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Unlike a biocompatibility study that can be scheduled for a specific quarter, cybersecurity cannot be treated as a one-time milestone. It must be an iterative process integrated throughout the entire product lifecycle, from initial design and software development to post-market surveillance.
AI audits are not a one-time, "risk-free" certification but an iterative process with quarterly re-audits. They quantify risk by finding vulnerabilities (which can initially have failure rates as high as 25%) and then measuring the improvement—often a 90% drop—after safeguards are implemented, giving enterprises a data-driven basis for trust.
When facing a massive dataset, don't build for the whole thing. Isolate a representative 'thin slice,' such as 50 rules for a single technology like CloudTrail instead of 1,000 rules. Build a complete, working product for that slice to prove value and validate your approach before committing to the full-scale project.
MedTech companies mistakenly assign product cybersecurity to their IT teams, whose focus is data protection. Product security is about patient safety and should be owned by Quality Assurance, as all documentation must integrate into the Quality Management System (QMS) like other design files.
Contrary to typical agile discovery, projects in high-stakes environments benefit from starting with extremely strict processes and documentation. This establishes a compliant foundation. Flexibility can be introduced later, once core requirements and constraints are fully mastered, rather than starting loose and adding rigor.
Retrofitting cybersecurity into a medical device near submission is a common, catastrophic error. The FDA requires security to be designed-in from the start. "Bolting it on" later leads to significant delays and costs, much like trying to add rebar to an already-poured foundation.
Treating AI risk management as a final step before launch leads to failure and loss of customer trust. Instead, it must be an integrated, continuous process throughout the entire AI development pipeline, from conception to deployment and iteration, to be effective.
Products are no longer 'done' upon shipping. They are dynamic systems that continuously evolve based on data inputs and feedback loops. This requires a shift in mindset from building a finished object to nurturing a living, breathing system with its own 'metabolism of data'.
The primary lens for medical device cybersecurity should be patient safety, not data protection. A hacked device can directly harm a patient, making security as fundamental as sterility. This reframing changes the entire approach from a compliance checklist to a core design principle.
Shift the view of AI from a singular product launch to a continuous process encompassing use case selection, training, deployment, and decommissioning. This broader aperture creates multiple intervention points to embed responsibility and mitigate harm throughout the lifecycle.
A MedTech company was forced to disable key features to gain FDA clearance because a microcontroller selected two years earlier lacked necessary security capabilities. This shows how seemingly minor, early hardware decisions can have irreversible and costly consequences on the final product's functionality.