IS INFORMATION SECURITY POLICY
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1 IS INFORMATION SECURITY POLICY Version: Version 1.0 Ratified by: Trust Executive Committee Approved by responsible committee(s) IS Business Continuity and Security Group Name/title of originator/policy author(s): Marcus Kirby, Head of IS Support Services Lead Executive(s): Chrisha Alagaratnam, Director of Finance and Performance Date issued: March 2012 Review date: January 2015 Target audience: All staff Page 1 of 8
2 Section Page 1. Introduction 3 2. Key Audience 3 3. Summary 3 4. The Policy Aims 3 5. The Policy 3 6. Relevant Legal and Statutory Requirements Risk Assessments 3 7. Key Roles and Responsibilities Chief Executive Officer Head of IS support Services Information Excellence Committee Business Continuity and Security Group Application System Management Head of Information Security Systems Manager Managers Responsibilities Staff Responsibilities 6 8. How the policy will be monitored, audited and reviewed 6 9. Relevant Policies and Procedures Relating to IS Service Continuity Equality Impact Assessment Appendices NONE Page 2 of 8
3 1. INTRODUCTION The Epsom and St Helier University Hospitals NHS Trust (Trust) is increasingly dependent upon its information systems for its normal day to day operational and administrative functions. It is therefore essential that the confidentiality, integrity and availability of Trust systems and information are maintained at a level which is appropriate to its needs. Whilst it is not possible to absolutely guarantee that all systems and information are always secure, this policy reduces the risk to a minimum. 2. KEY AUDIENCE All Staff 3. SUMMARY The purpose of this Information Security Policy is to protect, to a consistently high standard, all information assets, including patient records and other NHS corporate information, from all potentially damaging threats, whether internal or external, deliberate or accidental. This policy, related policies and sub policies are aimed at providing a comprehensive and consistent approach to the security management of information across the Trust in line with legislation and NHS guidance. It will ensure continuous business capability, and minimise both the likelihood of occurrence and the impacts of any information security incidents. This policy applies to all information assets and all records held on any medium both paper and electronic. The policy applies to all Trust employees and all partners, suppliers and service providers to the Trust who have legitimate rights to access and use Trust information and information systems. It is compulsory that all those who work for the Trust whether as an employee, a contractor or a supplier comply with this policy, related policies and sub policies and the standards, guidelines and procedures that are derived from them. 4. THE POLICY AIMS The Information Security Policy is intended to preserve confidentiality, integrity and availability of data. Confidentiality Integrity Availability by protecting information against unauthorised disclosure by protecting information against errors, omissions or unauthorised alterations by protecting information against destruction and degradation of the service/s and making it accessible to appropriate staff when they require it 5. THE POLICY A comprehensive, systematic and reliable programme for information security management will be maintained based on the requirements of the Information Page 3 of 8
4 Governance Toolkit. There will be annual reporting of attainment and associated improvement plans through the formal information governance structures. Threats to information security will be identified through robust risk assessment and management arrangements and shall be a key component of its overall Information Governance strategy. Threats will be reviewed to ensure that: Data is protected against unauthorised access or disclosure The integrity and evidential value of information shall be maintained Information shall be available to properly authorised personnel as and when it is required Relevant regulatory and legislative requirements will be achieved. The Trust will have in place organisation wide service continuity plans for all information systems. This will include risk assessments to ensure that alternative fallback arrangements are identified and tested. Relevant Information Governance training and awareness will be available to all staff. All breaches of information security, actual or suspected, shall be recorded, reported to and investigated by an appropriately appointed, trained and experienced Information Security Officer. All organisations that access the NHS network infrastructure or services provided under a national contract shall satisfy and maintain NHS Information Governance, NHS Statement of Compliance and Information Security Management conditions. There will be adequate audit provision, based upon robust risk management arrangements to ensure the continuing effectiveness of information security management. 6. RELEVANT LEGAL AND STATUTORY REQUIREMENTS 6.1 Risk Assessment The Trust will ensure that any risk identified is adequately assessed in accordance with the Trust s Risk management Policy and the associated risk management procedures so that appropriate action can be taken to reduce the risk so far as is reasonably practicable. 7. KEY ROLES AND RESPONSIBILITIES 7.1 Chief Executive Officer The Chief Executive Officer has overall responsibility for the Information Security Policy within the Trust. This responsibility on a day to day basis is delegated to the Director of Information Services. 7.2 Head of IS Support Services Page 4 of 8
