Mapping HIPAA to ISO 27001: A Comprehensive Guide

Two Foundational Frameworks: ISO 27001 and HIPAA

With the growing number of risks in the information security space, a standardized approach is crucial to protecting an organization’s operations. Two foundational frameworks for data protection and security are HIPAA and ISO 27001. Given the completely different contexts of these two frameworks, it’s odd to put them together in one comparison. However, there are entities that need to comply with both of these standards. Read on as we discuss the common ground between these two standards.

HIPAA is a US legislation that regulates the use of all protected health information transmitted by healthcare organizations. It also prohibits healthcare organizations from disclosing personal information without the individual’s consent. 

ISO 27001 specifies the requirements for establishing, implementing, maintaining, and continually improving an Information Security Management System (ISMS). These requirements describe the intended behavior of an ISMS, once it is fully operational. The standard is not a step-by-step guide on how to build or create an ISMS, but rather a set of risk-based specifications and controls. Organizations that meet these specifications can show that they have the security controls in place to address the confidentiality, integrity, and availability of their system and data.

While HIPAA and ISO both deal with securing sensitive information, they cover different jurisdictions and scopes. Compliance with the more holistic ISO facilitates compliance with the health-information-specific HIPAA requirements.

Examples of health-related data that are addressed in both ISO 27001 and HIPAA are listed below.

• personal health information
• pseudonymized data derived from personal health information via some methodology for pseudonymous identification
• statistical and research data, including anonymized data derived from individual health information by removal of personally identifying data
•  clinical/medical knowledge not related to any specific subjects of care, including clinical decision support data (e.g. data on adverse drug reactions)
• data on health professionals, staff, and volunteers
• information related to public health surveillance
• audit trail data, produced by health information systems that contain personal health information, or pseudonymous data derived from personal health information, or that contain data about the actions of users with regard to personal health information
•  system security data for health information systems, including access control data and other security-related system configuration data for health information systems.

Diving into HIPAA Compliance: What You Need to Know

The Health Insurance Portability and Accountability Act of 1996 (HIPAA) is a law in the US that oversees the privacy and security of protected health information (PHI). It applies to covered entities and their business associates. Covered entities include health plans, healthcare clearinghouses, and healthcare providers.

HIPAA compliance is required of any organization that electronically transmits health information. Covered entities are required to perform periodic technical and nontechnical evaluations to prove HIPAA compliance. While there is no official certification body and no HIPAA certification, the legislation is enforced by the US Department of Health and Human Services Office for Civil Rights (OCR). Any violations or failure to comply results in steep financial penalties.

The Importance of HIPAA Compliance

HIPAA compliance is critical for healthcare organizations that handle PHI. Failure to comply with HIPAA can lead to financial penalties and reputational damage. HIPAA compliance protects patient privacy, ensures the security of sensitive information, and builds trust between healthcare organizations and their patients.

Diving into ISO 27001 Certification: What You Need to Know

ISO 27001 is one of the most widely recognized global security standards. While ISO 27001 certification is optional, any organization that wants to formalize and improve its protection of sensitive data information can benefit from adhering to the standard. Some organizations may further require their service providers or third-party contractors to attain certification before engaging in a business contract.

Two Major Stages of Iso 27001 Certification 

Stage 1: An informal preliminary review of your ISMS

An external auditor will look over an organization’s ISMS and verify its InfoSec policies against ISO 27001 requirements, statement of applicability (SoA), and risk treatment plans (RTP).

Stage 2: A formal compliance audit

Auditors will revisit an organization’s policies and test all ISMS controls listed in the SoA against ISO 27001 requirements. They will also collect evidence to verify whether the management system is appropriately designed and implemented.

Organizations that pass the second stage will receive their ISO 27001 certification, which remains valid for three years. During this time, organizations must complete annual surveillance audits every year and then a recertification audit at the end of the third year.

