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In an industry as highly regulated as healthcare, building a single secure and compliant application that tracks patient care and appointments at a clinic requires a great deal of planning from development and security teams. So, imagine what it would be like to build a solution that includes almost everything related to a patient’s healthcare, including insurance and billing. That’s what Highmark Health (Highmark)—a U.S. health and wellness organization that provides millions of customers with health insurance plans, a physician and hospital network, and a diverse portfolio of businesses–decided to do. 

Highmark is developing a solution called Living Health to re-imagine healthcare delivery, and it is using Google Cloud and the Google Cloud Professional Services Organization (PSO) to build and maintain the innovation platform supporting this forward thinking experience. Considering all the personal information that different parties like insurers, specialists, billers and coders, clinics, and hospitals share, Highmark must build security and compliance into every part of the solution. 

In this blog, we look at how Highmark Health and Google are using a technique called “secure-by-design” to address the security, privacy, and compliance aspects of bringing Living Health to life.

Secure-by-design: Preventive care for development

In healthcare, preventing an illness or condition is the ideal outcome. Preventive care often involves early intervention—a course of ideas and actions to ward off illness, permanent injury, and so on. Interestingly, when developing a groundbreaking delivery model like Living Health, it’s a good idea to take the same approach to security, privacy, and compliance. 

That’s why Highmark’s security and technology teams worked with their Google Cloud PSO team to implement secure-by-design for every step of design, development, and operations. Security is built into the entire development process rather than waiting until after implementation to reactively secure the platform or remediate security gaps. 

It’s analogous to choosing the right brakes for a car before it rolls off the assembly line instead of having an inspector shut down production because the car failed its safety tests. The key aspect of secure-by-design is an underlying application architecture created from foundational building blocks that sit on top of a secure cloud infrastructure. Secure-by-design works to ensure that these building blocks are secure and compliant before moving on to development.

The entire approach requires security, development, and cloud teams to work together with other stakeholders. Most importantly, it requires a cloud partner, cloud services, and a cloud infrastructure that can support it. 

Finding the right cloud and services for secure-by-design 

Highmark chose Google Cloud because of its leadership in analytics, infrastructure services, and platform as a service. In addition, Google Cloud has made strategic investments in healthcare interoperability and innovation, which was another key reason Highmark decided to work with Google. As a result, Highmark felt that Google Cloud and the Google Cloud PSO were best suited for delivering on the vision of Living Health—its security and its outcomes. 

“Google takes security more seriously than the other providers we considered, which is very important to an organization like us. Cloud applications and infrastructure for healthcare must be secure and compliant,” explains Highmark Vice President and Chief Information Security Officer, Omar Khawaja. 

Forming a foundation for security and compliance

How does security-by-design with services work? It starts with the creation and securing of the foundational platform, allowing teams to harden and enforce specified security controls. It’s a collaborative process that starts with input from cross-functional teams—not just technology teams—using terms they understand, so that everyone has a stake in the design. 

A strong data governance and protection program classifies and segments workloads based on risk and sensitivity. Teams build multiple layers of defense into the foundational layers to mitigate against key industry risks. Google managed services such as VPC Service Controls help prevent unauthorized access. Automated controls such as those in Data Loss Prevention help teams quickly classify data and identify and respond to potential sources of data risk. Automation capabilities help ensure that security policies are enforced.

After the foundational work is done, it’s time to assess and apply security controls to the different building blocks, which are Google Cloud services such as Google Kubernetes Engine, Google Compute Engine, and Google Cloud Storage. The goal is to make sure that these and similar building blocks, or any combination of them, do not introduce additional risks and to ensure any identified risks are remediated or mitigated. 

Enabling use cases, step by step

After the foundational security is established, the security-by-design program enables the Google Cloud services that developers then use to build use cases that form Living Health. The service enablement approach allows Highmark to address complexity by providing the controls most relevant for each individual service. 

