I have exciting news. My new O'Reilly book Hacker Culture: A to Z (which is already available in paperback and eBook) will be available in audiobook format on January 9th 2024.
You should be able to preorder the audiobook from audiobooks.com, Google Play, Barnes & Noble, and other retailers about 30 days before publication. Which means very soon.
TITLE: Polite Example Letter to a Health-Related Website Endangering Your Privacy
THIS is the letter I wish more people would send to health-related websites and merchants when they observe a privacy problem!
fullscript.com is a service that dispenses non-pharma products to patients (like medical grade supplements) based upon doctor's orders. You have to be referred by a physician to get a patient account. They even have a way of integrating with EHR systems.
They need to get security right.
To: Fullscript Support <[email protected]>
Dear Fullscript Team:
I have always appreciated being able to order from your excellent website.
Your service strives to supply patients with supplements and medicines ordered by doctors. As such, what is ordered can give insight into medical conditions that patients may have.
You may or may not be covered by HIPAA regulations, but I'm sure you will agree that ethically and as a matter of good business practice, Fullscript would want to maintain medical privacy of patients given that medical practices trust you.
This is why I'm concerned with the HIGH level of 3rd party tracking going on throughout your product catalogue. On your login page, the Firefox web browser displays a "gate" icon to let me know that information (I believe my email address) is being shared with Facebook. This is also the case with your order checkout page (see attached screenshot showing Facebook "gate" icon, as well as Privacy Badger and Ghostery plug-in icons in upper right-hand corner blocking multiple outbound data connections).
Privacy Badger is a web browser plugin that detects and warns of or stops (depending upon severity) outbound information from my web browser to 3rd party URLs. Directly below is Privacy Badger's report from your checkout page:
~~~~
Privacy Badger (privacybadger.org) is a browser extension that automatically learns to block invisible trackers. Privacy Badger is made by the Electronic Frontier Foundation, a nonprofit that fights for your rights online.
Privacy Badger blocked 23 potential trackers on us.fullscript.com:
insight.adsrvr.org
js.adsrvr.org
bat.bing.com
static.cloudflareinsights.com
script.crazyegg.com
12179857.fls.doubleclick.net
12322157.fls.doubleclick.net
googleads.g.doubleclick.net
connect.facebook.net
www.google-analytics.com
analytics.google.com
www.google.com
www.googletagmanager.com
fonts.gstatic.com
ad.ipredictive.com
trc.lhmos.com
snap.licdn.com
o927579.ingest.sentry.io
js.stripe.com
m.stripe.network
m.stripe.com
q.stripe.com
r.stripe.com
~~~
Please note that I was able to successfully checkout WITH Privacy Badger blocking protections on, so most of this outbound information was NOT necessary to the operation of your website.
There are several advertising networks and 3rd party data brokers receiving some kind of information.
I am aware that a limited amount of data sharing can be necessary to the operation of a website (sometimes). I am also aware that this all is not malicious -- web development and marketing does not usually talk to the legal department before deploying tools useful to gathering site usage statistics (Crazy Egg and Google Analytics). However, these conversations need to happen.
As for "de-identified" or "anonymized" data -- data brokers collect information across several websites, and so are able to reconstruct patient identities even if you don't transmit what would obviously be PHI (protected health information). As an example, if Google sees the same cookie or pixel tracking across multiple websites and just one of them sends a name, then Google knows my name. If Facebook is sent my email address (as looks to be the case), and I happen to have a Facebook account under that same email address, then Facebook knows who I am -- and can potentially link my purchases with my profile.
The sorts of computing device data that you are collecting and forwarding here may well qualify as PHI. Please see:
Use of Online Tracking Technologies by HIPAA Covered Entities and Business Associates
<https://www.hhs.gov/hipaa/for-professionals/privacy/guidance/hipaa-online-tracking/index.html>
This HHS and OCR guidance includes many 3rd party tracking technologies.
What I would really like to see happen is:
a) A thorough look at what information your website is sending out to what 3rd parties, along with an understanding of how data brokers can combine information tidbits from multiple websites to build profiles.
b) Use of alternative marketing analysis tools that help your business. For example, there are alternatives to Google Analytics that do not share all that data with Google and still give your marketing team the data they need.
c) An examination if you are sharing information about what products patients are clicking on and/or purchasing with 3rd parties. This would be especially problematic. (Crazy Egg tracks client progress through a website, but I'm unclear if they keep the information or just leave it with you.)
d) Use of alternative code libraries that are in-house. For example, web developers frequently utilize fonts.gstatic.com, but you could likely get fonts and other code sets elsewhere or store them in-house.
