Aim
The aim of this Policy is to establish
and maintain the security and confidentiality of information,
information systems, applications and networks owned or held by NHS
East Midlands.
The objectives of this policy are to
preserve:
- Confidentiality – access to data must be confined to those with
specific authority to view the data
- Integrity – Information is to be complete and accurate. All
systems, assets and networks must operate correctly, according to
specification
- Availability – Information must be available and delivered to
the right person, at the time when it is needed
This policy seeks to ensure that:
- NHS East Midlands Information Systems are properly assessed for
security (manual and electronic)
- Confidentiality, integrity and availability are maintained
- Staff are aware of their responsibilities, roles and
accountability
- Procedures to detect and resolve security breaches are in
place
- Systems are not misused
Scope
This policy applies to all NHS East
Midlands Directorates and all users of NHS East Midlands
information systems and networks.
Responsibilities
- Ultimate responsibility for IM&T security rests with the
Chief Executive.
- At Board level, responsibility for IM&T Security resides
with the Director of Strategic IM&T
- Line managers are responsible for ensuring that their permanent
and temporary staff, and contractors, are aware of the IM&T
Security policy and their roles and responsibilities detailed
within it
- It is the responsibility of all staff to comply with this
policy.
Definitions
Information System – for the purposes
of this policy, an information system is defined as any electronic
means of processing data. Examples include network access, SBS, and
ESR.
Potential Threats
This Policy has been designed to
address the following risks:
- Fraud – altering data for private gain or benefit, altering or
misusing programs, destroying/suppressing/misappropriating computer
output
- Viruses – introducing viruses to NHS East Midlands computers
and systems
- Theft – of data, software and hardware
- Use of unlicensed software – using illicit copies of
software
- Private work – unauthorised use of NHS East Midlands computing
facilities for private gain or benefit
- Hacking – deliberately gaining unauthorised access to a
computer system
- Sabotage – causing deliberate damage to data, software,
processes or equipment
- Misuse of personal data – unofficial access to data or
‘browsing’ through computer records and breaches of Data Protection
legislation
- Introducing offensive material – access to or processing
offensive material (e.g. pornographic or racist material)
- Integrity – ensuring data is accurate and of good
quality
Total security is almost certainly
impossible to achieve but adequate security represents a balance
between these four factors:
- The risks of illegal access/damage
- The consequences and costs of damage limitation
- The limitations that the security may impose on users
- The costs of implementing the security
Human attitudes are fundamental to good
security. Managers, users and operators must be aware of the
reasons for taking security issues seriously and take appropriate
action.
Misuse of NHS East Midlands information
systems or communications equipment by an employee may result in
disciplinary action.
Equipment Security
Equipment security is required to
protect IM&T equipment against loss, theft or damage, and to
avoid interruption of business activity.
Equipment Siting
All PC and terminal screens must be
positioned so that any confidential information displayed will not
be viewable by unauthorised personnel.
Security of Equipment &
Information Off-Site
Equipment and person identifiable data
should not be taken off site.
Confidential or sensitive information
should not be placed on privately owned computers and must be
stored on NHS East Midlands file servers.
Sensitive or person identifiable data
stored for the purposes of transportation on portable devices must
be held in accordance with NHS East Midlands Transportation of
Records Procedure and NHS East Midlands Mobile
Computing/Teleworking Procedure.
All laptops must be encrypted to ensure
the data they hold is stored securely and cannot be accessed by
unauthorised users should the laptop be stolen or lost.
Security of Third Party
Access
No external agency (NHS or not) will be
given access to NHS East Midlands network unless that body has been
formally authorised to have access by NHS East Midlands Director of
Strategic IM&T (or nominated deputy). All non-NHS agencies will
be required to sign security and confidentiality agreements with
NHS East Midlands. Third parties must also obtain NHS Connecting
for Health’s Statement of Compliance.
External agencies will only be allowed
access to the hardware/systems for which they are responsible.
NHS East Midlands will control all
external agencies access to its systems by enabling/disabling
through the secure gateway, for each approved access requirement,
as per Derwent Shared Services Firewall Policy.
Remote Access
Staff will only be allowed remote
access to the NHS East Midlands network after gaining the
permission of their line manager and completing a remote access
application form provided by DSS Customer Services Team.
User Access
Control
Setting network access for staff will
form part of the starter’s process managed by line mangers. The
removing of network access for staff will form part of the leaver’s
process managed by Human Resources.
When an individual’s responsibilities
change or they leave the employment of the NHS East Midlands,
system managers will modify or remove access privileges as
appropriate.
Whenever possible, user classification
should be used when allocating access rights to systems. The issues
to be considered in user classification are:
- Restricting access to certain parts of the records
- Restricting access to:
- Named data
about individuals
- Anonymised
data about individuals
- Aggregated
data
- Restricting user access to a particular ‘view’ of the data
- Defining what a user can do with the data i.e. create, read,
update, delete
- Defining whether a user should have ‘online’ access, access for
batch processing, pre-set reports or ad hoc reports.
User Password
Management
Users must keep their passwords secret
and never disclose them to colleagues.
Passwords must be changed regularly –
all new systems must enforce regular password changes.
