this was exactly what I have suggested in my previous message.  I agree, the
solution that I would recommend should be able to non-invasively monitor
multiple systems and hard drives, and even lab equipment if applicable and
should log all the information in the central location with reports
available for audit purposes.  The are to companies on the market that
provide such capabilities and both came from the pharma arena, where FDA was
long time ago focusing on security and privacy of electronic records.  If
you would like I could readily provide more information.

On one of the recent Barnett sponsored conferences on HIPPA and 21 CFR Part
11 Security regulations, I was actually presenting the topic of the
commonalities and differences between the two regulations and way to comply
with both at the same time.  The idea is simple:  Focus on data security and
traceability and then find the right solution on the market.  The mane
criteria for the solution should be : 
that what ever solution you chose you should not need to change your
existing systems a bit and it should not interfere with your regular
operations.

Jacob Vishnevsky
Stelex-TVG 
Two Greenwood Square, Suite 310 
3331 Street Road 
Bensalem, PA 19020 
phone: (215) 352-1133
cell:(215) 421-8539 
fax: (215) 638-9333 
email: [EMAIL PROTECTED] <mailto:jvishnevsky@;stelex.com> 



-----Original Message-----
From: Marshall E. Fryman [mailto:mfryman@;futuraintl.com]
Sent: Thursday, October 24, 2002 5:56 PM
To: WEDI SNIP Privacy Workgroup List
Subject: RE: Privacy issues


Thin client is a very expensive solution to this problem. By the time you 
deploy all the various licenses that Microsoft requires and purchase a 
server capable of running the clients, you would be talking about several 
thousand dollars as a minimum. You would also be relying on the inherent 
logging system of MS to make this work. Their logging system appears to be 
very poor when dealing with a significant amount of logged traffic.

I was hoping for a background service application that would monitor file 
access activity and record it in a DB that would then have various report 
capabilities. If there isn't one readily available, we can certainly 
develop one, I was just hoping that someone had already discovered an easy 
means of logging access to files that are outside the normal data set of 
the record keeping systems but still needed to maintain HIPAA compliance.

m

At 05:11 PM 10/24/2002 -0400, you wrote:

>Marshall,
>
>Did you consider deployment of thin clients?  Your logs would then id all 
>access.
>
>Jake Mazur
>GovConnect
>A Subsidiary of govONE Solutions
>15 Piedmont Center, Suite 1200
>3575 Piedmont Road NE
>Atlanta, GA 30305
>Home Office:  704.554.0026
>[EMAIL PROTECTED]
><http://www.govconnect.com/>http://www.govconnect.com/
>
>-----Original Message-----
>From: Marshall E. Fryman 
>[<mailto:mfryman@;futuraintl.com>mailto:mfryman@;futuraintl.com]
>Sent: Thursday, October 24, 2002 3:24 PM
>To: WEDI SNIP Privacy Workgroup List
>Subject: RE: Privacy issues
>
>---
>Thanks to everyone who responded to my original question (quoted below.) My
>reason for asking is that I represent a niche software manufacturer for
>health care and am looking to develop a recommendation for our accounts in
>regards to "best practices." We are already implementing tracking of
>information that is stored in our database regarding who entered the
>information, last modified it, etc. There will be full temporal access to
>the history of the records so you can easily move backward and (if starting
>from an earlier period) forward in time in relationship to a given record.
>
>The problem that I have found to be consistent across all of our accounts
>is that they frequently have confidential information stored in letters,
>spreadsheets, etc. that they have developed to do some specific task.
>Unfortunately, the client rarely informs us of these alternative items and
>they are not using our software which will be able to protect and audit
>access to the data. One of the solutions that will correct unauthorized
>access to the data is to recommend the deployment of Windows NT machines.
>Is anyone aware of an audit system that will identify access to word
>processor / spreadsheet / other documents with the same temporal
>information and could hopefully be written into a database? Windows 2000
>domains support audit policies that would appear to do this; however, our
>experience suggests that this system is very poor at tracking anything over
>a long period of time.
>
>Thanks,
>Marshall



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on this listserv therefore represent the views of the individual participants, and do 
not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If 
you wish to receive an official opinion, post your question to the WEDI SNIP Issues 
Database at http://snip.wedi.org/tracking/.   These listservs should not be used for 
commercial marketing purposes or discussion of specific vendor products and services.  
They also are not intended to be used as a forum for personal disagreements or 
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