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GB/T 39725-2020Information security technology—Guide for health data security (English PDF)

信息安全技术 健康医疗数据安全指南

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Issued by

SAMR; SAC

Level / Type

National · Recommended

Issue date

December 14, 2020

Implementation date

July 1, 2021

Scope

GB/T 39725-2020 is the English-translated version of 信息安全技术 健康医疗数据安全指南.

GB/T 39725-2020 sets out the security measures that controllers of health and medical data can take to protect that data.

Clause 1 states that it is meant to guide those controllers, and that the competent departments for health care and network security, third-party evaluation agencies and other organisations can also use it for reference when carrying out the safety supervision, management and evaluation of health and medical data.

The document moves from Scope, Normative references, Terms and definitions and Abbreviations to the security objective, then to a classification system covering the data category scope, data classification, related role classification, circulation usage scenarios and data open formats, then to the use disclosure principle, the key points of hierarchical, scenario and open security measures, a safety management guide with an overview, organisation, process and emergency response, a safety technical guide with general safety technology and de-identification, and finally data security in typical scenarios.

Those scenarios are doctor access to data, patient query, clinical research, secondary use, health sensor data, mobile applications, commercial insurance docking and medical devices.

Seven informative appendices follow, on the scope of personal health and medical data, health information related standards, examples of data use management methods, an example of data application approval, a data processing use agreement template, a health and medical data security checklist and an example of de-identification of health information data elements, together with a list of references.

Clause 2 cites GB/T 22080-2016, GB/T 22081-2016, GB/T 22239-2019, GB/T 25069, GB/T 31168, GB/T 35273, GB/T 35274-2017, GB/T 37964-2019 and ISO 80001, and the safety technical guide tells the controller to work to GB/T 22081-2016, GB/T 22239-2019, GB/T 31168 and GB/T 35274-2017 and to carry out de-identification in accordance with GB/T 37964-2019.

Clause 3 defines personal health data, health data and the health service professional, the last being a person authorised by the government or by industry organisations to perform specific health and medical duties.

The draft on the page is partial and breaks off inside the patient query scenario, so the later scenario clauses are not shown in full. It was issued on 14 December 2020 and has applied since 1 July 2021.

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Document preview — GB/T 39725-2020

National Standard of the People's Republic of China

ICS
35.040
Classification
L 80

Issued by: State Administration for Market Regulation; Standardization Administration of the PRC

Contents

  • Preface
  • Introduction
  • 1 Scope
  • 2 Normative references
  • 3 Terms and definitions
  • 4 Abbreviations
  • 5 Security objective
  • 6 Classification system
  • 6.1 Data category scope
  • 6.2 Data classification
  • 6.3 Related role classification
  • 6.4 Circulation usage scenario
  • 6.5 Data open format
  • 7 Use Disclosure Principle
  • 8 Key points of safety measures
  • 8.1 Key points of hierarchical safety measures
  • 8.2 Key points of scenario security measures
  • 8.3 Key points of open security measures
  • 9 Safety Management Guide
  • 9.1 Overview
  • 9.2 Organization
  • 9.3 Process
  • 9.4 Emergency response
  • 10 Safety Technical Guide
  • 10.1 General safety technology
  • 10.2 De-identification
  • 11 Data security in typical scenarios
  • 11.1 Doctor access to data security
  • 11.2 Patient query data security
  • 11.3 Clinical research data security
  • 11.4 Data security for secondary use
  • 11.5 Health sensor data security
  • 11.6 Mobile Application Data Security
  • 11.7 Commercial insurance docking security
  • 11.8 Medical device data security
  • Appendix A (informative appendix) Scope of personal health and medical data
  • Appendix B (Informative Appendix) Health Information Related Standards
  • Appendix C (informative appendix) Examples of data use management methods
  • Appendix D (informative appendix) Example of data application approval
  • Appendix E (Informative Appendix) Data Processing Use Agreement Template
  • Appendix F (Informative Appendix) Health and Medical Data Security Checklist
  • Appendix G (informative appendix) Example of de-identification of health information data elements
  • References

1 Scope

This standard specifies the security measures that health and medical data controllers can take when protecting health and medical data.

