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Mitigating human error in email handling to prevent HIPAA breaches

Written by Tshedimoso Makhene | June 14, 2024

According to the study Human Factors in Electronic Health Records Cybersecurity Breach: An Exploratory Analysis, unintentional human errors, such as misdirected emails, phishing attacks, or carelessness, account for 73.1% of data breaches and compromised 141 million records between 2015 and 2020. These findings indicate that even the most advanced security infrastructure can be undermined by everyday human behavior.

 

Understanding the risk landscape

Human error accounts for a substantial portion of HIPAA breaches involving email. Whether it's sending emails to the wrong recipients, failing to encrypt sensitive information, or falling victim to phishing attacks, these mistakes can lead to unauthorized disclosures of protected health information (PHI). The above study Human Factors in Electronic Health Records Cybersecurity Breach: An Exploratory Analysis, further "revealed that 382 incidents, or 26 percent of all human factor-based breaches, were due to an insider's carelessness, negligence, or apathy. In each of these cases, no malicious intent was visible in that there was no intent to access patient data, but a data breach occurred." This suggests that most breaches are not the result of disgruntled employees or external hackers alone, but of well-meaning staff navigating complex systems under time pressure. Clinicians, administrators, and billing personnel often juggle multiple responsibilities, increasing the likelihood of mistakes, especially when email systems lack built-in safeguards.

Email-related breaches are particularly risky because they often contain a large volume of PHI and may go undetected for extended periods. A single misaddressed email can expose diagnoses, test results, insurance information, and other identifiers.  Such breaches may trigger HIPAA breach notification requirements and reputational damage.

 

Strengthening technical safeguards

The HIPAA Security Rule mandates the implementation of technical safeguards when handling electronic PHI. According to the HHS, “Implementation of the Technical Safeguards standards represent good business practices for technology and associated technical policies and procedures within a covered entity.” 

Regulated entities must use HIPAA compliant email services with built-in encryption to safeguard PHI during transmission. Encryption ensures that even if intercepted, emails containing sensitive patient data remain protected from unauthorized access.

Additionally, these entities should implement robust email filters and data loss prevention (DLP) solutions to scan outgoing emails for PHI. These tools help detect and prevent accidental disclosures by flagging sensitive information before it leaves the organization’s network. 

HIPAA’s technical safeguards also require entities “implement electronic procedures that terminate an electronic session after a predetermined time of inactivity.” This ensures that even if healthcare providers don’t have the time or forget to log off a session, the risk of accidental PHI exposure is minimized.  

 

Enhancing staff training and awareness

HIPAA requires workforce training under both the Privacy Rule and the Security Rule. Under the Privacy Rule, regulated entities must provide role-based training to all employees, ensure new hires are trained soon after onboarding, and offer refresher or updated training when policies or regulations change. Ongoing education is encouraged to reinforce compliance.

Under the Security Rule, organizations must also train staff on safeguarding electronic PHI by providing regular security reminders, educating employees on identifying and reporting malicious software and phishing attempts, monitoring login activity for suspicious behavior, and following best practices for password management. Together, these requirements ensure staff are equipped to protect PHI and maintain HIPAA compliance.

Furthermore, HIPAA-regulated entities must provide continuous education on HIPAA regulations, focusing on proper email protocols, encryption requirements, and recognizing phishing attempts.

It is also good practice to regularly conduct simulated phishing exercises to assess staff susceptibility to phishing scams. These simulations provide valuable insights into vulnerabilities and allow organizations to refine their training programs accordingly. They also help reinforce the importance of vigilance when handling sensitive information via email.

Related: Tips to spot phishing emails disguised as healthcare communication

 

Developing and enforcing policies

Regulated entities must define specific guidelines for email usage, including protocols for verifying recipients, using blind carbon copy (BCC) when necessary, and mandatory encryption of emails containing PHI. Clear policies ensure consistency and compliance across the organization.

If applicable, they must also establish policies governing the use of personal devices for work-related emails and accessing PHI. These policies should outline security measures such as device encryption and remote wipe capabilities to mitigate risks associated with mobile access.

 

Creating an effective incident response plan

Develop a comprehensive plan outlining steps for detecting, containing, and mitigating email-related breaches. Include procedures for reporting incidents, assessing the scope of exposure, and notifying affected parties promptly to comply with HIPAA breach notification requirements.

Continuously review and update email security protocols in response to emerging threats and lessons learned from past incidents. Regular audits and assessments help identify vulnerabilities and ensure that security measures remain effective. 

 

How Paubox can step in

Paubox helps healthcare organizations reduce the risk of human error in email handling by making HIPAA compliance simple, automatic, and built into everyday workflows. Rather than relying on staff to remember when to encrypt messages or identify PHI correctly, Paubox shifts much of the compliance burden from individuals to technology.

 

Automatic, always-on encryption

Paubox encrypts all outbound emails by default, without requiring staff to click extra buttons, add keywords to subject lines, or change how they send email. This reduces the risk of unintentional non-compliance caused by forgetfulness, time pressure, or misunderstanding of HIPAA requirements. Emails containing PHI are protected automatically, even if a user does not realize sensitive information is included.

 

Preventing misdirected and risky emails

By integrating directly with existing email systems, Paubox helps organizations maintain secure communication without disrupting workflows. This approach minimizes common errors such as sending unencrypted PHI, replying to insecure patient emails, or forwarding sensitive information without proper safeguards. This is especially valuable in high-volume environments where staff send dozens of emails daily.

 

Supporting phishing awareness and defense

Paubox’s advanced threat protection helps identify and block malicious emails before they reach employee inboxes, reducing the likelihood that staff will accidentally click on harmful links or download infected attachments.

 

Simplifying compliance and training efforts

Paubox automates encryption and enforces secure email practices, therefore reinforcing HIPAA training by aligning technology with policy. Staff can focus on patient care and administrative tasks rather than worrying about the technical details of compliance. This makes ongoing training more effective, as employees are supported by systems designed to prevent mistakes rather than punished for them.

 

Strengthening audit readiness and risk management

Paubox helps healthcare organizations demonstrate reasonable and appropriate safeguards under HIPAA by reducing reliance on manual processes. By lowering the risk of human error and strengthening email security, Paubox supports a stronger overall compliance posture and helps organizations better withstand audits, investigations, and breach-related scrutiny.

 

FAQs

What should I do if I accidentally send an email containing PHI to the wrong recipient?

If you accidentally send PHI to the wrong recipient, immediately notify your organization’s HIPAA compliance officer or IT security team. They can assess the situation, determine the potential risk, and take appropriate steps to mitigate harm.

 

Can email encryption alone ensure HIPAA compliance for transmitting PHI?

Email encryption alone is not enough for HIPAA compliance. Organizations should also enforce strong access controls, train staff on secure email practices, and implement policies to prevent unauthorized access or disclosures.

 

What are some best practices for securely storing email communications containing PHI?

Best practices for securely storing email communications containing PHI include retaining emails in secure, encrypted storage systems that restrict access to authorized personnel only.