For each service, the teams begin by determining the risks and the controls that can reduce them. The next step is enforcing preventive and detective controls across various tools. After validation, technical teams can be granted an authorization to operate, also called an ATO. An ATO authorizes the service for development in a use case.

For use cases with greater data sensitivity, the Highmark teams validate the recommended security controls with an external trust assessor, who uses the HITRUST Common Security Framework, which maps to certifications and compliance such as HIPAA, NIST, GDPR, and more. A certification process follows that can take anywhere from a few weeks to a few months. In addition to certification, there is ongoing monitoring of the environment for events, behavior, control effectiveness, and control lapses or any deviation from the controls.

The approach simplifies compliance for developers by abstracting compliance requirements away. The process provides developers a set of security requirements written in the language of the cloud, rather than in the language of compliance, providing more prescriptive guidance as they build solutions. Through the secure-by-design program, the Highmark technology and security teams, Google, the business, and the third-party trust assessor all contribute to a secure foundation for any architectural design with enabled Google Cloud services as building blocks. 

Beating the learning curve 

Thanks to the Living Health project, the Highmark technology and security teams are trying new methods. They are exploring new tools for building secure applications in the cloud. They are paying close attention to processes and the use case steps and, when necessary, aligning different teams to execute. Because everyone is working together collaboratively toward a shared goal, teams are delivering more things on time and with predictability, which has reduced volatility and surprises. 

The secrets to success: Bringing everyone to the table early and with humility

Together, Highmark and Google Cloud PSO have created over 24 secure-by-design building blocks by bringing everyone to the table early and relying on thoughtful, honest communication. Input for the architecture design produced for Highmark came from privacy teams, legal teams, security teams, and the teams that are building the applications. And that degree of collaboration ultimately leads to a much better product because everyone has a shared sense of responsibility and ownership of what was built. 

Delivering a highly complex solution like Living Health takes significant, more purposeful communication and execution. It is also important to be honest and humble. The security, technology, and Google teams have learned to admit when something isn’t working and to ask for help or ideas for a solution. The teams are also able to accept that they don’t have all the answers, and that they need to figure out solutions by experimenting. Khawaja puts it simply, “That level of humility has been really important and enabled us to have the successes that we’ve had. And hopefully that’ll be something that we continue to retain in our DNA.”

Whether driven by government policy, industry regulation, or geo-political considerations, the evolution of cloud computing has led organizations to want even more control over their data and more transparency from their cloud services. At Google Cloud, one of the best tools for achieving that level of control and transparency is a bit of technological magic we call Cloud External Key Manager (EKM).

Cloud EKM can help you protect your cloud data at rest with encryption keys which are stored and managed in a third-party key management system that’s outside Google Cloud’s infrastructure, and ultimately outside Google’s control. This can help you achieve full separation between your encryption keys and your data stored in the cloud. Cloud EKM works with symmetric and asymmetric encryption keys, and offers organization policies that allow for fine-grained control over what types of keys are used. Via Key Access Justification (KAJ) it also offers a way for clients to control each key use.

At their core, many cloud security and cloud computing discussions are about the kinds of trust that Cloud EKM specifically and encryption more broadly can help create. While the concept of digital trust is much bigger than cybersecurity and its tripartite components of security, privacy, and compliance, one of the most crucial themes of cloud computing is the cloud trust paradox. In order to trust the cloud more, you must be able to trust it less, and external control of keys and their use can help reduce concerns over unauthorized access to sensitive data.

How it works

From our Cloud EKM documentation, you can use keys that you manage within a supported external key management partner to protect data within Google Cloud. You can protect data at rest in services that support CMEK, or by calling the Cloud Key Management Service API directly.

Cloud EKM provides several benefits:

• Key provenance: You control the location and distribution of your externally-managed keys. Externally-managed keys are never cached or stored within Google Cloud. Google cannot see them. Instead, Cloud EKM communicates directly with the external key management device for each request.
• Access control: You manage access to your externally-managed keys. Before you can use an externally-managed key to encrypt or decrypt data in Google Cloud, you must grant the Google Cloud project access to use the key. You can revoke this access at any time.
• Centralized key management: You can manage your keys and access policies from a single location and user interface, whether the data they protect resides in the cloud or on your premises. The system that managed the keys is entirely outside Google control.

