1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Verb Categorization by Record-Entry Events EHR Interoperability-Privacy and Security Work Groups Verb Harmonization Initiative Work-in-Progress Notes Steve Hufnagel, facilitator, 2 September 2014 DRAFT-P INTRODUCTION1: Privacy and Security can provide authorization and access controls to EHR system operations and information exchanges, which result in record-entry lifecycle state transitions; where, CRUDEA (Create, Read, Update, Delete, Execute, Append) are underlying computer operations Record entries go through a sequence of lifecycle events (aka state transitions) EHRS FM operation verbs are “triggers” to the record-entry state transitions Security audit log and/or provenance metadata may be captured, at the record-entry state transitions, as Fast Healthcare Interoperability Resources (FHIR). The goal of this initiative is to align EHR, Security and Privacy terms. The objectives / approach of this initiative are to iteratively 1. categorize the verbs by the Record-Entry lifecycle events they trigger 2. align events and their trigger verbs in the context of each Record-Entry lifecycle event 3. align lifecycle events, Privacy and Security controls, and EHR operational verbs. The products of this initiative are: 1. Domain Analysis Model (DAM) (e.g., State Transition Model of record-entry events) 2. Vocabulary, taxonomy (abstract hierarchy) and glossary of “terms”; where, term implies classes or objects containing record-entry nouns and operation verbs. REFERENCE: See companion Excel workbook “EHRS-FM Verb triggers mapped to Record-Entry Lifecycle Events Harmonization-Matrix and Definitions.xlsx”, which also contains the glossary of terms. REQUESTED ACTION: Please pose questions and provide suggestions for improvement. ASSUMPTIONS: Lifecycle Event State Transition Diagram (below) 1. Foundational Events need full provenance metadata resource; while, derived events may only need privacy & security metadata resource; where, Events/States are adjectives for Record-Entries (e.g., originated/ retained and encrypted record-entry) One-or-more verbs can trigger one-or-more events/states o (e.g., Export record-entry results-in an exported and disclosed record-entry) 2. Within an EHRS-FM profile, this Notional Record-Entry-Lifecycle State-Transition-Diagram should be adapted to define "fit-for-purpose" state-transitions and state-transition metadata according-to scope-of practice, organizational-policy and jurisdictional-law. e.g. business Rules may change the “Final State” from “Destroyed” to “Archived” and/or remove “Destroyed”. SUGGESTIONS / ISSUES: 1. 7/29/14 MvdZ – CRUDEA needs Query and Search [Michael Van Der Zel] 2. 7/29/14 TW – Categorizations/ hierarchies based-on policy (e.g., read access of sensitive data). a. 7/30/14 SH – What provenance is associated with ABAC access to sensitive data 3. 7/29/14 RDG - “Disambiguate” verb may be merited. [Reed Gelzer] 4. 7/29/14 RDG - The EHR FM R2 glossary definition for Attest/Attested may or may not line up entirely with its use here. 1 This Introduction is based on the 2014-07-15 EHR Interoperability Workgroup and Privacy and Security Workgroup PSS discussions. 47 48 49 50 51 52 5. 7/29/14 RDG - The EHR FM R2 Glossary does not have Verify as a noun or verb. 6. 7/29/14 RDG - Consider the concept that there are undoubtedly transition events that are aggregations of simultaneous transition types. For example, when executing an amendment on a Record Entry, a common scenario will include retaining the original as an immutable entry AND executing the amendment transition to an Amended record AND retaining the amended record entry as an immutable entry? Presumably “aggregated transition events” would be designed in and “hard coded” or configurable. stm Notional State-Transition-Diagram (STD); where, EHRS-FM operarion verbs trigger Record-Entry Lifecycle-Events 2 Linked = 1 Boundary states are derived. Linked = 0 Encrypted = 1 unlink De-Identified = 0 Encrypted = 0 decrypt decrypt encrypt link Translated = 1 translate transmit Transmitted = 1 Foundation Record-Entry State-Machine results in an immutable record; where, state-transitions and associated metadata are according-to scope-of-practice, organizational-policy and jurisdictional-law re-identify pseudomize De-Identified = 1 Originated/ Retained = 1 de-identify originate receive business rule to receive or originate without retaining Initially, all states = 0 Legal Hold = 0 business rule Attested = 1 amend amend attest Amended = 1 Inmutable Record verify amend Received/ Retained =1 remove hold business rule verify Immutable Record view extract Outputed/ Reported =1 Viewed/ Accessed = 1 Extracted = 1 Verified = 1 verify place hold Legal Hold = 1 output attest decide Decided = 1 attest destroy depricate archive re-activate Deprecated/ Retracted = 1 Destroyed = 