Description

This curriculum spans the equivalent of a multi-workshop program, addressing the design, implementation, and governance of remote access controls across clinical systems, third-party relationships, and enterprise security infrastructure, as typically managed through an internal healthcare security capability.

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

Determine whether ISO 27799 applies to hybrid cloud-hosted electronic health record (EHR) systems based on data residency and jurisdictional requirements.
Map ISO 27799 controls to existing HIPAA administrative safeguards to identify coverage gaps in remote access workflows.
Assess whether third-party telehealth providers fall within the scope of organizational compliance responsibilities under ISO 27799.
Define the boundary between clinical data handled under ISO 27799 and non-clinical HR data governed by ISO 27001.
Document exceptions for legacy medical devices that cannot support encrypted remote access due to firmware limitations.
Establish criteria for classifying data as "health information" under ISO 27799 when integrating wearable device data into patient records.
Coordinate with legal counsel to validate that remote access policies align with regional health privacy laws such as GDPR or PIPEDA.
Decide whether outsourced medical transcription services require full ISO 27799 alignment or a subset of controls.

Module 2: Risk Assessment for Remote Access in Clinical Environments

Conduct threat modeling for physician access to EHRs from personal mobile devices on public Wi-Fi networks.
Quantify the risk of data exfiltration via remote desktop protocols (RDP) used by off-site radiologists.
Identify high-risk user groups, such as locum tenens physicians, who may lack consistent security training.
Evaluate the impact of delayed patching on remote access endpoints used in home healthcare settings.
Assess vulnerabilities in virtual private network (VPN) concentrators supporting after-hours clinician access.
Perform penetration testing on remote monitoring systems for implanted cardiac devices.
Document residual risks associated with allowing remote access from unmanaged contractor laptops.
Integrate findings from remote access risk assessments into the organization’s overall ISMS risk register.

Module 3: Policy Development for Secure Remote Access

Define acceptable use criteria for personal smartphones accessing patient portals via mobile apps.
Specify technical requirements for multi-factor authentication (MFA) in remote access policy, including fallback procedures.
Establish time-of-day restrictions for administrative access to EHR databases from remote locations.
Prohibit the use of remote access tools like TeamViewer on clinical workstations without prior authorization.
Set password complexity and rotation rules for remote access accounts based on ISO 27799 Annex A.9.
Include clauses requiring automatic session termination after 15 minutes of inactivity on remote connections.
Outline disciplinary actions for policy violations involving unauthorized remote access to patient records.
Define data handling rules for cached clinical data on remote devices, including encryption requirements.

Module 4: Identity and Access Management Integration

Integrate physician single sign-on (SSO) systems with remote access gateways using SAML 2.0 assertions.
Implement role-based access control (RBAC) to restrict remote access based on clinical role and department.
Automate deprovisioning of remote access rights upon physician contract expiration via HR system integration.
Enforce just-in-time (JIT) access for external consultants connecting to internal diagnostic systems.
Configure conditional access policies to block remote logins from high-risk geographic regions.
Sync privileged access management (PAM) systems with remote access logs for session monitoring.
Validate identity proofing procedures for remote staff during onboarding against ISO 27799 A.5.16.
Implement dynamic access controls that adjust permissions based on device compliance status.

Module 5: Technical Controls for Secure Remote Connectivity

Deploy zero trust network access (ZTNA) to replace traditional VPNs for remote clinician access.
Enforce end-to-end encryption using TLS 1.3 for all remote EHR transactions.
Configure firewall rules to allow remote access only through designated jump servers.
Implement host-based intrusion prevention systems (HIPS) on laptops used for remote access.
Require disk encryption on all devices permitted to cache patient data during remote sessions.
Set up network segmentation to isolate remote access gateways from clinical networks.
Deploy endpoint detection and response (EDR) agents on remote devices for real-time threat monitoring.
Configure secure DNS resolution for remote users to prevent pharming attacks on patient portals.

Module 6: Secure Configuration of Remote Access Devices

Define and distribute standardized device configurations for organization-issued tablets used in home care.
Enforce automatic OS and application updates on all remote access endpoints via MDM policies.
Disable USB ports on remote devices to prevent unauthorized data transfer from clinical systems.
Implement registry-level settings to prevent caching of patient data in browser histories.
Configure remote wipe capabilities for lost or stolen devices accessing protected health information.
Restrict installation of third-party applications on remote access devices through application whitelisting.
Set up secure boot and firmware validation to prevent tampering on remote diagnostic equipment.
Validate antivirus signature update frequency on remote workstations during compliance audits.

Module 7: Monitoring, Logging, and Audit Trail Management

Aggregate remote access logs from firewalls, VPNs, and EHR systems into a centralized SIEM platform.
Define log retention periods for remote access events in accordance with legal hold requirements.
Configure real-time alerts for multiple failed login attempts from a single remote IP address.
Conduct quarterly audits of remote access logs to detect unauthorized access to sensitive records.
Preserve audit trails for remote sessions involving access to psychiatric or HIV-related patient data.
Ensure log integrity by applying cryptographic hashing and write-once storage mechanisms.
Correlate remote session durations with clinical shift schedules to identify anomalies.
Integrate remote access event data with user behavior analytics (UBA) tools for insider threat detection.

Module 8: Incident Response and Breach Management for Remote Access

Develop playbooks for responding to compromised remote access credentials used by off-site staff.
Isolate infected remote endpoints from clinical networks during active malware investigations.
Preserve volatile memory from remote devices involved in suspected data exfiltration incidents.
Notify patients and regulators when unencrypted PHI is accessed via a breached remote connection.
Conduct post-incident reviews to determine if MFA could have prevented unauthorized access.
Update remote access policies based on lessons learned from tabletop exercises simulating ransomware attacks.
Coordinate with ISPs to obtain subscriber information for malicious remote login sources.
Implement temporary access freezes during widespread phishing campaigns targeting remote clinicians.

Module 9: Third-Party and Vendor Remote Access Governance

Negotiate contractual clauses requiring medical device vendors to comply with remote access policies.
Require third-party IT support providers to use organization-controlled jump servers for remote maintenance.
Conduct annual security assessments of vendors with persistent remote access to clinical systems.
Limit vendor access to specific IP addresses and predefined maintenance windows.
Enforce dual control for remote configuration changes initiated by external engineers.
Monitor and log all remote sessions performed by vendor personnel using session recording tools.
Verify that third-party remote access tools do not store credentials in plaintext configuration files.
Terminate standing remote access privileges for vendors upon contract completion.

Module 10: Continuous Improvement and Compliance Validation

Schedule annual reassessment of remote access controls against updated ISO 27799 guidelines.
Perform internal audits to verify adherence to remote access policies across decentralized clinics.
Update risk assessments when deploying new remote monitoring technologies for chronic disease management.
Validate that remote access training content reflects current threats and policy changes.
Measure MFA adoption rates among remote clinical staff and address non-compliance.
Review firewall rule changes affecting remote access during change advisory board (CAB) meetings.
Track key performance indicators such as mean time to detect unauthorized remote sessions.
Align remote access control testing with external auditor requirements for certification readiness.