hire a HIPAA consultant who can answer such questions 
 authoritatively.

This is good advice.  You really don't want to be basing legal
decisions on a third-party's statements.  I'd have your attorney
review each service's documents directly.

That said, even if AppEngine doesn't comply on its own, the new-ish
data connectors that let you attach to information from behind your
firewall may be enough to let you build out some minor infrastructure
to supplement AppEngine for compliance purposes.

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[google-appengine] Re: HIPAA requirements vs. AppEngine security guidelines

2009-07-08 Thread Andrew Badera

On Tue, Jul 7, 2009 at 10:11 PM, GenghisOnemdkach...@gmail.com wrote:

 Andy

 Thanks for the heads-up...

 The link to that paper is here and it makes for a good read...
 http://awsmedia.s3.amazonaws.com/AWS_HIPAA_Whitepaper_Final.pdf


Thanks for the link. Bookmarked it this time.

--ab

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[google-appengine] Re: HIPAA requirements vs. AppEngine security guidelines

2009-07-07 Thread Andrew Badera

There's a whitepaper by Amazon on the topic. Google it, it's been a
few months since I looked at it, don't have a link offhand, sorry.

Thanks-
- Andy Badera
- and...@badera.us
- Google me: http://www.google.com/search?q=andrew+badera
- This email is: [ ] bloggable [x] ask first [ ] private



On Mon, Jul 6, 2009 at 5:17 PM, GenghisOnemdkach...@gmail.com wrote:

 Does anyone know if Amazon's EC2 platform is HIPAA-compliant?

 On Jul 6, 12:44 pm, richard emberson richard.ember...@gmail.com
 wrote:
 Not going to happen. The IT requirements for Google would
 cost far more than the couple of applications that might
 need HIPAA. They would have to have a completely
 separate group with their own machines, passwords,
 procedures, etc. with a real wall (both material wall
 and software/hardware wall) between the group and the rest of
 Google or all of Google would have to be HIPAA
 compliant. So, how much is it worth for Google? Not much.

 RME



 Ken wrote:
  Hi,

  I'm researching the feasibility of running a healthcare app on the
  AppEngine cloud.  I've read through the AE terms of service and they
  don't say much about the actual security guidelines other than
  deferring to the boilerplate Google security policy.  I have no doubt
  there are internal documents detailing the exact security guarantees
  provided by Google's infrastructure, but that information is not
  readily available to the public.

  It's been a full year since the last time HIPAA was discussed in this
  group.  Now that SSL support has been enabled, data transfer
  constraints can be met with ease.  So, what's the story today with GAE
  and HIPAA compliance?  Are the App Engine's data storage and transfer
  mechanisms compatible with the guidelines set out by HIPAA?

  Google Apps documentation has quite a bit more security information,
  such as specifying annual SAS 70 Type II audits.  I'm not familiar
  with this particular security audit, but some quick research seems to
  indicate that SAS 70 audit controls are mostly a superset of HIPAA
  guidelines.  However, there are some aspects of HIPAA compliance that
  seem to be difficult to implement in a distributed database system, so
  any reassurances from the Google App Engine folks in this regard would
  be most appreciated.

  Thanks!

  Ken

 --
 Quis custodiet ipsos custodes
 


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[google-appengine] Re: HIPAA requirements vs. AppEngine security guidelines

2009-07-07 Thread GenghisOne

Andy

Thanks for the heads-up...

The link to that paper is here and it makes for a good read...
http://awsmedia.s3.amazonaws.com/AWS_HIPAA_Whitepaper_Final.pdf

Unfortunately after I skimmed through it I felt a little unsettled
about AppEngine's security model...probably just my limited
understanding of what's under the hood, but nonetheless security is
kinda important and maybe its time to start asking some plain
questions.

For instance, here's one thing the Amazon whitepaper had to say about
auditing...


In designing a HIPAA-compliant system, customers should put auditing
capabilities in place
to allow security analysts to drill down into detailed activity logs
or reports to see who had
access, IP address entry, what data was accessed, etc. This data
should be tracked, logged, and
stored in a central location for extended periods of time in case of
an audit. 

So can AppEngine enable this and if so how? My gut is telling me yes
but there's still a nagging concern...How do I know if someone inside
Google looked at my customers data? Is there some kind of *deep*
logging mechanism of sorts?

Thx much.

BTW -- If Google has a comparable whitepaper, I'd very much appreciate
the link.

Thx much.

On Jul 7, 4:01 am, Andrew Badera and...@badera.us wrote:
 There's a whitepaper by Amazon on the topic. Google it, it's been a
 few months since I looked at it, don't have a link offhand, sorry.

