How Good is a Security Policy against Real Breaches? A HIPAA Case Study

Policy design is an important part of software development. As security breaches increase in variety, designing a security policy that addresses all potential breaches becomes a nontrivial task. A complete security policy would specify rules to prevent breaches. Systematically determining which, if any, policy clause has been violated by a reported breach is a means for identifying gaps in a policy. Our research goal is to help analysts measure the gaps between security policies and reported breaches by developing a systematic process based on semantic reasoning. We propose SEMAVER, a framework for determining coverage of breaches by policies via comparison of individual policy clauses and breach descriptions. We represent a security policy as a set of norms. Norms (commitments, authorizations, and prohibitions) describe expected behaviors of users, and formalize who is accountable to whom and for what. A breach corresponds to a norm violation. We develop a semantic similarity metric for pairwise comparison between the norm that represents a policy clause and the norm that has been violated by a reported breach. We use the US Health Insurance Portability and Accountability Act (HIPAA) as a case study. Our investigation of a subset of the breaches reported by the US Department of Health and Human Services (HHS) reveals the gaps between HIPAA and reported breaches, leading to a coverage of 65%. Additionally, our classification of the 1,577 HHS breaches shows that 44% of the breaches are accidental misuses and 56% are malicious misuses. We find that HIPAA's gaps regarding accidental misuses are significantly larger than its gaps regarding malicious misuses.