Moving sensitive patient data to a compliant archive

What was going on

The client wanted to move sensitive patient data out of Salesforce and into a compliant archive, mainly to cut storage costs. The data sat in a US data centre, was governed by HIPAA and was subject to GxP.

To complicate matters, it was under legal hold after earlier problems with auditing, handling and storage. That meant the data could not be edited, exported or destroyed.

What I was asked to do

Check what the legal hold really allowed, working with the customer’s legal, compliance and security teams and with internal ethics and security groups. Then build a compliant migration plan and prove it with a proof of concept.

• Security and auditing controls for the target archive
• Encryption at rest and in transit
• A risk assessment and a recovery plan
• Backup and immutability for archived data

What I did

I acted as the trusted advisor in the room, leading the conversations on regulatory, ethical and security questions.

• Worked with the customer’s engineers to confirm the archive met TLS/SSL standards and encryption requirements
• Guided their developers through the integration design, with QA, code reviews and user acceptance testing
• Designed around blockers so business and technical needs stayed aligned
• Wrote the risk assessment and mitigation plan, and got it through the ethics committee
• Presented the proof of concept and refined it from stakeholder feedback

What changed

The solution met the customer’s goals inside the compliance rules, with strong security controls, encryption and immutable backups.

Doing it responsibly

The point of the work was to meet HIPAA and GxP while handling the social and legal risks honestly. I argued for transparency and accountability throughout, because the people most affected were patients.