In all cases, the key resides on the external system, and is never sent to Google.

Here’s how it works:

1. Create or use an existing key in a supported external key management partner system. This key has a unique URI.
2. Grant your Google Cloud project access to use the key, in the external key management partner system.
3. Create a Cloud EKM key in your Google Cloud project, using the URI for the externally-managed key.

The Cloud EKM key and the external key management partner key work together to protect your data. The external key is never exposed to Google and cannot be accessed by Google employees. Furthermore, Cloud EKM can be combined with Key Access Justifications (KAJ) to establish cryptographic control over data access.

KAJ with Cloud EKM can give customers the ability to deny Google Cloud administrators access to their data at rest for any reason, even in situations typically exempted from customer control, such as outages or responses to third-party data requests. KAJ does this by providing customers a clear reason why data is being decrypted, which they can use to programmatically decide whether to permit decryption and thus allow access to their data.

Previously, we’ve discussed three patterns where keeping the keys off the cloud may in fact be truly necessary or outweighs the benefits of cloud-based key management. Here’s a brief summary of those three scenarios where Cloud EKM can help solve these Hold Your Own Key dilemmas.

Scenario 1: The last data to go to the cloud

As organizations complete their digital transformations by migrating data processing workloads to the cloud, there is often a pool of data that can not be moved to the cloud. Perhaps it’s the most sensitive data, the most regulated data, or the data with the toughest internal security control requirements.

Finance, healthcare, manufacturing and other heavily-regulated organizations face myriad risk, compliance, and policy reasons that may make it challenging to send some of their data to a public cloud provider. However, the organization may be willing to migrate this data set to the cloud as long as it is encrypted and they have sole possession of the encryption keys.

Scenario 2: Regional regulations and concerns

Regional requirements are playing a larger role in how organizations migrate to and operate workloads in the public cloud.

Some organizations are already facing situations where they are based in one country and want to use a cloud provider based in a different country, but they aren’t comfortable with or legally allowed to give the provider access to encryption keys for their stored data. Here the situations are more varied, and can include an organization’s desire to stay ahead of evolving regulatory demands or industry-specific mandates.

Ultimately, this scenario allows organizations to utilize Google Cloud while keeping their encryption keys in the location of their choice, and under their physical and administrative control.

Scenario 3: Centralized encryption key control

The focus here is on operational efficiency. Keeping all the keys within one system to cover multiple cloud and on-premise environments can help reduce overhead and attack surface, thus helping to improve security. As Gartner researchers concluded in their report, “Develop an Enterprisewide Encryption Key Management Strategy or Lose the Data1,” organizations are motivated to reduce the number of key management tools.

“By minimizing the number of third-party encryption solutions being deployed within an environment, organizations can focus on establishing a cryptographic center of excellence,” Gartner researchers said

Given that few organizations are 100% cloud-based today for workloads that require encryption, keeping keys on-prem can streamline key management. Centralizing key management can give the cloud user a central location to enforce policies around access to keys and access to data-at-rest, while a single set of keys can help reduce management complexity. A properly implemented system with adequate security and redundancy outweighs the need to have multiple systems.

Do I need Cloud EKM?

Whether protecting highly sensitive data, retaining key control to address geopolitical and regional concerns, or supporting hybrid and multi-cloud architectures, Cloud EKM is best suited for those Google Cloud customers who must keep their encryption keys off of the cloud and always under their full control.

To learn more about Cloud EKM, please review these resources:

• Our research explaining why Google Cloud users can benefit from Cloud EKM
• The most recent updates to Cloud EKM
• Take a deeper dive into the cloud trust paradox

1. Gartner, Develop an Enterprisewide Encryption Key Management Strategy or Lose the Data, David Mahdi, Brian Lowans, March 2022.