I appreciate you taking time to read this and working on the privacy concerns of your patients and affiliated medical practices.
Thanks.
~~~~~~
#AI #CollaborativeHumanAISystems #HumanAwareAI #artificialintelligence #psychology #counseling #socialwork #psychotherapy #EHR #medicalnotes #progressnotes @[email protected] @[email protected] @[email protected] @[email protected] @socialwork @[email protected] #mentalhealth #technology #psychiatry #healthcare #patientportal #HIPAA #dataprotection #infosec @[email protected] #doctors #hospitals #BAA #businessassociateagreement #coveredentities #privacy #HHS #OCR #fullscript
TITLE: Further Adventures in the HIPAA Silliness Zone
This short essay was inspired by a video I watched going over Microsoft legal agreements, the upshot of which is that they can harvest and use ALL of your data and creations (See *1 below in References). This inspires interesting HIPAA questions to say the least:
IF you have a HIPAA agreement with Microsoft, do they actually NOT harvest or use your data? How do they track that across all their applications and operating systems to tell?
Do their HIPAA and regular legal departments even talk to each other?
If you have a HIPAA agreement for your work computers, but then access your data through home computers, are all bets off? (And what sole proprietors don't mix use of computers for both?)
Now I don't really believe that Microsoft is doing all of this. What I THINK is that their lawyers just wrote overly broad legalese to protect them from all situations. Still -- legally it leaves us hanging. I certainly don't know that they are NOT doing it.
Then, I start thinking on some of the other crazy security situations I've encountered the past few years:
-- The multi-billion dollar medical data sales vendor that bought a calendar scheduling system, then wrote a HIPAA BAA agreement in which the PROVIDER has to pay any financial damages and penalties if THEY slip-up and lose data. (*2). Gee, what could go wrong?
-- The new AI progress notes generator service that sends data to 3rd parties including Google Tag Manager, LinkedIn Analytics, Facebook Connect, and Gravatar (*3)
-- The countless data breaches currently hitting hospitals across the USA. (*4)
It's all really quite mind numbing if you are a small healthcare provider or sole practitioner. I suspect 99% of us have just tuned this all out as noise at this point. After all, do we have the time or money to take on the legal departments of multi-billion dollar corporations?
The net results of this will be helpless nonchalance, boredom, and a gradual shifting of liability to US when upon occasion data is actually leaked by our vendors. And, of course, ever more fear and uncertainty in professions already full of it. Oh, and client data flowing through data brokers everywhere.
So what can we do? At first glance, not much. We need to be pressuring our professional associations to take on (or further take on) data security concerns including liability of giant "subcontractors" and insurance companies versus small healthcare providers. We also need to be supporting HHS and Federal government efforts to stop 3rd party trackers, including cookies, web beacons, pixel tracking, etc. from being allowable on systems related to healthcare. (*5) Bonus points if the penalties can apply mainly to larger corporations rather than hitting small provider offices hard.
Thanks,
Michael Reeder LCPC
Baltimore, MD
REFERENCES:
(*1)
The following video walks through the Microsoft Services Agreement and Microsoft Privacy Agreement to explain how Microsoft reserves the rights to use all data that you transmit through their services, or create or store in their apps (including data stored on OneDrive). It also collects information from all the programs used on your Windows machine. (This would seem to mean they can harvest data from your local hard drive, but I'm not sure.)
Microsoft Now Controls All Your Data
[https://m.youtube.com/watch?v=1bxz2KpbNn4&pp=ygUkTWljcm9zb2Z0IG5vdyBjb250cm9scyBhbGwgeW91ciBkYXRh](https://m.youtube.com/watch?v=1bxz2KpbNn4&pp=ygUkTWljcm9zb2Z0IG5vdyBjb250cm9scyBhbGwgeW91ciBkYXRh)
"("Data"), how we use your information, and the legal basis we use to process your Personal Information. The Privacy Statement also describes how Microsoft uses your content, i.e. Your communications with other people; the submissions you send to Microsoft through the Services; and the files, photographs, documents, audio, digital works, live streams, and videos that you upload, store, transmit, create, generate, or share through the Services, or any input you submit to generate content ("Your Content")."