The Importance of ISO 27001 Certification

ISO 27001 certification demonstrates an organization’s commitment to information security. It provides a framework for establishing, implementing, maintaining, and continually improving an organization’s information security management system (ISMS). Certification ensures that an organization’s security posture meets industry standards and helps build trust with clients and partners

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HIPAA Compliance vs. ISO 27001

HIPAA only applies to covered entities, such as healthcare providers, health plans, and healthcare clearinghouses, that transmit or maintain PHI. ISO 27001, on the other hand, can be applied to any organization that handles sensitive information, regardless of its size, location, or industry. This means that ISO 27001 can be used to protect a wide range of data, including financial information, intellectual property, and confidential business information.

While HIPAA and ISO 27001 are two different frameworks with distinct scopes, there are some overlapping areas where HIPAA clauses map to ISO 27001 controls. A comparison between the two shows that the comprehensive ISO requirements include the HIPAA requirements. As a matter of fact, ISO includes a  substantial number of additional requirements that go beyond what HIPAA requires, making ISO/IEC 27001 more holistic in nature.

Here are a few examples:

1. Risk assessments: HIPAA requires covered entities to conduct periodic risk assessments to identify potential vulnerabilities in their systems and processes. ISO 27001 also requires organizations to perform regular risk assessments to identify and address potential security risks.
2. Information security policies: HIPAA mandates that covered entities develop and maintain policies and procedures to protect the confidentiality, integrity, and availability of PHI. ISO 27001 similarly requires organizations to establish and maintain an information security policy that outlines the organization’s objectives and commitments to information security.
3. Access controls: HIPAA requires covered entities to implement access controls to restrict access to PHI to authorized individuals only. ISO 27001 requires organizations to implement access controls to ensure that only authorized individuals have access to information systems and data.
4. Physical security: HIPAA requires covered entities to implement physical safeguards to protect PHI from unauthorized access, theft, or damage. ISO 27001 requires organizations to establish physical security measures to protect information systems, data, and other assets from physical threats.
5. Incident response: HIPAA requires covered entities to establish procedures for responding to security incidents and breaches. ISO 27001 requires organizations to establish incident management processes to detect, report, and respond to security incidents and minimize their impact.
6. Business continuity: HIPAA requires covered entities to establish contingency plans to ensure the continuity of operations in the event of a disaster or other disruptive event. ISO 27001 requires organizations to establish business continuity and disaster recovery plans to ensure the timely restoration of critical business functions in the event of a disruption.

Mapping HIPAA to ISO 27001: A Practical Guide

1. Analyze and evaluate risk,  taking into account the context of the organization
2. Specify the ISO/IEC 27001 controls to be applied, and add the relevant controls to your  Statement of Applicability (SOA)
3. Cross-map HIPAA controls corresponding them ISO/IEC 27001 controls
4. Add any additional required HIPAA controls that may not be required by ISO, including the HIPAA organizational and documentation requirements.
5. Develop and implement policies and procedures applicable to the full set of selected ISO and HIPAA controls.

While HIPAA and ISO 27001 are not identical frameworks, they share some commonalities when it comes to information security. By mapping HIPAA clauses to ISO 27001 controls, organizations can identify the areas of overlap and ensure that their information security programs meet both sets of requirements. This can help organizations establish a comprehensive information security program that protects sensitive information and meets regulatory requirements.

Centraleyes Helps You Cross-Reference Between Frameworks

Whichever standard your organization is mandated to comply with, you’ll need a risk management and compliance platform with the flexibility to work with your organization’s needs. Centraleyes was built with both HIPAA and ISO standards in mind, alongside tens of other frameworks, with prebuilt references like HIPAA, NIST, and SOC 2 to ISO 27001 mappings. We empower businesses to manage their entire risk and compliance ecosystem within a single dashboard. 

Centraleyes also provides cross-references of HIPAA specifications to relevant controls in other foundational frameworks. HIPAA is designed to be flexible, scalable, and technology-neutral, which enables crosswalks between ISO, NIST, and SOC 2 HIPAA mapping.
Ready to discover how Centraleyes can become a valuable tool as you pursue HIPAA, ISO, or both? Reach out to us today and speak with a cybersecurity framework expert to learn more.