This standard is suitable for guiding health and medical data controllers to protect health and medical data, and it can also be used for health care and network security.

Relevant competent departments and third-party evaluation agencies and other organizations carry out the safety supervision, management and evaluation of health and medical data for reference.

2 Normative references

The following documents are indispensable for the application of this document. For dated reference documents, only the dated version applies to this document. For undated references, the latest version (including all amendments) applies to this document.

GB/T 22080-2016 Information Technology Security Technology Information Security Management System Requirements

GB/T 22081-2016 Information Technology Security Technical Information Security Control Practice Guide

GB/T 22239-2019 Information Security Technology Network Security Level Protection Basic Requirements

GB/T 25069 Information Security Technical Terms

GB/T 31168 Information Security Technology Cloud Computing Service Security Capability Requirements

GB/T 35273 Information Security Technology Personal Information Security Specification

GB/T 35274-2017 Information Security Technology Big Data Service Security Capability Requirements

GB/T 37964-2019 Information Security Technology Guidelines for De-identification of Personal Information

ISO 80001 integrates the application of network risk management for medical equipment (ApplicationofriskmanagementforIT-networksincorporatingmedicaldevices)

3 Terms and definitions

The following terms and definitions defined in GB/T 25069 apply to this document.

3.1 Personal health data

A related electronic device that can identify a specific natural person alone or in combination with other information or reflect the physical or mental health of a specific natural person data.

Note: Personal health medical data relates to the individual's past, present or future physical or mental health status, medical care services received and medical care paid for For service fees, see Appendix A.

3.2 Health data

Personal health and medical data and health and medical-related electronic data obtained after processing of personal health and medical data.

Example: After processing the group health and medical data, the overall group analysis results, trend forecasts, disease prevention statistics, etc. are obtained.

3.3 Health service professional

Persons who are authorized by the government or industry organizations to perform specific health and medical duties.

It has the right to revoke the authorization at any time.

7 Use Disclosure Principle

d) The subject (or its authorized representative) has the right to access its personal health and medical data or request the disclosure of its data, and the controller should disclose according to its requirements. Reveal corresponding personal health and medical data.

e) The subject has the right to review and obtain a copy of his personal health and medical data, and the controller should provide it, such as through file sharing or online Provided by inquiry.

f) When the subject discovers that the subject's personal health and medical data held by the controller is inaccurate or incomplete, the controller should provide it with Methods of requesting corrections or additional information.

g) The entity has the right to make historical backtracking inquiries on the use or disclosure of data by the controller or its processors, and the shortest backtracking period is six years.

h) The entity has the right to require the controller to restrict the use or disclosure of its personal health care in the process of diagnosis, treatment, payment, health services, etc. Data, and restrictions on the disclosure of information to relevant persons, the controller is not obliged to agree to the above restriction requests; but once agreed, unless otherwise In the case of legal requirements and medical emergencies, the controller should comply with the agreed restrictions.

i) The controller can use the treatment notes for treatment, and after the necessary de-identification processing, it can be used without personal authorization. Under circumstances, use or disclose treatment notes for internal training and academic seminars.

j) The controller should formulate and implement reasonable strategies and procedures to limit the use and disclosure to a minimum.

k) The controller should confirm that the processor's security capabilities meet the security requirements and sign a data processing agreement before allowing the processor to enter For data processing, the processor should process the data in accordance with the requirements of the controller. Without the permission of the controller, the processor cannot introduce a third party Assist in processing data.

l) Before the controller provides data to a third-party controller authorized by the government, it should obtain relevant documents stamped with the official seal of the government. Later, the responsibility for data security and the security of the transmission channel shall be borne by the third-party controller.

