USB debugging left on
A clinical Android tablet had developer options enabled. AC-19(3) MDM policy disables debugging so a connected PC cannot easily dump memory while an EHR session is live.
Disable Random Access Memory Dumping
Medium Risk
Moderate
Low Cost
AC-19(3) addresses disabling unauthorized dumping of random-access memory contents on mobile devices — a path attackers and some forensic tools use to extract credentials, tokens, and cached ePHI from device memory. Healthcare-managed phones and tablets should disable developer/debug options for standard users, restrict unauthorized diagnostic interfaces, and use MDM policies that prevent casual enabling of memory-dump capable debugging on devices enrolled for clinical apps.
Control Objective
Prevent unauthorized RAM/memory dumping and related debug interfaces on mobile devices that access ePHI so credentials and health data in memory are harder to extract.
Implementation Guidance
- MDM: disallow developer options / USB debugging on corporate clinical devices for standard users.
- Prefer supervised/managed device modes that restrict unauthorized diagnostic tooling.
- Block sideloading of apps that claim forensic dump capabilities on managed profiles.
- Limit physical debug ports where hardware allows; control who may use enterprise diagnostic modes.
- On laptops, restrict local users from arbitrary crash-dump collection to removable media when policy requires; protect dump files that may contain ePHI.
- Authorize break-glass diagnostic access only for IT with ticket and wipe afterward.
- Educate that jailbreak/root often enables memory inspection — mark non-compliant.
- Align with SI-16 / memory protection controls where applicable on endpoints.
Real-World Use Cases
How this control shows up in healthcare and HIPAA-covered environments.
Jailbroken on-call phone
Device fails compliance because root facilitates memory scraping; conditional access blocks clinical containers.
Laptop hibernation abuse
Policy controls dump/hibernation file handling on ePHI laptops so offline memory images are not freely copied to USB by standard users.
Best Practices
- Disable developer/debug options by policy.
- Supervised mode for clinical tablets.
- Jailbreak/root detection.
- Control diagnostic break-glass.
- Protect crash dump storage.
- Pair with encryption and screen lock.
Common Gaps & Violations
- Developer mode allowed on production clinical tablets.
- No jailbreak detection for BYOD clinical apps.
- Unrestricted USB debugging with ePHI apps installed.
- Crash dumps with cleartext ePHI written to unlocked shares.
- Shared admin PIN that enables debug menus.
Required Documentation
- Mobile debug/RAM dump restriction standard (AC-19(3))
- MDM configuration prohibiting developer options
- Jailbreak/root compliance rules
- Authorized diagnostic procedure
- Laptop dump-file handling rules (if in scope)
How to Test & Validate
- Attempt to enable USB debugging on managed clinical device; confirm blocked.
- Verify jailbroken/rooted test device is non-compliant.
- Confirm only authorized IT can enter diagnostic modes.
- Review crash-dump paths on sample ePHI laptops.
- Spot-check supervised tablet restrictions.
Audit Considerations
This enhancement is specialized; show MDM restrictions on debugging and non-compliance actions for rooted devices used with ePHI apps.
HIPAA Mapping
How this NIST control supports HIPAA Security Rule expectations.
- 164.312(a)(1) Access Control — prevent unauthorized extraction of ePHI via device interfaces.
- 164.312(c) Integrity — unauthorized memory dumping can facilitate integrity attacks and credential theft.
- 164.308(a)(1) Risk Analysis — physical access to mobile devices includes memory-extraction threats.
- 164.312(d) Person or Entity Authentication — dumped tokens undermine authentication.
Compliance Tips
- Include ‘developer options off’ in the mobile hardening checklist.
- Treat rooted devices with clinical apps as high-priority compliance failures.
- Limit who can run enterprise mobility diagnostic tools.
Frequently Asked Questions
Does this block legitimate MDM inventory?
No — enterprise management agents are authorized. The goal is unauthorized dumping by users or attackers.
Are crash dumps always forbidden?
Not always — control and protect them; they may contain sensitive data and should not be world-readable.
Is this only for phones?
Mobile devices broadly; apply analogous dump restrictions on portable endpoints that cache ePHI.
References & Resources
- NIST SP 800-53 Rev. 5 — AC-19 family enhancements
- NIST SP 800-124
- Related controls: AC-19, SI-16, CM-7, IA-3, MP-5
Related Guidelines
Related controls that commonly accompany AC-19(3).
Need Help Implementing AC-19(3)?
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