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Can We Abandon Confidentiality For Google Apps?
An anonymous reader writes "I provide IT services for medium-sized medical and law practices. Lately I have been getting a lot of feedback from doctors and lawyers who use gmail at home and believe that they can run a significant portion of their practice IT on Google Apps. From a support standpoint, I'd be happy to chuck mail/calendar service management into the bin and let them run with gmail, but for these businesses, there is significant legal liability associated with the confidentiality of their communications and records (e.g., HIPAA). For those with high-profile celebrity clients, simply telling them 'Google employees can read your stuff' will usually end the conversation right there. But for smaller practices, I often get a lot of push-back in the form of 'What's wrong with trusting Google?' and 'Google's not interested in our email/calendar.' Weighing what they see as a tiny legal risk against the promise of Free IT Stuff(TM) becomes increasingly lopsided given the clear functionality / usability / ubiquity that they experience when using Google at home. So my question to the Slashdot community is: Are they right? Is it time for me to remove the Tin Foil Hat on the subject of confidentiality and stop resisting the juggernaut that is Google? If not, what is the best way to clarify the confidentiality issues for these clients?"
..the google apps contract is fine. IAAL and i use google apps for all my stuff. i DO maintain a separate backup but everything goes on google. the bar is also fine with it.
If you are in an industry where your internal communications/documents/etc should or must remain confidential, than you cannot trust Google Apps as your free platform for email/document creation/document storage.
If you don't mind the possibility that the world may get your data, then by all means feel free to use Google, or any other SaaS type offering.
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Confidentiality is very, very important to businesses and individuals, even more so in the Internet age. One of the reasons to continue to operate your own infrastructure, no matter what the current hype is.
Most ACs are not even worth the keystrokes to insult them. Be generically insulted by this and ignored otherwise.
immediately squelch any such thoughts.
"I don't know, therefore Aliens" Wafflebox1
From here: http://docs.google.com/support/bin/answer.py?answer=82366&ctx=sibling
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Privacy and security: Understanding section 11.1 of our Terms of Service
Print
We've received questions over time about the meaning of section 11.1 of our Terms of Service. We realize that for those not familiar with legal agreements for services that use the Internet, these terms can look confusing, or even frightening.
The first thing to understand is that this language doesn't give Google ownership rights to your data. You, and you alone, own your content. Whether you wish to keep your content totally private, or share it with the world, that's your choice.
However, in order to honor this choice, Google Docs needs permission to display your content as you see fit. This is what we mean by a "license to reproduce." We need to ensure that when you click the "Publish document" button, or use the "Invite collaborators" option, we have the license to carry out your wishes. It is this agreement, between Google Docs and you, the user, that section 11.1 of our Terms of Service reflects."
Why would you even chance it? That's their EXISTING terms of service, but as always, those terms are subject to change without notice.
I can't imagine that HIPAA would allow this.
Sent from your iPad.
It might be an acceptable compromise. The same clients considering Google Apps are 99.999% likely to have a non-existent or ineffective backup/archiving system, lack the expertise/cash for sysadmining Microsoft enterprise apps and would probably benefit from being able to log in on multiple machines to access their data. All strategies involve risk - if you veto Google, they may be missing out on the best compromise solution. YMMV.
This is slashdot, not legaldot.
That being said, your writeup sounds like you're a contractor/have your own company. If that's the case, the best you can do (Outside of telling your customers you aren't going to and being fired) is make very clear, in writing, what your opinion is, and get them to sign off, in writing, that they are responsible and/or have another way for handling confidential info, etc.
I'm not sure if that's enough to cover your butt or not. See first sentence about this is slashdot, not legaldot. I would consult with a lawyer, preferably one that is not one of your customers.
Why does the story header appear *red* instead of the usual green? (Firefox 3.5 on Vista)
It does that when the story is brand spanking new, I think. It means you're getting the freshest of slashdot's offerings, rejoice!
You can't take the sky from me...
Tell them about what could happen, and that the risk may be low but not zero. Because data have been exposed through sloppiness before, not only through malice.
Then make sure YOU are not liable if they violate HIPPA or something similar. Either don't support their Google stuff or make sure you have documented that they use Google SAS against your advice.
C - the footgun of programming languages
If they wanna do it, they gotta get a lawyer--a lawyer who knows HIPAA. HIPAA compliance is a pain--and noncompliance can be very expensive.