(*2)
Full Slate: Last I checked their HIPAA, privacy, and BAA agreements. Although they reserve the right to change these agreements without notification and just post them to their website, so who knows at this point. <https://www.fullslate.com>
(*3)
Autonotes.ai: In fairness, they claim that no HIPAA data should be input into their system, even though you are writing progress notes. As of 7/30/23 they sent some sort of data to Google Tag Manager, LinkedIn Analytics, Facebook Connect, Gravatar which was severe enough that the Ghostery browser plug-in felt compelled to block or flag the transmissions. I hope they have changed this.
It should be pointed out that services similar to Full Slate and Autonotes claim that data sent to 3rd parties is not PHI and/or necessary to the operation of the service. This all could be true. I find that when Privacy Badger, or Ghostery, or my Pihole DNS server block these 3rd party transmissions that the vast majority of the time services work just fine.
Please also see Use of Online Tracking Technologies by HIPAA Covered Entities and Business Associates
<https://www.hhs.gov/hipaa/for-professionals/privacy/guidance/hipaa-online-tracking/index.html>
This HHS and OCR guidance includes the sorts of 3rd party tracking technologies often referred to as non-PHI, or de-identified. My non-lawyer mind is suspicious that violations could be found at several services.
(*4)
Just take a look at any of the daily headlines on Becker's Hospital Review:
<https://www.beckershospitalreview.com/cybersecurity.html>
(*5)
Hospital associations sue HHS over pixel tracking ban
<https://www.beckershospitalreview.com/healthcare-information-technology/hospital-associations-sue-hhs-over-pixel-tracking-ban.html>
--
#AI #CollaborativeHumanAISystems #HumanAwareAI #artificialintelligence #psychology #counseling #socialwork #psychotherapy #EHR #medicalnotes #progressnotes @[email protected] @[email protected] @[email protected] @[email protected] @[email protected] @[email protected] #mentalhealth #technology #psychiatry #healthcare #patientportal #HIPAA #dataprotection #infosec @[email protected] #doctors #hospitals #BAA #businessassociateagreement #Microsoft #coveredentities #privacy #HHS #OCR
So, the Speaker of the House of the United States of America has an app installed on is phone to "scan for porn use". An app that is granted access to scan EVERYTHING he does on his phone.
this vault has notes, papers, vendor material, books, PDFs, playlists, binaries, repositories, (nothing proprietary or employer work-product) going back to the early aughts.
I'm always a bit skeptical of presentations from tech company CEOs on
how their product areas are necessary in the mental health field.
That said, this article has a few good points:
/"Umar Nizamani, CEO, International, at NiceDay, emphasised that AI will
inevitably become an essential tool in mental health care: 'I am very
confident AI will not replace therapists – but therapists using AI will
replace therapists not using AI.'"//
/
I am beginning to think this also -- for better or worse. I took a VERY
fast 60 second look at NiceDay and it appears to be another
all-encompassing EHR, but with a strong emphasis on data. Lots of tools
and questionnaires and attractive graphs for therapists to monitor
symptoms. (I need to take a longer look later.) So data-driven could
be very good, if it does not crowd out the human touch.
/"Nizamani said there had been suicides caused by AI, citing the case of
a person in Belgium who died by suicide after downloading an anxiety
app. The individual was anxious about climate change. The app suggested
'if you did not exist' it would help the planet, said Nizamani."//
/
YIKES... So, yes, his point that care in implementation is needed is
critical. I worry at the speed of the gold-rush.
/"He [//Nizamni] //called on the industry to come together to ensure
that mental health systems using AI and data are 'explainable’,
'transparent', and 'accountable'." //
/
This has been my biggest focus so far, coming from an Internet security
background when I was younger.
/"Arden Tomison, CEO and founder of Thalamos"/ spoke on how his company
automates and streamlines complex bureaucracy and paperwork to both
speed patients getting help and extract the useful data from the forms
for clinicians to use. More at: https://www.thalamos.co.uk/
/"Dr Stefano Goria, co-founder and CTO at Thymia, gave an example of
'frontier AI': 'mental health biomarkers' which are 'driving towards
precision medicine' in mental health. Goria said thymia’s biomarkers
(e.g. how someone sounds, or how they appear in a video) could help
clinicians be aware of symptoms and diagnose conditions that are often
missed."//
/
Now THIS is how I'd like to receive my AI augmentation. Give me
improved diagnostic tools rather than replacing me with chatbots or
over-crowding the therapy process with too much automated tool data
collection (some is good). I just want this to remain in the hands of
the solo practitioner rather than being a performance monitor on us by
insurance companies. I want to see empowered clinicians.