1 Deprecated/ Retracted = 0 Archived = 1 disclose restore Archived = 0 Disclosed = 1 destroy Final State RBAC & ABAC Record-Entry State-Transition Trigger Event A hierarchy from high-level RBAC (Role-Based Access-Control) managed CRUDEA (Create, Read, Update, Delete, Execute, Append) categorized RELC events, to ABAC (Attribute-Based Access-Control) managed low-level operational-verb event-triggers defines where provenance (e.g., who, what, when, where, why, how) metadata (e.g., FHIR) is associated with "foundational" RBAC managed state-transitions (leading to immutable records), and also associated with ABAC managed sensitive-data accesses; where, shared-records should include RBAC provenance metadata. MetaData 53 54 Figure 1 Notional State Transition Machine for Record-Entry Lifecycle Events 55 56 57 58 59 60 61 62 63 64 This notional RELC (Record-Entry Life-Cycle) State-Transition-Machine defines "fit-for-purpose" state-transitions with associated access-controls and metadata according-to scope-of practice, organizational-policy and jurisdictional-law; where, security metadata is associated with all state-transitions. State Transition from Archived to Destroyed was added. Direct transition from originate receive to destroy was added for non-retained information Immutable record transition from Originated / Retained or Received / Retained was added RBAC & ABAC added as managing record-entry state-transitions Legend Record-Entry Lifecycle Event EHRS-FM Verb Privacy & Security verb 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 Manage an EHR 1. CRUDEA (Create, Read, Update, Delete, Execute, Append) (1) ISSUE: What about Query and Search [Michael Van Der Zel] (2) Control Access (Privacy & Security) applies to all operational verbs (a) Authenticate (b) Authorize (c) NOTE: RBAC is at the CRUDEA level, ABAC is at the operational verb level [Steve Hufnagel] (3) Metadata, with each type of CRUDEA (Create, Read, Update, Delete, Execute, Append) (a) Provenance (b) Privacy & Security Track (i) Log (Logging typically means the recording of implementation level events that happen as the program is running (methods get called, objects are created, etc.). As such it focuses on things that interest programmers) (ii) Audit (Auditing is about recording domain-level events: a transaction is created, a user is performing an action, etc. In certain types of application (Banking) there is a legal obligation to record such events.) (4) Privacy & Security Modify_Status These are at the CRUDEA level [Steve Hufnagel] (a) Abort (b) Activate (c) Cancel (d) Complete (e) Hold (f) Jump (g) Nullify (h) Release (i) Resume (j) Suspend 2. Maintain (a) Foundational Lifecycle Events/States and associated Trigger Verbs (i) CRUDEA, FHIR: Provenance & Security Event, RBAC access controls 1. Originate/ Retain Event-State may be triggered by the following verbs. a. Originate i. Capture ii. Enter b. Retain i. Store ii. Save 2. Receive/ Retain Event State-transition may be triggered by the following verbs: a. Exchange (needs definition!) (i) Receive 1. Import Import (ii) Retain 1. Store 2. Save 3. Auto Populate 4. Copy 5. Duplicate 111 112 113 114 115 116 117 118 119 120 121 122 6. Reproduce (ii) CRUDEA, FHIR: Provenance & Security Event, [if Attest is done separately from Originate], 1. Amend Event State-transition may be triggered by the following verbs: a. Amend [deprecated to edit in glossary action required!] b. Update [top level verb] RECOMMENDATION: Change Amend Event to Update Event i. Edit, [Definitions refer to amend, action required!] ii. Redact iii. Replace [Out of place?] iv. Annotate Annotate v. Append vi. Integrate vii. Tag [aka flag, does not require re-attest, out of place? Where does this belong?, EHRS Definition 123 124 125 126 127 is flag for follow-on action] ACTION: Security definition of Tag 2. Attest Event State-transition may be triggered by the following verbs: a. Sign (includes a digital signature) =? Attest (does attest include a signature?) 3. Verify Event State-transition may be triggered by the following verbs: a. Verify Verify 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 (iii) CRUDEA, FHIR: Provenance & Security Event 1. Destroy Event State-transition may be triggered by the following verbs: a. Purge Purge (specific type of delete where recovery is NOT possible)) b. Delete (recovery is potentially possible) (b) Derived Lifecycle Events/States and associated Trigger Verbs (i) CRUDEA, FHIR: Security Events 1. View/ Access Event State-transition may be triggered by the following verbs: a. Access (privacy permission … ability to read) =? Read (data operation) b. Collect c. Use d. Transmit , Exchange e. Harmonize f. Determine g. Analyze h. Decide i. Privacy permissions constrain or require logging of the data operations j. FHIR: Security Event 2. Disclose Event State-transition may be triggered