5 The Head of IS Support Services has overall responsibility for the management of Trust IT systems, infrastructure and for the technical aspects of Information Security. RESPONSIBLE COMMITTEES 7.3 Information Excellence Committee Is responsible for ensuring that the Trust has a compelling vision for Information Services owned by clinicians and other senior decision makers to ensure that strategy, plans, policies and management arrangements are effective in moving the Trust towards this vision. 7.4 Business Continuity and Security Group A sub group reporting to the Information Excellence Committee is responsible for developing and testing Business Continuity plans and to manage IS security arrangements to the IG toolkit standards. RESPONSIBILITIES 7.5 Application System Management Each Information system will have a designated Data Custodian and System Manager, sometimes these roles will be the same. Day to day responsibilities for enforcing the policy is devolved to the Data Custodians/System Managers. 7.6 Head of Information Security The person responsible for ensuring that a system and its users comply with the current Data Protection legislation and with the Data Protection Principles. This will include responsibility for ensuring that the registration of the system is kept up to date and that procedures are in place to achieve a high level of data quality. Usually part of the System Managers responsibilities. 7.7 System Manager This will be the individual who routinely maintains the computer hardware and its operating system in an operational condition. The individual is responsible for maintaining the integrity of the application; their role will typically involve authorising users and passwords, setting up access restrictions within the application, co-ordinating the provision of training and in certain cases coordinating the operational use of the application; monitoring the quality of the applications functionality and liaison with the Data Custodian to ensure the application is used to its fullest. 7.8 Manager s responsibilities Managers will ensure that; staff are instructed in their security responsibilities staff using computer systems/media are trained in their use only authorised staff are allowed access to the departments information Page 5 of 8
6 documentation is always maintained for all critical job functions to ensure continuity in the event of an individual s unavailability staff sign confidentiality agreements as part of their contract of employment. the relevant departmental systems administrators are advised immediately about staff changes affecting computer access (e.g., job function changes/leaving department or organisation) so that passwords may be withdrawn/deleted 7.9 Staff responsibilities All staff are responsible for acting in compliance with this policy and working to ensure that all the Trust information to which they have access is managed appropriately and securely. 8. HOW THE POLICY WILL BE MONITORED, AUDITED AND REVIEWED Compliance with this policy is monitored at local level and through the Business Continuity and Security Group. This policy will be the subject of a regular review by the Business Continuity and Security Group which will take place at not less than 3 yearly intervals. Earlier review may be triggered in response to feedback from training, regulatory changes or in response to critical incidents. 9. Relevant Policies and Procedures relating to IS Service Continuity Related policies IS Remote Access Policy IS Service Continuity Policy IS Disaster Recovery Policy IS Network Security Policy IS Access Control and Authentication Policy IS Legal and Regulatory Compliance Policy IS Risk Assessment and Management Policy IS Mobile Computing Policy IS Configuration Management and Change Control Policy IS Backup and Recovery Policy IS and Internet Use Policy IS Malware Policy IS Data Protection Policy IS Home working Policy Page 6 of 8
7 EQUALITY IMPACT ASSESSMENT FORM In order to carry out an effective impact assessment it is important to examine all available data and research so that any adverse impact on disability can be properly assessed. 1. Name of function, strategy, project or policy 2. Name, job title, department, and the telephone number of staff completing the assessment form 3. What is the main purpose and outcomes of the function, strategy, project or policy. 4. List the main activities of the function, project/policy (for strategies list the main policy areas) 5. Who would benefit from the strategy/project/policy IS Information Security Policy Malcolm Flier, Is Head of Support Services Mob: Tel: The purpose of this Information Security Policy is to protect, to a consistently high standard, all information assets, including patient records and other NHS corporate information, from all potentially damaging threats, whether internal or external, deliberate or accidental. This policy, related policies and sub policies are aimed at providing a comprehensive and consistent approach to the security management of information across the Trust in line with legislation and NHS guidance. Trust staff needing to access to IT systems and services. 6. Is it relevant to: - Race Relations Act - Sex Discrimination Act - Disability Discrimination Act - Employment Equality Regulations - Religion or Belief - Sexual Orientation - Age 7. Do you think that the function/strategy/project/ policy could have a negative or positive impact on : Race Disability Gender Religion Sexual Orientation Age 8. How could you minimise or N/A Yes 1. No Not relevant Not applicable there is no positive or negative impact on any of these aspects. Page 7 of 8
8 improve any negative impact? Explain how. 9. What consultation with relevant users on this project has taken place. 10. If there are gaps in your consultation and research, are there any experts/relevant groups that can be contacted to get further views or evidence on the issues. Please list them and explain how you will obtain their views. 11 a) Have you involved your staff in taking forward this impact assessment? 11 b) How have you involved the staff 12. In the light of all the information detailed in this form what practical actions would you take to reduce or remove any adverse/negative impact. N/A N/A N/A N/A To be signed by the Manager completing this form. Signed Date: 10 th January 2012 Malcolm Flier Head of Support Services Page 8 of 8
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