Investor Presentaiton
Number 16
July 2010
Strong Encryption
Information and Privacy Commissioner of Ontario
Fact Sheet
Health-Care Requirement for Strong Encryption
Introduction
The Office of the Information and Privacy Strong Encryption
Commissioner (IPC), in Order HO-004, and
most recently in Order HO-007, required
that health information be safeguarded at
all times, specifically by ensuring that any
personal health information stored on any
mobile devices (e.g., laptops, memory sticks,
PDAs) be strongly encrypted.' The Order did
not otherwise define what constitutes "strong
encryption" in the context of protecting the
confidentiality, integrity, and availability of
personal health information.
Accordingly, this paper provides a working
definition of strong encryption and discusses
the minimum functional and technical
requirements of what may be considered
to be strong encryption in a health-care
environment. These, in turn, will provide
procurement criteria that, if met, will ensure
that personal health information stored on
encrypted mobile devices or storage media
will remain accessible to authorized users,
but no one else.
Special thanks go to Dr. Robert Kyle, Durham
Region Commissioner and Medical Officer
of Health, for supporting the production
of this paper.
The term 'strong encryption' does not refer to
a particular technical or design specification,
or even to a specific encryption feature that
could be inserted into a procurement or
audit specification. No particular encryption
technology no matter how "strong" it
may be can ever, by itself, ensure that
information remains secure. Instead, avariety
of circumstances and factors need to be
taken into account to ensure that personal
information is protected against access by
unauthorized parties.
To begin with, a good encryption algorithm
must be used-one that has been subjected
to rigorous peer review. Next, the algorithm
must be properly implemented. This
may only be confirmed if the encryption
system is tested by an independent security
testing lab. Once the encryption system
is deployed, the encryption keys must be
protected and managed effectively. Users
who are authorized to decrypt data must
be securely authenticated by means of
passwords, biometrics, or security tokens.
Other IPC Publications
No. 12 - Encrypting Personal Health Information on
Mobile Devices
Provides guidance to health information custodians on
how to securely retain personal health information on
mobile devices through encryption.
No.13 - Wireless Communication Technologies: Video
Surveillance Systems
Addresses privacy issues that arise from the use of
wireless video surveillance technologies to transmit
personal information and the proactive security
measures required to protect the privacy of individuals.
No.16 Health-Care Requirement for Strong Encryption
Discusses the minimum functional and technical
requirements of what may be considered strong
encryption, thus ensuring that personal health
information stored on mobile devices is protected.
No.18 - Secure Transfer of Personal Health Information
Provides guidance for health information custodians on
the secure transfer of records of personal health
information.
www.ipc.on.ca
Information and Privacy
Commissioner of Ontario
Commissaire à l'information et à la
protection de la vie privée de l'OntarioView entire presentation