Quote Of The Year

Timeless Quotes - Sadly The Late Paul Shetler - "Its not Your Health Record it's a Government Record Of Your Health Information"

or

H. L. Mencken - "For every complex problem there is an answer that is clear, simple, and wrong."

Wednesday, August 31, 2022

We Still Have A Way To Go To Reach Safe And Secure Clinical Data Sharing. Let’s Stop Trying To Force The MyHR Into The Role Just Because It Is There!

This appeared last week:

IXUP, homomorphic encryption and the future of data sharing

Justin Hendry
Editor

As the sharing of personal identifiable information between government agencies and businesses becomes increasingly commonplace, there is growing risk that data is leaked publicly.

The arrival of the Consumer Data Right in 2019 and the passage of legislation that opens a “new path” for public sector data-sharing, more recently, has only accelerated this process in the name of convenience and research.

That’s where secure data software company IXUP, which hoovered up the assets of the collapsed data-sharing startup Data Republic for $3 million last year, comes in.

The ASX-listed Australian scaleup (pronounced ‘eyes up’) has collaborated with Microsoft to produce homomorphic encryption technology aimed at maintaining data confidentiality.

In practice, the technology allows organisations to share encrypted data and generate insights without having to decrypt the original dataset, enhancing the privacy of those whose details are contained in the dataset.

Internationally recognised guardrails like the Five Safes framework are also embedded in the platform to help data scientists manage the sensitive data.

At the launch of the company’s Sydney office on Friday in the repurposed former torpedo factory and submarine base known as Sub Base Platypus chief operating officer Elizabeth Whitelock said IXUP aimed to make sure “personal information is never breached”.

“Our innovative software was founded here in Sydney and our core team of developers are still here,” she said. “We are Australian. We are currently small, but we have grand plans to make a difference globally.”

Non-executive chairman Julian Babarczy said the company’s privacy enhancing technology (PET) is a “powerful new enabler for consumer data rights, business integrity, compliance and data-drive social impact”

“Privacy enhancing technology (PET) has multiple benefits. It protects the data of individuals, it assists companies to comply with privacy legislation and also delivers on the social contract that companies, government and citizens have to one another – and that’s to keep our data private and secure,” he said.

New South Wales Minister for Customer Service and Digital Government Victor Dominello, who attended the launch, said IXUP’s work was critical, and increasingly important for government.

“What you’re doing with PETs and what you’re doing with cyber makes a profound difference,” Dominello said.

“For example, we’re about to roll out NSW ID, a fully biometric to level three [digital identity]. That’s where we’re going to be, but that’s just the beginning of the journey,” he said.

“We need fully homomorphic encryption to put into the health app, so that when we get data – through an API feed – from the My Health Record, we get data portability.”

More here:

https://www.innovationaus.com/ixup-homomorphic-encryption-and-the-future-of-data-sharing/

We also have this from the next day:

Living standards at risk without big data and artificial intelligence

By Shane Wright

August 23, 2022 — 10.30pm

Australian living standards could slip behind those of other countries if the government and businesses fail to use and analyse data or take advantage of new technologies such as artificial intelligence, the Productivity Commission has warned.

As part of its broader examination of ways to lift the nation’s economic speed limit, the commission on Wednesday will release new research that suggests the internet of things, robotic automation and big data analysis could revolutionise the country and boost the living standards of everyday Australians.

The agency, renowned for its advocacy of classic economic solutions, also says governments may have to invest more heavily in rural and regional areas to ensure they are not left in technological wastelands.

Productivity growth in Australia and globally has slowed since before the global financial crisis, contributing to downward pressure on real wages growth. The commission has already estimated Australians are working longer than comparable countries to maintain living standards because of the slowdown in productivity.

As part of a broad examination of issues across the economy, the commission has released a discussion paper about data and technology, which it believes could offer a step-up in productivity for Australia.

While most Australians have good access to broadband services, the speed of those services are relatively slow. A speed test at the end of January this year found the median fixed broadband download speed was ranked 61st in the world. The median mobile internet download speed was 18th.

Commissioner Stephen King said it was clear local businesses and individuals did well on “basic” technology like internet access, but were falling behind when it came to more advanced areas such as analytics and AI that offered substantial productivity gains.

”Digital technology and data have already transformed our economy and society, but we have not yet tapped into their full potential.