by the following verbs: (Deprecated verb) a. Disclose (privacy operation?) b. Export (deprecated) Export c. Exchange (send and receive recommend deprecation of Exchange) d. Render i. Print ii. Present e. Forward f. Transfer g. FHIR: Security Event 3. Output/ Report Event State-transition may be triggered by the following verbs: a. Transmit 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 181 182 183 184 185 186 187 188 189 190 191 192 193 194 195 196 197 198 199 200 201 202 b. Export Export c. Exchange d. Render i. Print ii. Present e. Forward f. Transfer g. Disclose (based on Privacy & Security policy) h. FHIR: Security Event i. NOTE: This may result in a Receive/ Retain event for the recipient 4. Transmit Event State-transition may be triggered by the following verbs: a. Transmit b. Export Export c. Exchange d. Render i. Print ii. Present e. Forward f. Transfer g. Disclose (based on Privacy & Security policy) h. FHIR: Security Event i. NOTE: This may result in a Receive/ Retain event for the recipient j. ISSUE: What is the difference between Output/Report and Transmit? 5. Extract Event State-transition may be triggered by the following verbs: a. Extract b. Excerpt c. Derive d. FHIR: Security Event e. NOTE: This may result in a Create/ Retain event for a new record-entry (ii) CRUDEA, FHIR: Provenance & Security Event 1. Link Event State-transition may be triggered by the following verbs: a. Link b. Tag c. Track d. Log e. Audit f. Sustain (Ops.) [Out of place?] g. FHIR: Security Event 2. Unlink Event State-transition may be triggered by the following verbs: a. unlink b. FHIR: Security Event 3. Translate Event State-transition may be triggered by the following verbs: a. Translate b. Convert c. Encrypt Encrypt d. Decrypt Decrypt 203 204 205 206 207 208 209 210 211 212 213 214 215 216 217 218 219 220 221 222 223 224 225 226 227 228 229 230 231 232 233 234 235 236 237 238 239 240 241 242 243 244 245 246 247 248 4. 5. 6. 7. 8. 9. e. (Modify) Data Visibility [Does this belong here?] f. De-identify De-identify i. Pseudonymize ii. Anonymize iii. Mask Mask iv. Redact v. Hide g. FHIR: Security Event h. NOTE: This may result in a Create/ Retain event for a new record-entry Pseudomynize Event State-transition may be triggered by the following verbs: a. Pseudonymize b. De-identify De-identify c. FHIR: Security Event d. NOTE: This may result in a Create/ Retain event for a new record-entry De-Identify Event State-transition may be triggered by the following verbs: a. (Modify) Data Visibility [Does this belong here?] b. De-identify De-identify i. Pseudonymize ii. Anonymize iii. Mask Mask iv. Redact v. Hide c. FHIR: Security Event d. NOTE: anonymize and randomize missing? e. NOTE: This may result in a Create/ Retain event for a new record-entry Re-Identify Event State-transition may be triggered by the following verbs: a. (Modify) Data Visibility [Does this belong here?] b. Re-identify, Re-identify c. Identify d. Unmask e. Unhide f. FHIR: Security Event g. NOTE: This may result in a Create/ Retain event for a new record-entry Place Legal Hold Event State-transition may be triggered by the following verbs: a. Annotate / [Log] b. Tag c. FHIR: Security Event d. NOTE: This may result in a Create/ Retain event for a new record-entry Remove Legal Hold Event State-transition may be triggered by the following verbs: a. Annotate / [Log] b. Tag c. FHIR: Security Event d. NOTE: This may result in a Destroy event for a copied record-entry, put on legal hold. Encrypt Event State-transition may be triggered by the following verbs: a. Encrypt Encrypt b. FHIR: Security Event 249 250 251 252 253 254 255 256 257 258 259 260 261 262 263 264 265 266 267 268 269 270 271 272 273 274 275 276 277 278 10. 11. 12. 13. 14. c. NOTE: This may result in a Create/ Retain event for a new record-entry Decrypt Event State-transition may be triggered by the following verbs: a. Decrypt Decrypt b. FHIR: Security Event c. NOTE: This may result in a Create/ Retain event for a new record-entry Archive Event State-transition may be triggered by the following verbs: a. Archive Archive b. Backup Backup c. FHIR: Security Event d. NOTE: This may result in a Create/ Retain event for a new record-entry Restore Event State-transition may be triggered by the following verbs: a. Restore Restore b. Recover c. FHIR: Security Event d. NOTE: This may result in a Create/ Retain event for a new record-entry Deprecate/ Retract Event State-transition may be triggered by the following verbs: a. Remove b. Obsolete c. Tag [Out of place?] d. FHIR: Security Event e. NOTE: This may also result in an archive event Re-Activate Event State-transition may be triggered by the following verbs: a. Re-activate b. Annotate / [Log] c. Tag [Out of place?] d. Restore Restore e. Recover f. FHIR: Security Event g. NOTE: This may result in a Create/ Retain event for a new record-entry