 Thanks-
 - Andy Badera
 - and...@badera.us
 - Google me:http://www.google.com/search?q=andrew+badera
 - This email is: [ ] bloggable [x] ask first [ ] private

 On Mon, Jul 6, 2009 at 5:17 PM, GenghisOnemdkach...@gmail.com wrote:

  Does anyone know if Amazon's EC2 platform is HIPAA-compliant?

  On Jul 6, 12:44 pm, richard emberson richard.ember...@gmail.com
  wrote:
  Not going to happen. The IT requirements for Google would
  cost far more than the couple of applications that might
  need HIPAA. They would have to have a completely
  separate group with their own machines, passwords,
  procedures, etc. with a real wall (both material wall
  and software/hardware wall) between the group and the rest of
  Google or all of Google would have to be HIPAA
  compliant. So, how much is it worth for Google? Not much.

  RME

  Ken wrote:
   Hi,

   I'm researching the feasibility of running a healthcare app on the
   AppEngine cloud.  I've read through the AE terms of service and they
   don't say much about the actual security guidelines other than
   deferring to the boilerplate Google security policy.  I have no doubt
   there are internal documents detailing the exact security guarantees
   provided by Google's infrastructure, but that information is not
   readily available to the public.

   It's been a full year since the last time HIPAA was discussed in this
   group.  Now that SSL support has been enabled, data transfer
   constraints can be met with ease.  So, what's the story today with GAE
   and HIPAA compliance?  Are the App Engine's data storage and transfer
   mechanisms compatible with the guidelines set out by HIPAA?

   Google Apps documentation has quite a bit more security information,
   such as specifying annual SAS 70 Type II audits.  I'm not familiar
   with this particular security audit, but some quick research seems to
   indicate that SAS 70 audit controls are mostly a superset of HIPAA
   guidelines.  However, there are some aspects of HIPAA compliance that
   seem to be difficult to implement in a distributed database system, so
   any reassurances from the Google App Engine folks in this regard would
   be most appreciated.

   Thanks!

   Ken

  --
  Quis custodiet ipsos custodes
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[google-appengine] Re: HIPAA requirements vs. AppEngine security guidelines

2009-07-07 Thread Jeff Enderwick

I say go hire a HIPAA consultant who can answer such questions authoritatively.

I've been through FIPS before, and you would not believe the odd
lawyeresque contrivances used to get certified. With HIPAA you are in
the same realm, and so you should hire yourself the appropriate
barrister.

$.02,

Jeff

On Tue, Jul 7, 2009 at 7:11 PM, GenghisOnemdkach...@gmail.com wrote:

 Andy

 Thanks for the heads-up...

 The link to that paper is here and it makes for a good read...
 http://awsmedia.s3.amazonaws.com/AWS_HIPAA_Whitepaper_Final.pdf

 Unfortunately after I skimmed through it I felt a little unsettled
 about AppEngine's security model...probably just my limited
 understanding of what's under the hood, but nonetheless security is
 kinda important and maybe its time to start asking some plain
 questions.

 For instance, here's one thing the Amazon whitepaper had to say about
 auditing...


 In designing a HIPAA-compliant system, customers should put auditing
 capabilities in place
 to allow security analysts to drill down into detailed activity logs
 or reports to see who had
 access, IP address entry, what data was accessed, etc. This data
 should be tracked, logged, and
 stored in a central location for extended periods of time in case of
 an audit. 

 So can AppEngine enable this and if so how? My gut is telling me yes
 but there's still a nagging concern...How do I know if someone inside
 Google looked at my customers data? Is there some kind of *deep*
 logging mechanism of sorts?

 Thx much.

 BTW -- If Google has a comparable whitepaper, I'd very much appreciate
 the link.

 Thx much.

 On Jul 7, 4:01 am, Andrew Badera and...@badera.us wrote:
 There's a whitepaper by Amazon on the topic. Google it, it's been a
 few months since I looked at it, don't have a link offhand, sorry.

 Thanks-
 - Andy Badera
 - and...@badera.us
 - Google me:http://www.google.com/search?q=andrew+badera
 - This email is: [ ] bloggable [x] ask first [ ] private

 On Mon, Jul 6, 2009 at 5:17 PM, GenghisOnemdkach...@gmail.com wrote:

  Does anyone know if Amazon's EC2 platform is HIPAA-compliant?

  On Jul 6, 12:44 pm, richard emberson richard.ember...@gmail.com
  wrote:
  Not going to happen. The IT requirements for Google would
  cost far more than the couple of applications that might
  need HIPAA. They would have to have a completely
  separate group with their own machines, passwords,
  procedures, etc. with a real wall (both material wall
  and software/hardware wall) between the group and the rest of
  Google or all of Google would have to be HIPAA
  compliant. So, how much is it worth for Google? Not much.

