What Scan Playbook Actions are best for PHI in a HIPAA context?
Here are suggested Playbook actions for PHI, categorized by risk:
1. Critical Risk Actions (e.g., SSN + Clinical Context)
For findings that represent a high probability of a HIPAA breach, use Automatic Actions to remove the data from the insecure location immediately.
- Quarantine / Move: Automatically move the file to a secure, restricted-access "Quarantine" folder. This removes the risk while preserving the file for review.
- Shred (Use with Caution): If the file is in a location where it should never exist (e.g., a public web server or a temp folder), use the Shred action to delete it permanently.
- Redact: If using the Private AI integration, automatically redact the sensitive identifiers (like SSNs) while leaving the rest of the document intact.
2. High Risk Actions (e.g., MRN + Name or Bulk PHI)
For data that is sensitive but may be part of a legitimate business process, use Governance and Encryption actions.
- Classify (Persistent): Apply a "PHI - Restricted" label to the file metadata (M365) or NTFS ADS (Windows). This ensures the label "travels" with the file.
- MIP Labeling: Apply a Microsoft Information Protection (MIP) label that triggers automated encryption (e.g., "Highly Confidential - PHI").
- Restrict Sharing: For M365/OneDrive targets, use a playbook to remove "Anyone with the link" or "External" sharing permissions.
3. Medium Risk / Operational Actions (e.g., Name + DOB)
For findings that require human verification or owner awareness, use Notification and Workflow actions.
- Notify Owner: Send an automated email to the file owner with a link to the finding, asking them to confirm if the data is necessary and secure.
- Notify Privacy Team: Send a summary alert to your Compliance or Privacy alias for any finding that triggers a high-confidence PHI SDD.
- Execute Script: Trigger a custom PowerShell or Python script to log the finding into an external ticketing system (like Jira or ServiceNow) for tracking.
Summary Playbook Configuration Table
Trigger (SDD/Data Type) | Execution Mode | Primary Action | Secondary Action |
|---|---|---|---|
High-Confidence PHI SDD | Automatic | Quarantine | Notify Privacy Team |
Bulk PHI (>50 records) | Automatic | MIP: Encrypt | Notify Department Head |
MRN + Name | Automatic | Classify: PHI | Notify File Owner |
General Health Info | Manual Review | Classify: Internal | None (Wait for Review) |
Operational Best Practices
- Test in "Notify Only" Mode: When deploying a new PHI playbook, run it in "Notify Only" mode for 1-2 weeks to ensure your SDD logic isn't triggering on false positives before enabling "Quarantine" or "Shred."
- Check Permissions: Ensure your Search Agents have the necessary "Write" or "Modify" permissions on the target systems to execute these actions.
- Monitor Action Success: Use the Reduction Metrics in your dashboard to track "Action Attempted" vs. "Action Succeeded." If actions are failing, it is usually due to a permissions mismatch or a network path issue.
Pro Tip: In v13.6, ensure your shipper_queue is healthy. If the queue is backed up, your "Automatic" actions will still run on the agent, but the "Success" status won't be reflected in the console until the results are shipped.