“Technologies such as artificial intelligence, robotic automation and big data analytics could revolutionise how businesses operate and help lift Australia’s productivity growth by reducing costs, improving the quality of goods and services, and increasing product choice for consumers,” he said.

The commission said while Australian businesses were using some types of technology and data, broader adoption could be held back by inadequate internet connection, a lack of skills, low awareness or uncertainty about benefits, security concerns and the cost of new technology.

Some of those issues, such as the cost of putting in place new technology, would fall over time, but there were ongoing problems including the nation’s digital infrastructure, especially in rural and regional areas. It noted federal government investment in regional areas often “lacks transparency and accountability”.

The commission found much of the data generated by government-funded services was not currently shared, arguing there could be large benefits if it was more easily accessible.

It said governments could require certain health data to be shared as a condition of official funding, noting that better and more accurate health information could contribute to better decision-making.

The My Health Record system, started by the Gillard government and expanded by the Morrison government, could be the starting point for increased data sharing.

More here:

https://www.smh.com.au/politics/federal/living-standards-at-risk-without-big-data-and-artificial-intelligence-20220823-p5bbyt.html

There are a few take-outs from these two articles which are pretty non-controversial.

The first is clearly safe and secure data sharing is a worthwhile thing to be doing and that improved technologies that enhance these attributes are a good thing.

The second is that enablement of data sharing is a key to maximising the value we can get from the data, be it commercial or clinical data.

The third is the belief that effective sharing of clinical data can enhance the quality of care which seems to be pretty non-controversial these days.

But to me this is where both authors go way off the rails suggesting that the My Health Record might be a good stating point.

This really reminds me of the famous commentary suggesting if you want to get there (quality data sharing) I would not start from here (the MyHR)!

Why do people keep hoping that we will stumble on a use for this pile of junk when is is pretty clear thee is actually no purpose for which is fit! Much better to design our data sharing approaches on new and proven technologies in ways we are pretty sure will actually add value and work!

Let’s just write the MYHR investment off and start again with a clean sheet and some properly conceived solutions!

David.

Tuesday, August 30, 2022

Commentators and Journalists Weigh In On Digital Health And Related Privacy, Safety, Social Media And Security Matters. Lots Of Interesting Perspectives - August 30, 2022.

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This weekly blog is to explore the news around the larger issues around Digital Health, data security, data privacy, AI / ML. technology, social media and related matters.

I will also try to highlight ADHA Propaganda when I come upon it.

Just so we keep count, the latest Notes from the ADHA Board were dated 6 December, 2018 and we have seen none since! It’s pretty sad!

Note: Appearance here is not to suggest I see any credibility or value in what follows. I will leave it to the reader to decide what is worthwhile and what is not! The point is to let people know what is being said / published that I have come upon.

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https://gphn.org.au/burst/webinar-digital-health-standards-selection-process/

Webinar on ‘Digital health standards selection process’ 

July 24, 2020

Latest News

The Australian Institute of Digital Health is working with the Australian Digital Health Agency to develop a process for digital health standards selection for national use and adoption.

This session on Tuesday 28 July from 1-2pm is titled ‘Digital health standards selection process’ and will be followed up by targeted industry and key stakeholder consultation sessions through August coordinated by the AIDH.

Leading healthcare executive, Dr Tim Smyth, will facilitate the discussion with senior representatives from the standards community, the AIDH and the Agency.

Specifically, webinar participants will talk about ways to develop a process of digital health standards selection for national use and adoption to form part of a broader strategic approach to standards and standards lifecycle management.

To find out more or to register visit the Australasian Institute of Digital Health (AIDH) event webpage

(There may be a recording of this session available from this session a month ago)

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https://www.innovationaus.com/wa-future-health-innovation-fund-gets-a-new-focus/

WA Future Health Innovation fund gets a new focus

Brandon How
Reporter

25 August 2022

Four new areas of focus have been unveiled for the Western Australian government’s Future Health Research and Innovation fund.

Building on the four strategic themes outlined in the WA Future Health Research and Innovation (FHRI) Fund Strategy 2020-22, the next three years will include a particular focus on:

  • Aboriginal, rural, and remote health
  • Burden of diseases
  • Living with Covid-19 and Long-Covid
  • Mental health

The fund has awarded $63.6 million worth of grants to 364 recipients in its first two years. Although worth around $1.6 billion, only forecast investment income is made available through FHRI programs. One per cent of the state’s forecast annual royalties are added to the FHRI fund.