m) The controller confirms the legality, legitimacy and necessity of the data use, and confirms that the user has the corresponding data security capabilities, and After the user has signed a data use agreement and promised to protect the personal health and medical data in the restricted data set, the user can be restricted The data set is used for scientific research, medical care business, public health and other purposes; users can only use it within the scope of the agreement Data and assume the responsibility for data security. After the use of the data is completed, it should be returned, completely destroyed, or carried out in accordance with the requirements of the controller. He handles. Without the permission of the controller, the user cannot disclose the data to a third party.

n) If the controller collects and analyzes personal health and medical data and obtains health and medical related data that cannot identify the individual According to the data, the data is no longer personal information, but its use and disclosure should comply with other relevant national laws and regulations.

o) If the controller needs to provide corresponding data overseas due to academic research needs, after performing the necessary de-identification processing, The Data Security Committee discusses, approves, and agrees that non-secret-related and non-important data within 250 items can be provided, otherwise it should be submitted Approval by relevant departments.

p) Does not involve state secrets, important data, or other data that is prohibited or restricted from being provided abroad, with the authorization and consent of the subject, and the data According to the approval of the safety committee, the controller can provide personal health and medical data to overseas destinations, and the cumulative data volume should be controlled The rule is within 250, otherwise it should be submitted to relevant departments for approval.

q) Controllers should not store health and medical data on servers outside the country, and do not host or rent servers outside the country.

r) When the controller conducts external data cooperation development and utilization, it is advisable to adopt the open form of "data analysis platform" to disclose the use of data. Strict control.

8 Key points of safety measures

8.1 Key points of hierarchical safety measures

Data can be classified according to the needs of data protection, and different security protection measures can be implemented for different levels of data.

Rights management, identity authentication, and access control management. For example, the key points of data classification and security measures from the perspective of personal information security risk are as follows.

Table 3 shows. Please refer to 11.1 for details of data classification and safety measures in the doctor's reading scenario. Data classification and safety measures in clinical research scenarios See 11.3 for details.

9 Safety Management Guide

9.1 Overview

The controller can refer to Appendix C to establish data use management measures, refer to Appendix D to review and approve data applications, and refer to Appendix E and handling The manager (user) signs the data processing (use) agreement and conducts self-examination with reference to Appendix F.

9.2 Organization

It is advisable to establish a complete organizational security system, and the organizational structure includes at least the Health and Medical Data Security Committee and the Health and Medical Data Security Work office to ensure that health and medical data security management is done well, and the corresponding document records are formed, including but not limited to.

a) Establish a health and medical data security committee (referred to as the committee) to be fully responsible for the health and medical data security work, discuss and decide on health For major matters concerning health care data security, the committee should.

1) Including the senior management of the organization and the person in charge of each business;

2) Covering professionals related to information security, ethics, law, statistics, auditing, and confidentiality;

3) The highest person in charge of the organization serves as the chairman;

4) It can rely on the existing ethics committee, academic council, etc., without having to re-establish;

5) Coordinate the allocation of human, material, and financial resources necessary for health and medical data security, such as the principle of separation of permissions Then, equipped with security administrators, security auditors, system administrators, etc.;

6) Responsible for reviewing health and medical data security strategy, risk assessment plan, compliance assessment plan, risk treatment plan and emergency response Placement plan;

7) Responsible for reviewing data security related rules and regulations (e.g. data use approval process);

8) Responsible for reviewing de-identification strategies and procedures;

9) Regular work meetings are held, and it is recommended to hold at least once a month.

b) Establish a health and medical data security work office, and designate a designated person (such as a data security officer) to be responsible for daily health and medical data security jobs.

1) Responsible for implementing the decisions of the Health and Medical Data Security Committee and reporting to the committee;

2) Responsible for formulating, maintaining and updating health and medical data security strategies, risk assessment plans, compliance assessment plans, and risk disposal methods Case and emergency response plan;

3) Responsible for establishing, maintaining and updating data security related rules and regulations;

4) Responsible for formulating, maintaining and updating data use approval process, as well as de-identification strategy and process;

5) Sort out business processes and related health and medical information systems and data, and conduct security risk analysis and compliance analysis, and propose Recommendations on health and medical data security;

6) Form and manage the metadata structure to form a data and system supply chain structure that conforms to the business process;

7) Responsible for data security education and training of personnel to ensure that relevant personnel have corresponding data security capabilities;

8) At least annually conduct a comprehensive self-inspection of health and medical data security and make suggestions for rectification;

9) Audit the use of health and medical data, and adjust and improve security measures in a timely manner;

10) Monitor and alert the health and medical data security status, and adjust and improve security measures in time.