Passwords must not be easily guessable
or have been used before. The recommended minimum password length
is 6 characters using a combination of alphabetic and numeric
characters.
When a member of staff leaves their
position, their access rights must be removed from any systems that
they access. Line managers must ensure that system administrators
are informed when a member of staff leaves or changes role to
ensure this takes place.
When leaving their PC users should
either log off, or “lock” their PC by pressing ctrl-alt-delete.
This ensures a password is entered before the PC can be unlocked
and used. Smartcard users should remove their smartcard when
leaving a PC unattended.
Systems must be able to provide an
audit trail of user logins and activity.
Contractors & Temporary
Personnel
All contractors, agency and temporary
staff are subject to the same checks as permanent staff, and must
abide by the NHS East Midlands policies and procedures when
accessing systems and handling person identifiable data.
Adequate training, in keeping with the
designated responsibilities and risks, must be given prior to
authorising access.
Portable Devices
A portable device is defined as any
electronic device that can hold information (specifically person
identifiable data) e.g. portable computers, laptops, notebooks,
palmtops, Personal Digital Assistants (PDA’s), Blackberries.
Portable devices represent a heightened
risk regarding their physical security because:
- By definition, they are portable, smaller and easy to
steal
- Due to their portability they are more likely to be left in
less secure locations
- Any personal or confidential data stored on them is more
vulnerable because of the factors above
Therefore, particular measures should
be taken regarding these types of computers. As a result of this
risk NHS East Midlands has developed specific guidance surrounding
the usage and transportation of portable devices which can be found
in NHS East Midlands Transportation of Records Procedure and NHS
East Midlands Mobile Computing Procedure.
Housekeeping
All systems will be backed-up regularly
to ensure integrity and availability of data and all back-up tapes
and disks will be held in secure locations.
All PC users must save their files onto
the server rather than the hard drive of their PC.
Back-up and maintenance procedures must be adequately documented to
enable other technical staff to understand and comply with the
requirements.
Equipment Disposal
All removable media must be reformatted
before disposal, however if this is not possible, the media should
be destroyed.
Derwent Shared Services Customer
Services Team should be contacted to collect and dispose of all
redundant computer equipment. A technician should check that the
equipment can no longer be used and confirm that it should be
disposed of. Any data should be deleted, transferred or archived
prior to disposal.
Software
Protection
All users must ensure that they only
use licensed copies of software. It is a criminal offence to make
or use unauthorised copies of commercial software and offenders are
liable to disciplinary action.
All software should be installed by
Derwent Shared Services technical staff.
It is the responsibility of system
managers to ensure that the software pertaining to their system is
being used within the terms and conditions of the software
licence.
Software will not be placed on network
servers or on multiple machines unless this is in accordance with
the licensing agreement.
Any employees learning of any misuse of
software should report this to the HQ IT Manager.
Software Updates to
Systems
Anti-virus software will be installed
on all NHS East Midlands PCs (including laptops). Updates will be
automatically uploaded via log on scripts.
Emails from an unknown source should be
carefully examined. If an email looks suspicious, users should
contact Derwent Shared Services customer services team for
advice.
Users should report any
suspected/detected viruses on their machines to Derwent Shared
Services customer services team immediately.
Files should only be downloaded from
the internet if they are from a trusted source. If in doubt the
user should contact Derwent Shared Services customer services
team.
Equipment
Installation
IM&T equipment should be installed
and sited in accordance with the manufacturer’s specification.
All computer/communications equipment
rooms should be inaccessible to non-authorised staff at all
times.
Environmental controls will be
installed to protect key/central equipment.
Drinking and eating is not allowed in
areas housing critical computer or communications equipment such as
servers.
Power Supplies
Critical computer equipment will be
fitted with battery back-up to ensure that it does not fail. Such
battery power should suffice for all critical systems to perform an
automatic shut down.
An uninterrupted power supply should be
used for multi-user operational systems as it guarantees protection
from power cuts and fluctuations.
Development & Introduction
of Systems
NHS East Midlands, in conjunction with
Derwent Shared Services, will ensure that all new information
systems, and any developments to existing systems, comply with
Information Governance requirements.
Asset Control
An up to date register of all NHS East
Midlands IT equipment and disposals of physical computer assets
will be maintained by Derwent Shared Services in conjunction with
the HQ IT Manger.
An up to date register of all
proprietary software will be maintained by Derwent Shared Services
to ensure that licence conditions are followed.
Each of NHS East Midlands systems will
have a designated system owner(s) who are responsible for ensuring
compliance with this policy.
Access Control to Secure
Areas
All central processors/networked file
servers/central network equipment will always be located in secure
areas with restricted access.
In restricted areas, unrecognised or
unaccompanied visitors should be challenged.
Disaster Recovery
A full disaster recovery plan should be
in place, developed in conjunction with Derwent Shared
Services.
Internet & E-Mail
Use
All staff should ensure they understand
and comply with NHS East Midlands Internet Use and E-mail
Policies.
IM&T Security
Incidents
IM&T Security incidents should be
reported and dealt with in line with NHS East Midlands Incident
Reporting Policy.
Monitoring of the
Policy
This policy will be monitored by NHS
East Midlands Information Governance Steering Group.