PostgresSQL and HIPAA compliance

On Jun 17, 2016, at 3:03 AM, Alex John <alex.john@holmusk.com> wrote:

Hello, I have a few questions regarding the use of PostgreSQL and HIPAA
compliance. I work for a company that plans on storing protected health
information (PHI) on our servers. We have looked at various solutions for doing
so, and RDS is a prime candidate except for the fact that they have explicitly
stated that the Postgres engine is *not* HIPAA compliant.

There's nothing fundamental to postgresql that would make HIPAA compliance
difficult, and *probably* nothing major with the way it's deployed on RDS. Actual
certification takes time and money, though.

Users on the IRC channel generally say that the guidelines are more catered
towards building better firewalls and a sane access policy, but I would like to
know if there is anything within the implementation of Postgres itself that
violates said compliance.

If anyone works at a similar company and utilizes postgresql to store PHI,
please let me know.

EnterpriseDB are helping provide HIPAA compliant postgresql on AWS; it
might be worth having a chat with them.

http://www.enterprisedb.com/postgres-plus-edb-blog/fred-dalrymple/postgres-meets-hipaa-cloud
http://www.slideshare.net/EnterpriseDB/achieving-hipaa-compliance-with-postgres-plus-cloud-database

Cheers,
Steve

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The method you use to store the data is irrelevant. Access to your network.
Logging. If you're encrypting the disk. How is the application presenting
this data. What kind of ACLs are you using. Asking if PG is good to store
HIPAA data is exactly as useful as asking if you can even store HIPAA data.
There are so many more important things to consider.

RDS is a hosted service. They don't have all the guarentees you'd want for
PHI. I'm sure they're MySQL engine probably has similar warnings.

Jim

On Fri, Jun 17, 2016 at 6:03 AM, Alex John <alex.john@holmusk.com> wrote:

On 06/17/2016 03:03 AM, Alex John wrote:

Hello, I have a few questions regarding the use of PostgreSQL and HIPAA
compliance. I work for a company that plans on storing protected health
information (PHI) on our servers. We have looked at various solutions for doing
so, and RDS is a prime candidate except for the fact that they have explicitly
stated that the Postgres engine is *not* HIPAA compliant.

Correct but that isn't a Postgres problem, it is an RDS one.

Users on the IRC channel generally say that the guidelines are more catered
towards building better firewalls and a sane access policy, but I would like to
know if there is anything within the implementation of Postgres itself that
violates said compliance.

No.

If anyone works at a similar company and utilizes postgresql to store PHI,
please let me know.

We do (see sig) for multiple companies and it is fully compliant.

Your issue isn't PostgreSQL.

JD

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On 06/17/2016 03:03 AM, Alex John wrote:

RDS is a prime candidate except for the fact that they have explicitly
stated that the Postgres engine is *not* HIPAA compliant.

More precisely, it is not covered by the BAA Amazon will sign.

I've helped several companies run HIPAA-compliant Postgres on regular
EC2 instances (which *are* covered by your BAA, as long as they are
dedicated instances---which do cost more). So you just have to do some
of the server work yourself. If you are making the rest of your app
HIPAA-compliant anyway, it shouldn't add a large burden to do Postgres
that way too. Make sure your access rules are good, use SSL for the
connections, put it on an encrypted disk (easy these days with encrypted
EBS volumes), etc.

Slightly more effort but still very doable is handling requirements for
auditing accesses and changes. How you do this probably depends on the
rest of your stack.

Yours,
Paul

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-----Original Message-----
From: Alex John
Sent: Friday, June 17, 2016 3:04 AM
To: pgsql-general@postgresql.org
Subject: [GENERAL] PostgresSQL and HIPAA compliance

Hello, I have a few questions regarding the use of PostgreSQL and HIPAA
compliance. I work for a company that plans on storing protected health
information (PHI) on our servers. We have looked at various solutions for
doing so, and RDS is a prime candidate except for the fact that they have
explicitly stated that the Postgres engine is *not* HIPAA compliant.

Users on the IRC channel generally say that the guidelines are more catered
towards building better firewalls and a sane access policy, but I would like
to know if there is anything within the implementation of Postgres itself
that violates said compliance.

If anyone works at a similar company and utilizes postgresql to store PHI,
please let me know.

Thank you,
Alex

---------------------------------------------------------------------

HIPAA compliance does not specify (ever) the technical solution to meet the
requirements, so ANY datastore that can be properly managed within the
context of HIPAA compliance is legal and allowed. Ignore IRCs and search on
securing PHI on relational databases, you'll find lots of details around
data access roles, documentation, processes, data obfuscation, etc.

Mike

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On 2016-06-17 14:09, Paul Jungwirth wrote:

On 06/17/2016 03:03 AM, Alex John wrote:

RDS is a prime candidate except for the fact that they have explicitly
stated that the Postgres engine is *not* HIPAA compliant.

More precisely, it is not covered by the BAA Amazon will sign.

I've helped several companies run HIPAA-compliant Postgres on regular
EC2 instances (which *are* covered by your BAA, as long as they are
dedicated instances---which do cost more). So you just have to do some
of the server work yourself. If you are making the rest of your app
HIPAA-compliant anyway, it shouldn't add a large burden to do Postgres
that way too. Make sure your access rules are good, use SSL for the
connections, put it on an encrypted disk (easy these days with encrypted
EBS volumes), etc.

Slightly more effort but still very doable is handling requirements for
auditing accesses and changes. How you do this probably depends on the
rest of your stack.

Yours,
Paul

This is what we do, we have dedicated EC2 instances for PostgreSQL
storing PHI. From my point of view, it's the same as any other server
running Linux (I can SSH in, or tunnel my DB connection). To be honest
I'd rather have it this way than deal with the RDS interface.

Try to avoid those HIPAA compliance meetings though, they are terrible
and long.

-- Stephen

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