9.3 Process

9.3.1 Planning

The main tasks in the planning stage are as follows, and each task should be documented accordingly.

a) Define the scope of health and medical data security work, determine work goals, and establish work plans;

b) Establish a health and medical data security strategy and notify the whole organization;

c) Establish rules and regulations related to health and medical data security and notify the whole organization;

d) Establish a health and medical data security risk assessment plan and a compliance assessment plan;

e) Sort out health and medical data related businesses and related systems and data;

f) Identify health and medical data security risks and assess the impact;

g) Identify health and medical data security compliance risk points and assess the impact;

h) Establish a risk treatment plan for risks; if it involves data use disclosure, it should be handled in accordance with Chapter 7 "Use Disclosure Requirements";

If the network and system are secure, it should be handled in accordance with GB/T 22081-2016 and GB/T 22239-2019; basic security is involved Security and data services should be handled in accordance with GB/T 35274-2017; those involving cloud computing security should be handled in accordance with GB/T 31168 for disposal;

i) Review and pass the risk treatment plan;

j) Establish a data security emergency response plan.

9.3.2 Implementation

The main tasks in the implementation phase are as follows, and each task should be documented accordingly.

a) In the process of using and disclosing health and medical data, all links should strictly implement the established data security related regulations and security strategies And process;

b) Implement a risk treatment plan, including the implementation of selected safety measures;

c) Equipped with appropriate resources, including manpower, material resources, and funds, to support the development of safety work;

d) Carry out necessary information security education and training;

e) Implement effective management and control of information security work carried out and various resources invested in information security work;

f) Take effective response measures to information security incidents.

9.3.3 Inspection

The main tasks of the inspection phase are as follows, and each task should be documented accordingly.

a) Monitor the work process related to health and medical data security, such as the implementation process of security measures;

b) Regularly review the implementation effectiveness of the risk treatment plan, including evaluating the acceptability of the remaining risks after the implementation of the corresponding measures;

c) Regularly check whether the use and disclosure of health and medical data meets Chapter 7 "Use Disclosure Requirements";

d) Regularly check whether safety technical work and de-identification work have been carried out in accordance with Chapter 10;

e) The inspection process is incorporated into the internal management of the organization;

f) Perform self-inspection according to the situation, or ask a third-party agency to conduct an inspection.

9.3.4 Improvement

The main work in the improvement phase is as follows, and each work should be documented accordingly.

a) Improve security measures based on monitoring or inspection results, including taking preventive measures, or adjustments that may affect the security of health and medical data Full content of business activities;

b) Establish a rectification plan and implement it as planned.

9.4 Emergency treatment

The main work of emergency response is as follows, and each work should be documented accordingly.

a) Establish an emergency plan, including the conditions for starting the emergency plan, emergency handling procedures, system recovery procedures, incident reporting procedures, and afterwards Education and training. The network security emergency plan should be reviewed and revised regularly, and emergency drills should be organized at least once a year.

b) Special data security emergency support teams and expert teams should be designated to ensure that security incidents are handled in a timely and effective manner.

c) A disaster recovery plan should be formulated to ensure that the health and medical information system can recover from cyber security incidents in a timely manner, and establish security incidents Traceability mechanism.

d) After a data security incident occurs, it should be handled according to the emergency plan; after the incident is handled Departments report the incident in writing, and the content should at least include. incident description, cause and impact analysis, handling methods and other information.

e) A comprehensive assessment should be carried out based on the safety problems found in the detection and evaluation, monitoring and early warning and the disposal results, and the risk should be carried out again when necessary Identify and update the security policy.

