Description

This curriculum spans the design and governance of a multi-layered phishing defense program in healthcare, comparable to an internal capability-building initiative that integrates ISO 27799 controls across risk assessment, technical deployment, third-party oversight, and adaptive awareness for clinical and administrative workflows.

Module 1: Understanding the Scope and Applicability of ISO 27799 in Healthcare Organizations

Determine which departments handling electronic health records (EHR) must comply with ISO 27799 controls based on data sensitivity and regulatory exposure.
Map clinical, administrative, and third-party systems to ISO 27799’s information asset inventory requirements, including mobile devices used by physicians.
Decide whether cloud-based patient portals fall under organizational control boundaries as defined in ISO 27799 Section 5.1.
Assess jurisdictional conflicts when healthcare providers operate across regions with differing privacy laws (e.g., HIPAA vs. GDPR) and align with ISO 27799’s jurisdictional compliance guidance.
Document custodianship roles for patient data across departments to satisfy ISO 27799’s information classification and ownership requirements.
Implement labeling schemes for health information at different sensitivity levels (e.g., psychotherapy notes vs. appointment logs) per ISO 27799 classification rules.
Conduct a gap analysis between existing information security policies and ISO 27799’s healthcare-specific controls, focusing on patient confidentiality obligations.
Establish a process for periodic review of asset inventories to reflect changes in telehealth infrastructure and BYOD usage.

Module 2: Phishing Risk Assessment Specific to Healthcare Environments

Identify high-risk user groups such as billing staff and receptionists who frequently process insurance claims and are targeted in business email compromise (BEC) attacks.
Integrate phishing likelihood and impact into the organization’s overall risk register using ISO 27799’s risk assessment framework (A.8.1).
Quantify the potential impact of a phishing-induced ransomware event on patient care delivery, considering system downtime and data unavailability.
Select threat intelligence sources that provide healthcare-specific indicators of compromise (IOCs) for phishing campaigns.
Conduct tabletop exercises simulating phishing attacks on clinical staff to evaluate detection and response capabilities.
Define acceptable risk thresholds for phishing-related incidents based on organizational risk appetite and regulatory reporting obligations.
Map phishing attack vectors (e.g., malicious attachments in appointment confirmations) to relevant ISO 27799 control objectives.
Validate risk assessment outputs with clinical leadership to ensure operational realities are reflected in mitigation priorities.

Module 3: Designing Role-Based Awareness Programs Aligned with ISO 27799

Develop distinct phishing training content for clinicians, IT staff, and administrative personnel based on their email usage patterns and access levels.
Integrate HIPAA-compliant examples of phishing emails into training modules to reinforce real-world relevance.
Time simulated phishing campaigns to coincide with known high-risk periods, such as tax season or software update cycles.
Configure feedback mechanisms for users who report phishing attempts, ensuring timely acknowledgment and analysis of submissions.
Measure training effectiveness using metrics such as click-through rates on test emails and reporting frequency, adjusting content accordingly.
Obtain documented acknowledgment from staff that they have completed phishing awareness training, as required for audit purposes.
Coordinate with HR to embed security awareness into onboarding for new clinical contractors and temporary staff.
Revise training materials quarterly based on emerging phishing tactics observed in the healthcare sector.

Module 4: Technical Controls for Email Defense in Clinical Settings

Configure DMARC, DKIM, and SPF policies to reduce spoofed emails reaching clinical inboxes, balancing strictness with legitimate email delivery.
Implement URL rewriting in email gateways to scan links at time of click, particularly for emails containing patient portal references.
Deploy sandboxing for email attachments in environments where diagnostic imaging reports are shared via email.
Adjust spam filter sensitivity to reduce false positives on clinical correspondence while blocking known phishing domains.
Enforce TLS encryption for all email transmissions involving protected health information (PHI), including third-party referrals.
Integrate email security logs with SIEM systems to correlate phishing attempts with other suspicious activities.
Whitelist critical medical device vendors’ IP addresses while maintaining attachment scanning for those sources.
Disable automatic image loading in clinical email clients to prevent tracking by phishing actors.