  RME

  Ken wrote:
   Hi,

   I'm researching the feasibility of running a healthcare app on the
   AppEngine cloud.  I've read through the AE terms of service and they
   don't say much about the actual security guidelines other than
   deferring to the boilerplate Google security policy.  I have no doubt
   there are internal documents detailing the exact security guarantees
   provided by Google's infrastructure, but that information is not
   readily available to the public.

   It's been a full year since the last time HIPAA was discussed in this
   group.  Now that SSL support has been enabled, data transfer
   constraints can be met with ease.  So, what's the story today with GAE
   and HIPAA compliance?  Are the App Engine's data storage and transfer
   mechanisms compatible with the guidelines set out by HIPAA?

   Google Apps documentation has quite a bit more security information,
   such as specifying annual SAS 70 Type II audits.  I'm not familiar
   with this particular security audit, but some quick research seems to
   indicate that SAS 70 audit controls are mostly a superset of HIPAA
   guidelines.  However, there are some aspects of HIPAA compliance that
   seem to be difficult to implement in a distributed database system, so
   any reassurances from the Google App Engine folks in this regard would
   be most appreciated.

   Thanks!

   Ken

  --
  Quis custodiet ipsos custodes
 


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[google-appengine] Re: HIPAA requirements vs. AppEngine security guidelines

2009-07-06 Thread richard emberson

Not going to happen. The IT requirements for Google would
cost far more than the couple of applications that might
need HIPAA. They would have to have a completely
separate group with their own machines, passwords,
procedures, etc. with a real wall (both material wall
and software/hardware wall) between the group and the rest of
Google or all of Google would have to be HIPAA
compliant. So, how much is it worth for Google? Not much.

RME

Ken wrote:
 Hi,
 
 I'm researching the feasibility of running a healthcare app on the
 AppEngine cloud.  I've read through the AE terms of service and they
 don't say much about the actual security guidelines other than
 deferring to the boilerplate Google security policy.  I have no doubt
 there are internal documents detailing the exact security guarantees
 provided by Google's infrastructure, but that information is not
 readily available to the public.
 
 It's been a full year since the last time HIPAA was discussed in this
 group.  Now that SSL support has been enabled, data transfer
 constraints can be met with ease.  So, what's the story today with GAE
 and HIPAA compliance?  Are the App Engine's data storage and transfer
 mechanisms compatible with the guidelines set out by HIPAA?
 
 Google Apps documentation has quite a bit more security information,
 such as specifying annual SAS 70 Type II audits.  I'm not familiar
 with this particular security audit, but some quick research seems to
 indicate that SAS 70 audit controls are mostly a superset of HIPAA
 guidelines.  However, there are some aspects of HIPAA compliance that
 seem to be difficult to implement in a distributed database system, so
 any reassurances from the Google App Engine folks in this regard would
 be most appreciated.
 
 Thanks!
 
 Ken
 
  
 

-- 
Quis custodiet ipsos custodes

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[google-appengine] Re: HIPAA requirements vs. AppEngine security guidelines

2009-07-06 Thread GenghisOne

Does anyone know if Amazon's EC2 platform is HIPAA-compliant?

On Jul 6, 12:44 pm, richard emberson richard.ember...@gmail.com
wrote:
 Not going to happen. The IT requirements for Google would
 cost far more than the couple of applications that might
 need HIPAA. They would have to have a completely
 separate group with their own machines, passwords,
 procedures, etc. with a real wall (both material wall
 and software/hardware wall) between the group and the rest of
 Google or all of Google would have to be HIPAA
 compliant. So, how much is it worth for Google? Not much.

 RME



 Ken wrote:
  Hi,

  I'm researching the feasibility of running a healthcare app on the
  AppEngine cloud.  I've read through the AE terms of service and they
  don't say much about the actual security guidelines other than
  deferring to the boilerplate Google security policy.  I have no doubt
  there are internal documents detailing the exact security guarantees
  provided by Google's infrastructure, but that information is not
  readily available to the public.

  It's been a full year since the last time HIPAA was discussed in this
  group.  Now that SSL support has been enabled, data transfer
  constraints can be met with ease.  So, what's the story today with GAE
  and HIPAA compliance?  Are the App Engine's data storage and transfer
  mechanisms compatible with the guidelines set out by HIPAA?

  Google Apps documentation has quite a bit more security information,
  such as specifying annual SAS 70 Type II audits.  I'm not familiar
  with this particular security audit, but some quick research seems to
  indicate that SAS 70 audit controls are mostly a superset of HIPAA
  guidelines.  However, there are some aspects of HIPAA compliance that
  seem to be difficult to implement in a distributed database system, so
  any reassurances from the Google App Engine folks in this regard would
  be most appreciated.

  Thanks!

  Ken

 --
 Quis custodiet ipsos custodes
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