Apparently some people have to be told that using AI services in the
cloud to compose medical letters is a violation of HIPAA.
Now what I would like to see with all the AI-assisted EHR systems
currently being developed (EPIC, Oracle, Amazon, etc.) is not only BAA
contracts in place with the tech companies, but also:
a) Separate AI systems that don't share data with the main AI system.
(So the Hospital AI database would be separate from the general AI
database), or
b) Much better: Separate AI software and databases that are held
internal to the Hospital's own computer servers with restricted Internet
access to the outside.
This is wholly feasible, yet somehow I have a low trust level of it
occurring.
For any private practice people out there playing with AI on a small
office scale, I'm not a lawyer, but what I would recommend are a) AI
systems that can be run on a desktop (not in the cloud), and b) cutting
them off from Internet or severe restrictions on where those desktops
can call out to since you likely don't know what's in the code of the AI
you downloaded!
*Iowa health system warns against using ChatGPT to draft patient letters*
<https://www.beckershospitalreview.com/cybersecurity/iowa-health-system-warns-against-using-chatgpt-to-draft-patient-letters.html>
/Iowa City-based University of Iowa Health Care is warning employees
against the use of ChatGPT for its potential to violate HIPAA.../
--
#AI #CollaborativeHumanAISystems #HumanAwareAI #chatbotgpt #chatgpt
#artificialintelligence #psychology #counseling #socialwork
#psychotherapy #EHR #medicalnotes #progressnotes
@[email protected] @[email protected]
@[email protected] @[email protected] @[email protected]
@[email protected] #mentalhealth #technology #psychiatry #healthcare
#patientportal
#HIPAA #dataprotection #infosec @[email protected] #doctors #hospitals
#BAA #businessassociateagreement
.
.
NYU Information for Practice puts out 400-500 good quality health-related research posts per week but its too much for many people, so that bot is limited to just subscribers. You can read it or subscribe at @[email protected]
.
Since 1991 The National Psychologist has focused on keeping practicing psychologists current with news, information and items of interest. Check them out for more free articles, resources, and subscription information: <https://www.nationalpsychologist.com>
.
EMAIL DAILY DIGEST OF RSS FEEDS -- SUBSCRIBE:
<http://subscribe-article-digests.clinicians-exchange.org>
.
READ ONLINE: <http://read-the-rss-mega-archive.clinicians-exchange.org>
It's primitive... but it works... mostly...
Hey, hacker fam. Quick update on what's going to be a big week.
Tomorrow I'm flying out to Bellevue and Wednesday I'm speaking at #BlueHat about the work @SophosXOps has done helping #Microsoft protect all Windows users from a very devious attack.
After I return, I'm in full-swing campaign mode running for the #BVSD#SchoolBoard. I've been doing door-knocking and meet-and-greet for days. Yesterday I spent hours giving out water to marathon runners here in #boulder
Next week though - I'll be participating in a candidate forum hosted by BVSD and you will be able to watch it live from anywhere because it will be broadcast by #livestream on BVSD's Youtube channel (https://www.youtube.com/@bouldervalleyschooldistric5781/streams). October 18 from 6pm-7:30pm MDT (UTC -6)
You can read up now on the forum and ** you can even submit questions.**
So wait building all these "secure" chat apps on a browser engine packaged in a thin layer of UI, with its insane number of dependencies and the gigantic, immense attack surface that this entails, was somehow a bad idea?
Who knew! Who could have foreseen this! Shocking, really.
I usually just browse the #InfoSec.exchange Local feed, but I think it’s time to adopt better practices and start following people. Any suggestions for the best of Infosec #Fediverse to follow?
This AI will follow along and take the session notes for the doctor by
listening to the office visit. It will also bring up charts and records
through voice command and prompt the doctor to do routine things during
the office visit. It's due out early next year.
This could be very helpful.
However I can imagine a few kinks in the office visit process initially:
Patient: "Doctor, my knee hurts"
AI: "REMEMBER TO MAKE A FOLLOW-UP APPOINTMENT"
Patient: "What was that?!"