Lawyer costs may even outweigh the Google savings
As a Paramedic, I can say that HIPPA is extremely strict and will, if violated, force your license to be questioned as well as cause fines to be pushed your way. Honestly, doing ANYTHING outside of a secured network or a patient care medium (i.e. Pyxis, Temsis) with privileged, confidential information will plant a bullseye on your back. It is just not worth risking it. I can guarantee that an expert data thief is going to be more skilled and knowledgeable at computers and networking than any physician I know.
Your role, as a qualified member of the IT staff, is to make the higher-ups aware of the risks. Do your due-diligence, tell them the data isn't secure (in person, in e-mail, and maybe even on paper), and remind them from time-to-time (using creative new analogies whenever possible). That's it, you've done your job.
The fact of the matter is, regardless what the policy is, and regardless what they all "agree" on, they're going to put sensitive information on the Web. You'd have to take away their Internet access and portable devices to prevent it, and even then, they'd just go home and use that.
Accept that the best you can do is educate them and provide alternatives.
I'd like to report them to the regulatory commission that enforces HIPAA rules.
Seriously, read up on HIPAA and get them to follow HIPAA rules, otherwise huge fines could be coming their way.
Just because a doctor hands out those privacy pamphlets doesn't give them the green light to ignore or circumvent the privacy and security rules. Claiming ignorance is not an option.
Get them off of gmail and google apps and put them on systems and networks that you can effectively apply controls too.
You have no control over the security and privacy controls in place within google apps thus you can't effectively satisfy the HIPAA rules.If they do not want to do an internal networks with servers, outsource it all to a data center that is HIPAA compliant and where you control the servers both physically and logically.
Good luck and hire yourself a partner or subcontractor that does HIPAA and SOX regulatory consulting. You could hire me but I'm $350/hr.
Amazon published a white paper about using their AWS platform with HIPAA compient applications: basic idea is to keep data encrypted until it is in memory, and encrypt it again before writing to persistent storage.
For Google Apps, how about using rich clients that decrypt data for viewing/editing, and encrypt it again before storing back on big table, etc.
Perhaps Google themselves would implement this as browser plugins?
We are a contractor for the Veterans administration. The VA insists that we comply with privacy issues strictly. Any communications that have patient information must be sent on encrypted secure systems. No open email servers/hotmail/gmail/whatever is allowed. Failure to comply with the privacy (detailed in the out of control HIPAA set of rules and standards) is punishable both financially and by being banned from contracting with the US federal government. As an administrator, I have to remind physicians that if they are caught transmitting identifiable information of our patients over unsecured channels, it may cost us our contract and may result in their being banned from seeing medicare/medicaid patients. Anyhow, that's my two cents on utilizing gmail or such for sensitive information.
The Google Mini (http://www.google.com/enterprise/search/index.html) is a search appliance. It will not run mail/apps.
Some stories are red to show that they were posted by a communist.
signature is pants
I think there are three classes of company for the purposes of this discussion:
If you trust shared hosting providers; you shouldn't care about the Google employees who can access your data
If you trust managed hosting providers like Rackspace, particularly if they're hosting virtualised servers for you; you probably shouln't care about Google employees with access to your data.
If you don't trust managed hosting providers; well you're probably not reading this from the office, and Google Apps doesn't get a look in.
I'd say most companies fall into the second.
Agreed. Also online aps are more-expensive longterm. For example I purchased Microsoft Office 97, and I'm still using it 12 years later, which is an annual cost of just ~$12. Online aps have significantly higher fees than that.
There's also the advantage of owning the software. If for example you develop a design, you can archive both the design and the tools so they can still be used 15-20 years from now and "resurrected" from the basement. You can't do that with online aps which are constantly updated with no way to "freeze" a tool at a certain point.
"I disapprove of what you say, but I will defend to the death your right to say it." - historian Evelyn Beatrice Hall
I dislike MS as much as the next /.er but if your company allows your Exchange server to call home to Microsoft, for anything other than patching, your network admin needs to be fired.
That would never work for our military projects. Everything has to stay within the building's walls, including email.
"I disapprove of what you say, but I will defend to the death your right to say it." - historian Evelyn Beatrice Hall
No matter how ironclad the agreement or how draconian the penalties your data will still be public. Sue Google into non existence and well your data is still public.