10 Safety Technical Guide

10.1 General safety technology

The controller should follow GB/T 22081-2016, GB/T 22239-2019, GB/T 31168 and GB/T 35274-2017, etc. Good data security management.

a) Information systems and network facilities and cloud platforms that carry health and medical data should be provided with necessary security protection.

b) It should be aimed at various activities in the data life cycle, including data collection, data transmission, data storage, data processing, data exchange, Implement data security measures such as data destruction to reduce security risks and ensure data security.

c) It is advisable to adopt the necessary security for data platforms and applications around the characteristics of each stage of the system life cycle such as planning, development, deployment, and operation and maintenance.

Measures to establish a secure data management infrastructure, reduce the security risks of data platform and application operation, and ensure business continuity.

d) It is advisable to categorize and manage health and medical data, formulate and implement reasonable strategies and procedures, and limit the use and disclosure to the most Low limit.

e) Security measures such as identity authentication, access control, security audit, intrusion prevention, malicious code prevention, and media usage management should be implemented.

f) It is necessary to ensure that data quality meets business needs, and implement security measures such as backup and restoration and remaining information protection.

g) Encryption technology should be used to ensure the integrity, confidentiality and traceability of data in the process of collection, transmission and storage; use media to transmit If it is transported, the media should be controlled.

h) When storing personal biometric information, it is advisable to use technical measures to process it before storing, for example, only store personal biometric information Summary.

i) The use of cryptographic technology should meet the relevant requirements of national cryptographic management.

j) It should meet the relevant general requirements of important data management, critical information infrastructure security management and other policies.

10.2 De-identification

The controller should carry out de-identification work in accordance with GB/T 37964-2019, and the de-identified data should be used for controlled public sharing or The territory is publicly shared (an environment under the full control of the controller), and it is advisable to agree on the purpose, method, period and security of the data through the data use agreement Measures etc. The de-identification strategy, process and results should be approved by the Data Security Committee. Data is used in clinical research and pharmaceutical/medical research and development When, the relevant requirements are as follows.

a) It is advisable to remove the information that can uniquely identify the individual in the personal attribute data or the information that will have a significant impact on the individual after disclosure.

Such as. name; ID card/driver's license number; phone number, fax, email; medical insurance number, medical record file number, account; health Object identification information (information irrelevant to the purpose of application, such as fingerprints, voice, etc.); photos; hobbies, beliefs, etc.

b) The information in personal attribute data that can be indirectly linked to individuals should be processed by generalization, conversion, etc., for example.

1) Unit, address, zip code and other information, if unit information or combined with other information covers more than 20,000 people If the address information includes province (municipalities directly under the Central Government), city (county), street (township) or other information After the combination, the population covered by the combination is more than 20,000, which can be retained, otherwise the street (township) should be removed to ensure that the combination covers the people The group is more than 20,000; if the zip code information or the combination of other information covers more than 20,000, it can be retained, no It is advisable to set the low zip code to '0' to ensure that more than 20,000 people can be covered.

2) Generalize the specific age, for example, give an age range. For example. 38 years old can be converted into 30~40 years old, Ensure that there are more than 20,000 people meeting the same age requirements in the same area.

3) Birthday and all other date information, such as. admission time, discharge time, can only be specific to the year, or time drift deal with.

11 Data security in typical scenarios

11.2 Patient query data security

11.2.1 Overview

It is suitable for the scenario where patients query their own health and medical data online. The patient assumes the main role.

11.2.2 Key safety measures
11.2.2.1 Identification

Patients inquire their health and medical data through the online system. For the first registration, they need to associate a real-name mobile phone and pass the real-name mobile phone and mobile phone inspection.

Certificate code login. Considering the need for children to query information in place of elderly parents, the account can be bound to the child's mobile phone (upload a scanned copy of the ID card or household register)

It can be verified or authenticated by the system background), the guardian replaces the minor to query information and other situations, and imitate the processing.

After registration, individuals need to set up an account and password. […]

......
This preview omits tables, figures, formulas and parts of the technical clauses. The complete document — 62 pages — is available in the English PDF.

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