It is expected to have $36.4 million available for distribution in financial year 2022-23, according to the most recent state budget. This is expected to decline to less than $30 million in each of the following three years.

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https://digitalhealth.org.au/blog/call-for-expressions-of-interest-to-be-part-of-the-aidh-expert-advisory-groups/

Call for Expressions of Interest to be part of the AIDH Expert Advisory Groups

Aug 23, 2022 | Advocacy, Community of Practice, Expert Advisory Group, Shifting the Dial

Director of Leadership & Policy

As the Institute embarks on its new strategy to shift the dial on our nation’s transition to a digital health future, we’re asking for the support and involvement of our Fellows and members.

The first step in delivering Shifting the Dial is the establishment of our Expert Advisory Groups.

Expert Advisory Groups – or ‘EAGs’, will be the driving force behind the further development, continual refinement, and the delivery of the Shifting the Dial strategy.

The strategy has intentionally been kept high-level to allow AIDH Fellows and members – the pioneers and leaders within the digital health sector – shape its development and have genuine input into how we influence the future direction of Australia’s healthcare system.

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https://www.menzies.edu.au/page/Research/Projects/Kidney/My_Health_Record_upload_from_Territory_Kidney_Care/

My Health Record upload from Territory Kidney Care

Objective:

The primary objective of this project is the technical implementation and change communication of the capability to upload synopsis letters from the TKC System to the My Health Record.

Summary:

Territory Kidney Care (TKC) is an innovative clinical information system used to assist with the early identification and best-practice management of kidney disease. It utilises a service-orientated architecture which automatically and securely transfers the clinical information of patients from existing health platforms, based on agreed criteria, to provide a complete patient picture. The technology applies algorithms to the collected patient data, which then stratifies patients according to risk and Chronic Kidney Disease (CKD) stage, enters patients into surveillance loops and initiates triggers to alert clinical teams of actions required.

In December 2021, the Northern Territory Department of Health (NT Health) and Australian Digital Health Agency (ADHA) agreed to implement the capability to upload synopsis reports from the TKC system to the My Health Record (MHR).  The agreement between NT Health and ADHA, and subsequently between NT Health and Menzies School of Health Research (Menzies), contains a schedule of deliverables to be completed by September 2022. 

Chief Investigator:

Project Contact:
Project Dates: 
  • March - September 2022

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https://medicalrepublic.com.au/dignity-over-data-medical-ai-fails-to-impress/75721

26 August 2022

Dignity over data: medical AI fails to impress

By Wendy John

Computer says yes, but patient says no to automated decision making.


AI in healthcare is only going to get bigger, and new Macquarie University research reveals how to do it better.

In this podcast, we hear from Associate Professor Paul Formosa from Macquarie University. He’s been researching how patients respond to AI making their medical decisions compared to how they respond if a human is involved.

Professor Formosa says that patients see humans as appropriate decision makers and that AI is perceived as dehumanising; even when the decision outcome is identical.

“There’s this dual aspect to people’s relationship with data. They want decisions based on data and they don’t like it when data is missing. However, they also don’t like themselves to be reduced merely to a number,” Professor Formosa says.

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https://itbrief.com.au/story/why-cloud-adoption-is-only-the-first-step

Why cloud adoption is only the first step

24 August, 2022

Article by Cloudera VP industry solutions Cindy Maike.

The global pandemic highlighted, without a doubt, the importance and vulnerability of our national healthcare system. It also showed that while leaders may collectively understand the need for foundational healthcare infrastructure, there is a lot more work needed to strengthen the healthcare sector’s digital resilience.           

One way the sector can accelerate this path to resilience is by unlocking its untapped potential of cloud and data. The sector has already had a taste of what this looks like.  Data and analytics played a crucial role in vaccine rollout acceleration; large volumes of patient data from decentralised clinical trials could be aggregated and analysed as fast as possible. 

Today, boards by necessity are having more frequent conversations around digital initiatives, which is encouraging. These conversations are also broader, looking at technology’s role as an enabler of organisational strategy rather than seeing it as an isolated cost centre. There are two key issues driving this change.  A need for hospitals to achieve more efficient and effective healthcare services and the impact of regulatory change on compliance and governance.