Module 5: Securing Clinical Communication Channels Beyond Email

Assess the use of consumer messaging apps (e.g., WhatsApp) among clinical teams and enforce policy-compliant alternatives.
Configure secure messaging platforms to prevent forwarding of PHI to unauthorized recipients, aligning with ISO 27799 access control requirements.
Implement endpoint controls on tablets used in patient rooms to prevent phishing via malicious browser pop-ups.
Monitor for phishing attempts in patient-facing portals, such as fake appointment reminders with malicious links.
Restrict USB port access on clinical workstations to prevent malware introduction via phishing-induced social engineering.
Enforce multi-factor authentication (MFA) on all telehealth platforms to mitigate account takeover from credential harvesting.
Evaluate the security posture of third-party scheduling systems that send automated SMS reminders containing clickable links.
Conduct regular audits of communication logs to detect unauthorized data sharing initiated through phishing compromises.

Module 6: Incident Response Planning for Phishing-Induced Breaches

Define escalation paths for suspected phishing incidents involving clinical staff, ensuring minimal disruption to patient care.
Establish criteria for declaring a phishing event a reportable breach under HIPAA, based on data exfiltration evidence.
Pre-stage forensic toolkits for rapid deployment on compromised clinical workstations without affecting EHR availability.
Coordinate with legal counsel to preserve chain of custody for evidence collected during phishing investigations.
Activate communication protocols to notify patients when PHI is confirmed exposed due to a phishing attack.
Integrate phishing response playbooks into existing disaster recovery plans, particularly for ransomware scenarios.
Conduct post-incident reviews to determine if controls failed or were bypassed, updating policies accordingly.
Ensure backup systems are isolated and immutable to prevent deletion during phishing-triggered ransomware attacks.

Module 7: Third-Party Risk Management in Healthcare Ecosystems

Require business associates to demonstrate phishing resilience controls as part of vendor risk assessments.
Include contractual clauses mandating prompt reporting of phishing incidents involving shared patient data.
Verify that third-party billing services apply email security controls equivalent to internal standards.
Conduct phishing simulations on vendor staff with access to the organization’s EHR system.
Restrict data access for external partners using role-based permissions aligned with the principle of least privilege.
Monitor third-party login activity for anomalies indicating account compromise from credential phishing.
Perform on-site audits of large vendors to validate implementation of phishing awareness and detection controls.
Terminate data-sharing agreements with vendors that repeatedly fail phishing security requirements.

Module 8: Audit and Compliance Validation for Phishing Controls

Prepare evidence for auditors showing alignment between phishing defenses and ISO 27799 control A.12.2.1 (technical vulnerability management).
Generate reports demonstrating frequency and outcomes of phishing simulations for compliance documentation.
Verify that access logs for systems containing PHI are retained for the duration required by organizational policy and law.
Conduct internal audits of email gateway configurations to ensure anti-phishing controls are active and updated.
Review user access rights semi-annually to detect unauthorized privileges that could result from phishing-based privilege escalation.
Validate that incident response plans have been tested within the past 12 months, including phishing scenarios.
Document exceptions to phishing control implementations, including justifications and compensating controls.
Coordinate external audits with healthcare regulators to demonstrate proactive phishing risk management.

Module 9: Continuous Improvement and Adaptive Governance

Establish a feedback loop from helpdesk reports to refine phishing detection rules in real time.
Update risk assessments annually to reflect changes in telemedicine adoption and associated phishing exposure.
Adjust awareness training content based on analysis of actual phishing emails blocked by email filters.
Introduce adaptive authentication for users who repeatedly fall for simulated phishing attempts.
Benchmark phishing resilience metrics against peer healthcare institutions using industry reports.
Revise governance policies to address new attack vectors such as AI-generated voice phishing (vishing) targeting call centers.
Engage clinical leadership in quarterly security reviews to maintain alignment with care delivery priorities.
Allocate budget for emerging tools like AI-driven email anomaly detection based on demonstrated ROI from incident reduction.

Phishing Attacks in ISO 27799