Without physical security there is no security.
If you don't own the box and control access yourself there is no physical security.
Yea, but I own the network.
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Agreed. Also online aps are more-expensive longterm. For example I purchased Microsoft Office 97, and I'm still using it 12 years later, which is an annual cost of just ~$12. Online aps have significantly higher fees than that.
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Do you really think it's wise or responsible to be using a piece of closed-source software (and one not known for its security, to say the least) so many years after the vendor has stopped supporting or releasing patches for it, and for which known exploits are in the wild?
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In what way does, for example, Google Apps Standard Edition ($0/year), cost more -- either up-front or in the long term?
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Do you not think using current tools at the time to produce a file, then ensuring the file is stored in an industry-standard open file format (such as ODF, RTF, plain text, HTML, TeX, or PDF -- or even better, more than one), is an acceptable archive, without needing to also archive a copy of (or later run) a dated (and bug-ridden and proprietary, in this case) application along with it -- which may not even run on machines "15 or 20 years" later, as you mention?
Once something is on Google, the up side is: any computer with internet access can log in and access it. The down side is the same: any computer with internet access can log in and access it.
If something is on your internal network, that already puts a bit of a limit on who can access those files. It's not bulletproof, and you can still get rooted, but it's a limit. The average Tom, Dick and Harry are as good as physically separated from that data, even if they can guess your password.
Once that stuff is on Google, essentially anyone who can guess your password is good to go.
For example, you only need one employee who uses the same password everywhere (it happens more often than you'd think) and has ever shared their home email password with their spouse, or their WoW account with the chinese guy who power-levelled it, or whatever. Or they only need the same password somewhere where you need to guess their mother's maiden name to get that password. (Again, you'd be surprised how many put the real maiden name there.)
Or some passwords are that easy to find out, because they're weak. People use their nickname, or pet's name, or whatnot as passwords all the time.
Some passwords aren't even kept secret. I know the logins for a local hospital _and_ the emergency medical service, without ever having worked there, just because the former was taped to the monitor and the latter was spoken out loud while I was there. And yes, apparently veryone there used the same. So every ex-employee knows those too. Plus any patient who can read or has ears.
So, ok, now you know a name and password for the hospital computers. Now what?
In a traditional IT scenario, they're only accessible from the internal network. Sure, you can try to sneak into a room and use their computer, but you can be caught, so most people won't. Sure, you can try to get them rooted somehow, but again most people wouldn't even know how.
Now move those files on Google, and you have a real extra problem. If that hospital ever moves its data to Google, every single patient who ever read the post-it on a monitor, can try it from their own home. No having to sneak anywhere, no risking that someone walks in on you, no l33t haxxx0r skillz needed. Just point your browser at Google, log in as a doctor, and read the medical data of everyone who ever used that hospital.
A polar bear is a cartesian bear after a coordinate transform.
which leads to
pgp is fine for a small practice to use between say the receptionist and the doctor. the problem with using pgp to obtain your confidentiality with respect to HIPAA is that emails sent from outside sources (e.g. patients) are subject to HIPAA as well, and unless you can convince all their customers to use pgp, that'll never work.
My advice for the original asker is to take a firm stand with your clients. If there is any way that they can pin the liability on you for recommending use of google apps or other online services they will when the lawyers come knocking. I suggest you strongly recommend against it, in writing, and keep that recommendation on file.
This comment is fully compliant with RFC 527.
Do you really think it's wise or responsible to be using a piece of closed-source software (and one not known for its security, to say the least) so many years after the vendor has stopped supporting or releasing patches for it, and for which known exploits are in the wild?
Word/Excel/Powerpoint? I really wouldn't worry about it, as long as they meet his needs. (Although, I'd consider giving OO.o a try.)
Outlook - yeah, I'd suggest he pony up for a new copy, or switch to something else.
In what way does, for example, Google Apps Standard Edition ($0/year), cost more -- either up-front or in the long term?
Lost productivity.
1) Lost productivity when the local ISP or some some intermediate router is down? Multiply by each user. (In a lot of places that's pretty significant. Lots of places suffer multiple hours of network down time / flaky internet every month.)
2) Lost productivity as your employees are clicking on google ads and browsing online when they should be working on that spreadsheet or word document, or simply lost productivity as the ads become insufferably intrusive and distracting.