Within Australia, boards have increased reporting obligations aligned to the updated critical national infrastructure bill. Unfortunately, within Australia and New Zealand, we now have a history of cyber events disrupting service delivery to patients. Across both sides of the Tasman, we are also seeing tightened cyber security legislation. 

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https://www.afr.com/companies/retail/amazon-keeps-growing-and-so-does-its-cache-of-data-on-you-20220824-p5bce9

Amazon keeps growing, and so does its cache of data on you

Amazon will spend billions of dollars in two gigantic acquisitions that, if approved, will broaden its ever-growing presence in the lives of consumers.

HALELUYA HADERO

Aug 24, 2022 – 1.51pm

From what you buy online, to how you remember tasks, to when you monitor your doorstep, Amazon is seemingly everywhere.

And it appears the company doesn’t want to halt its reach any time soon.

In recent weeks, Amazon has said it will spend billions of dollars in two gigantic acquisitions that, if approved, will broaden its ever-growing presence in the lives of consumers.

This time, the company is targeting two areas: healthcare, through its $US3.9 billion ($5.6 billion) buyout of the primary care company One Medical, and the “smart home”, where it plans to expand its already mighty presence through a $US1.7 billion merger with iRobot, the maker of the popular robotic Roomba vacuum.

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https://itwire.com/science-news/health/scientists-develop-tool-to-monitor-medical-patient-decline.html

Wednesday, 24 August 2022 11:40

Scientists develop tool to monitor medical patient decline

By Kenn Anthony Mendoza

CSIRO scientists have led a study to develop a machine learning tool that informs medical professionals of a patient’s deteriorating condition.

Published in Nature: Scientific Reports in collaboration with Princess Alexandra Hospital and Metro South Health, the study showed that the early warning deterioration alerts can be set to monitor patients two to eight hours before they are triggered by current clinical criteria.

CSIRO scientist Dr Sankalp Khanna said medical professionals could now use the data contained in electronic medical records (EMRs) to predict when a patient’s vital signs such as blood pressure or temperature are likely to reach a danger zone—triggering patient decline.

With the massive amount of data in the EMR comes the potential for better patient care.

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https://www.gizmodo.com.au/2022/08/csiro-medical-alert-tool/

CSIRO’s New Warning Tool Detects Patient Deterioration, but It Requires Better Electronic Medical Records

Asha Barbaschow

August 24, 2022 at 1:43 pm

Imagine a future where medical professionals are alerted to a patient’s deteriorating condition well before physical signs can be seen. That’s a future CSIRO is working towards, leading a new study to develop such technology through machine learning.

The study, CSIRO explained, showed that early warning deterioration alerts can be set to monitor patients two to eight hours before they are triggered by current clinical criteria. This early warning detection isn’t through the use of sensors, but rather an algorithm that pulls data stored in electronic medical records.

Medical professionals could use the data contained in electronic medical records (EMRs) to predict when a patient’s vital signs such as blood pressure or temperature are likely to reach a danger zone, triggering patient decline. But that would require medical records to be kept up to date, and for people to actually use them. My Health Record has a pretty abysmal uptake and as someone who received one as part of the initial trial, there are chunks missing from my record as I moved state-to-state, bulk-billed late-night medical centre to medical centre. There are a number of EMRs out in the wild, not just My Health Record, but a problem CSIRO would run into is interoperability with other hospitals, for example, and the issue of the files not being complete.

“With the massive amount of data in the EMR comes the potential for better patient care,” CSIRO wrote in a press release.

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https://www.lexology.com/library/detail.aspx?g=d564d78e-e50e-4628-8482-1f20e73c684c

Securing Australia’s critical infrastructure: The role of the Cyber and Infrastructure Security Centre

Nyman Gibson Miralis - Dennis Miralis

Australia August 22 2022

Critical infrastructure delivers the essential services for our daily lives such as communications, financial services and markets, data storage and processing, healthcare, and many others.

Cyber-attacks can rapidly impact multiple critical infrastructure sectors, and therefore robust cyber security is essential to protect the community.

Established on 1 September 2021 and sitting within the Department of Home Affairs, the Cyber and Infrastructure Security Centre (CISC) partners with governments, industry and the community to assist critical infrastructure providers to manage risks and protect Australians.

This article explores the key functions of the CISC as outlined on its website.