Doctor: "Oh pay no attention -- that is just the new AI system everyone
has to consent to for treatment. It will help us during the session."
AI: "HAVE YOU EXAMINED THE KNEE X-RAY YET?"
Doctor: "AI, pull up the knee x-ray"
Patient: "This is my first visit, there is no knee x-ray yet."
AI: "REMEMBER TO SCHEDULE A KNEE X-RAY"
Doctor & Patient Together: "We don't know if we need a knee x-ray yet!"
Patient: "It started hurting yesterday"
Doctor: "Jump up on the table and I'll take a look at it"
AI: "SHALL I SUMMON A NURSE TO WATCH TO GUARD AGAINST ALLEGATIONS OF
IMPROPRIETY?"
Doctor: "NO!"
Doctor: "It does look a bit red. Does this hurt?"
Patient: "A bit when you touch there and I bend it."
AI: "SHALL I SCHEDULE THE KNEE X-RAY NOW?"
Doctor: "SHUT UP! AI -- Silent mode now!"
Office visits are going to be fun the next few years while this gets sorted.
.
.
NYU Information for Practice puts out 400-500 good quality health-related research posts per week but its too much for many people, so that bot is limited to just subscribers. You can subscribe at @PsychResearchBot
TITLE: Good Therapy Credit Card Info and Security / 3rd Party Tracking
Yes, I actually do ask myself why I bother anymore, in case you are
wondering.
This stuff is so ubiquitous now as to be all but unavoidable.
That said, perhaps multiple letters from their customers (such as the
one below) might sway thinking?
www.goodtherapy.org
Dear Good Therapy Support:
[email protected]
I just updated my payment information with a new credit card.
In order to do this, I had to turn off "Brave Shields" -- basically a
web browser feature that blocks 3rd party tracking (cookies, web
beacons, sending data out to outside URLs). The web page would not
display with shields up.
*In payment transactions on multiple other websites I have NEVER had to
turn off my 3rd party tracking blockers.**
*
This is disconcerting -- makes me wonder how secure your website is.
Please consider changing this.
Also -- although I will never use your Good Therapy Verified Seal widget
-- its abilities to collect data for tracking, analysis, and advertising
from mental health websites is in very poor judgement. This stops only
just slightly short of a HIPAA violation as anyone looking at a
therapist's website is certainly considering mental health help. Data
from multiple such widgets and trackers across websites is used all the
time by 3rd party aggregators to discover the full name and identity of
visitors.
This is disappointing behavior that has lowered my trust in your
organization.
Thanks,
Michael Reeder
#psychology #counseling #socialwork #psychotherapy #legal
@[email protected] @[email protected]
@[email protected] @[email protected] @[email protected]
@[email protected] #mentalhealth #technology #psychiatry #healthcare
#HIPAA #dataprotection #infosec @[email protected] #doctors #hospitals
#BAA #businessassociateagreement #patientprivacy #goodtherapy
.
.
NYU Information for Practice puts out 400-500 good quality health-related research posts per week but its too much for many people, so that bot is limited to just subscribers. You can subscribe at @[email protected]
So some of you might remember this post (and the subsequent demonstration on national news) of using a voice cloning tool (AI, Audio Deep Fake) by @racheltobac
(If you haven't seen it, go watch it. Rachel is amazing.)
I'd never needed to do a similar attack before, but! I was just tasked yesterday with researching it.
Asked some friends for a turn-key solution to clone voices. Got pointed to a website. Signed up for $1 a month (first month... then it goes to $5 a month thereafter).
Pulled some audio of my mark down from a youtube interview (a podcast works great too).
Only needed a minute's worth of audio.
Uploaded it to the website for cloning.
Typed out a quick script for the voice to read.
30 seconds later, I had my cloned audio.
It was so good, that it even included natural voice inflections AND!!! verbal pauses like umm's and uhh's that matched the mark's original presentation. I can't tell the difference between the cloned voice and the original person.
Y'all... voice cloning and audio deep fakes are well past the ease of "script-kiddy" level. Anyone can do it.
We're all in this together. But when we go home at the end of the day, many of us have other hobbies or interests, completely unrelated to infosec.
What is yours?
I'll start: I'm a guitar player, and heavy metal enthusiast besides. Here's a short demo I made for a zombie movie that didn't make it past the cutting room floor.
What do you do when your customers aren't watching? #infosec