Think about it... you are getting standard edition for "free". Google wouldn't do unless some non-trivial number of users is READING and CLICKING on those ads. If your secretary is working on a budget spreadsheet, and gets distracted by an google ad in the corner of her spreadsheet, gets distracted and clicks on it, and goes browsing for 20 minutes as a result... that costs you money. And THAT is PRECISELY what your beloved partner google is counting on. THAT is their entire business model. Give you the app for free, and then extract a profit by luring your staff to click ads instead of work.
Now you might counter that google ads are unobtrusive and easily ignored. That's true to a point, but I find adds in my productivity apps VERY distracting; far more than I do on the web. I personally won't use ad supported software, but don't find them nearly so distracting on the web. Maybe its just me... But face facts google is a multi-billion dollar advertising company as direct result of people not ignoring those ads. So the ads =DO= work. Maybe YOU don't click them, but SOMEBODY is. And every time they work on someone in your company they cost you money.
I don't object to google apps for home and noncommercial use, and their 'premium' stuff is ad free, as you are now paying them directly for service.
But a business owner who gets his staff to use standard edition? Its idiotic... what's next? Will you switch to "free" printer toner from the Jehova's Witnesses, and in exchange they'll have witnesses wander around your office to spread the good news?
Do you not think using current tools at the time to produce a file, then ensuring the file is stored in an industry-standard open file format (such as ODF, RTF, plain text, HTML, TeX, or PDF -- or even better, more than one), is an acceptable archive, without needing to also archive a copy of (or later run) a dated (and bug-ridden and proprietary, in this case) application along with it -- which may not even run on machines "15 or 20 years" later, as you mention?
What makes you so confident ODF will be readable in 20 years by Google Apps, or that a google apps will even exist? All ODF being a standard ensures is that you WILL be able to write something that can read it 20 years from now, because the specification is documented and public. There is no gaurantee google apps or anything else will run it 20 years from now. And if you are looking to archive ODF, you should probably make a point of storing something that can actually read it too, ideally along with its source, unless you want to gamble on having to implement something yourself from scratch 20 years from now.
Google apps doesn't enable you to avoid making your own backups, and if anything google apps, makes it slightly more complicated. Google apps could disappear tomorrow (unlikely in the immediate future, but possible, and who knows what the more distant future holds; companies have been shut off before), so not only do you need backups, but you should have some means of reading them too... because you can't rely on google apps being available or supporting the files.
You forgot the other side of the coin:
Many people seem to believe that using something like Google Docs is just like using MS Office, but the reality is that it's fundamentally different in many ways. Nearly ubiquitous accessibility, collaborative tools, change history, backups, etc. The amount of productivity and work that saves alone is WAY more than any time you could lose due to advertising in my estimation. Your comparison is absurd and poorly thought out as well, because "getting toner from Jehovah's Witnesses does not give you any benefit other than getting it for free. Using cloud authoring software compared to personal software is COMPLETELY different for the reasons I listed above and others.
The fact is that neither one is REALLY better than the other, it all depends on the task at hand, as both approches have their strengths and weaknesses. If I'm just writing a quick letter, then I'm going to use Word or OO, but if the file itself is going to be used over an extended period of time, and especially viewed or contributed to by others, I find it makes more sense to use Google Docs.
Plus, I can't count how many times I've worked with a team on something and wound up using a Google Doc as what essentially amounts to a massive whiteboard to outline our plan of attack and add our ideas and solutions to the task at hand, as well as comment on others.
HIPAA requires ePHI to be protected both in transit and at rest (on disk). Google will tell you flat out that your data is not sufficiently protected (eg encrypted) at rest to qualify as being HIPAA compliant. Obviously you can use SSL during transit but that doesn't solve the whole equation. Google apps, flat out, are not HIPAA compliant, and google will be the first to tell you that.
1) Lost productivity when the local ISP or some some intermediate router is down? Multiply by each user. (In a lot of places that's pretty significant. Lots of places suffer multiple hours of network down time / flaky internet every month.)
Google Chrome supports offline use of google apps.
2) Lost productivity as your employees are clicking on google ads and browsing online when they should be working on that spreadsheet or word document, or simply lost productivity as the ads become insufferably intrusive and distracting.
Only the standard free version is ad based. If you upgrade to the premium the ads are gone. For anything serious like outlook integration, you need google apps premium.