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https://www.smh.com.au/politics/federal/living-standards-at-risk-without-big-data-and-artificial-intelligence-20220823-p5bbyt.html

Living standards at risk without big data and artificial intelligence

By Shane Wright

August 23, 2022 — 10.30pm

Australian living standards could slip behind those of other countries if the government and businesses fail to use and analyse data or take advantage of new technologies such as artificial intelligence, the Productivity Commission has warned.

As part of its broader examination of ways to lift the nation’s economic speed limit, the commission on Wednesday will release new research that suggests the internet of things, robotic automation and big data analysis could revolutionise the country and boost the living standards of everyday Australians.

The agency, renowned for its advocacy of classic economic solutions, also says governments may have to invest more heavily in rural and regional areas to ensure they are not left in technological wastelands.

Productivity growth in Australia and globally has slowed since before the global financial crisis, contributing to downward pressure on real wages growth. The commission has already estimated Australians are working longer than comparable countries to maintain living standards because of the slowdown in productivity.

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https://www.digitalnationaus.com.au/news/metaverse-to-enhance-medical-and-biopharmaceutical-industry-accenture-584313

Metaverse to enhance medical and biopharmaceutical industry: Accenture

By Athina Mallis on Aug 24, 2022 5:43AM

Scientists and medical technology leaders expect the metaverse to have a positive impact on their organisations according to a new report.

The Accenture Life Sciences Technology Vision 2022 report explained that nearly half of the biopharma executives surveyed believe the metaverse will have a breakthrough or transformational impact on their organisations.

The report explores the technology trends that will transform how biopharmaceutical and medical technology companies solve manufacturing and device problems, improve equity in clinical trial participation and build more resilient supply chains to provide patients and healthcare professionals with more personalised experiences.

Petra Jantzer, global industry life sciences lead at Accenture, said, "We are in the early days of the metaverse, and the technology innovations we implement today — the solutions, products and services companies offer, how they develop and distribute them and how they fundamentally operate their organisations — are the building blocks of the future for life sciences.

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https://wildhealth.net.au/is-tech-pushing-older-gps-out-the-door/

23 August 2022

Is tech pushing older GPs out the door?

By Francis Wilkins

When is it time for a GP to retire?  

The pace of change in new technology and clinical evidence is accelerating, making it harder for older doctors to stay on top of things.  

But with a “workforce cliff” approaching as up to a fifth of GPs plan to retire, and a continuing decline in the number of graduates wanting to specialise in general practice, is there an argument for incentivising GPs to keep working as long as possible?  

The pandemic inspired an all-hands-on-deck mentality, and showed that recently retired GPs could help in various capacities besides regular clinic days. Similar thinking may need to be applied more generally as we face a workforce shortage, especially in regional and rural Australia. 

Currently, there’s no regulatory barrier. AHPRA does not conduct age-based assessments or specify a retirement age. GPs can continue to practise so long as they comply with the MBA’s registration standards and requirements of the National Law. 

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https://wildhealth.net.au/digital-health-pilots-where-many-good-ideas-go-to-die/

23 August 2022

Digital health pilots: where many good ideas go to die

By Tim Blake

Implementing pilot projects for digital health solutions in healthcare is hard.   

There are a myriad of complex considerations which impact adoption, ranging from funding, incentivisation and motivation through to the digital literacy of patients and health providers.  As a result, many projects, even those that show reasonable results, never make it beyond pilot stage.  The “digital health pilot” is where many good ideas, implemented poorly, go to die. 

And if implementing pilot programs for digital health solutions in healthcare is hard, then taking solutions from pilot project to systemic, large-scale adoption is harder still.  Turning a successful pilot project into a widely-adopted, sustainable, digitally-enabled model of care is an art that few have truly achieved.  The huge variety of current state infrastructure, digital literacy, clinical workflows and organisational cultures make implementation on a large scale extremely challenging. 

One of the great risks in the “pilot” approach to driving adoption of digital health solutions is that it rewards health services which are already mature. Digital health maturity is a quantitative and qualitative measure of the extent to which a health organisation has already adopted, and is positioned to adopt, digitally-enabled models of care in the future. 

Therefore, organisations that are progressively minded and have had previous success are more likely to put their hand up to implement new digital health solutions.  And whilst this is not inherently a bad thing, it risks exacerbating the “digital divide” between health services.  The already mature become more mature.  Those without digital confidence get left behind. 

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https://www.innovationaus.com/ixup-homomorphic-encryption-and-the-future-of-data-sharing/

IXUP, homomorphic encryption and the future of data sharing

Justin Hendry
Editor

22 August 2022

As the sharing of personal identifiable information between government agencies and businesses becomes increasingly commonplace, there is growing risk that data is leaked publicly.

The arrival of the Consumer Data Right in 2019 and the passage of legislation that opens a “new path” for public sector data-sharing, more recently, has only accelerated this process in the name of convenience and research.

That’s where secure data software company IXUP, which hoovered up the assets of the collapsed data-sharing startup Data Republic for $3 million last year, comes in.

The ASX-listed Australian scaleup (pronounced ‘eyes up’) has collaborated with Microsoft to produce homomorphic encryption technology aimed at maintaining data confidentiality.

In practice, the technology allows organisations to share encrypted data and generate insights without having to decrypt the original dataset, enhancing the privacy of those whose details are contained in the dataset.

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https://www.afr.com/politics/federal/labor-looks-to-protect-and-promote-critical-tech-20220821-p5bbjm

Labor looks to protect and promote critical tech

Tom McIlroy Political reporter

Aug 22, 2022 – 12.00am

Australia should be at the forefront of critical technology development, boosting domestic industry and positioning the country as an innovation powerhouse, Industry and Science Minister Ed Husic says.

Set to open a new consultation period on how best to harness and manage critical technologies to support Australia’s national interest, Mr Husic has asked for feedback on emerging sectors and categories.

The 2021 national list featured 63 technologies across seven categories, including advanced materials and manufacturing, artificial intelligence, computing and communications, quantum and biotechnology.

Businesses, researchers and the broader community are encouraged to provide feedback on the list, used by the federal government to clarify which technologies are critical to the economy or have the potential to become critical within the next decade.

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https://www.afr.com/politics/federal/australia-s-cyber-shield-boosted-for-jewel-assets-20220820-p5bbfq

Australia’s cyber shield boosted for ‘jewel’ assets

Tom McIlroy Political reporter

Aug 22, 2022 – 5.00am

Companies and institutions considered the “crown jewels” of the Australian economy will get beefed up protection from foreign cyberattacks as the Albanese government activates laws designed to safeguard critical infrastructure and nationally significant systems.

Using national security laws passed by the Coalition for the protection of essential services – including energy, utilities, communications, banking, healthcare and education operations – Home Affairs Minister Clare O’Neil has designated 82 of the most sensitive as critical infrastructure assets.

Managed by 38 different entities, the assets cannot be publicly named under the laws. Together the group is considered the most susceptible to attack from malicious cyber threats and interference, coming amid a deteriorating global threat environment in the wake of the COVID-19 pandemic.

Companies and owners behind the systems, including major Australian and multinational firms, have been alerted to the new designations and associated responsibilities.

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https://itwire.com/guest-articles/guest-research/global-ransomware-survey-reveals-one-in-three-organisations-see-malicious-insiders-as-a-route-for-ransomware.html

Friday, 19 August 2022 10:47

Global ransomware survey reveals one in three organisations see malicious insiders as a route for ransomware

By Gigamon

GUEST RESEARCH: Gigamon, the leading deep observability company, today launched its first State of Ransomware 2022 and Beyond report aimed at providing insights into how the threatscape is evolving and how the severity of the ‘blame culture’ in cybersecurity is escalating.

According to the global survey of IT and security leaders across the US, EMEA and APAC, nearly one-third of organisations have suffered a ransomware attack enabled by a malicious insider, a threat seen as commonly as the accidental insider (35%).

Furthermore, 59% of organisations believe ransomware has worsened in the last three months, with phishing (58%), malware/computer viruses (56%) and cloud applications (42%) cited as other common threat vectors.

As the ransomware crisis worsens, threat actors like Lapsus$ group are now well-known for preying on disgruntled employees to gain access to corporate networks – 95% (and 99% of CISOs/CIOs) view the malicious insider as a significant risk.

Fortunately, 66% of these respondents now have a strategy for addressing both types of insider threats. However, it’s clear that many organisations lack the visibility required to distinguish which type of insider threat is endangering their business, which makes it significantly harder to mitigate risk.

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David.