Type: Register No: Status: Remote IT Working Policy 09021 Public Developed in response to: IG Toolkit Best Practice Contributes to CQC Outcome No 21 Consulted With Post/Committee/Group IT Operations Manager Barry Stannard Information Governance Manager Liz Stewart Health & Safety Manager Leanne Wilson Shaun Jeffery MBCS MCMI Acting Head External Technical Peer of ICT, Newham University Hospital NHS Review Date 22-02-2012 22-02-2012 22-02-2012 06-02-2012 Trust 01-03-2012 Professionally Approved By Kate Thompson , Head of IT Version Number 2.0 Issuing Directorate IT Ratified by: Document Ratification Group Ratified on: 22nd March 2012 Trust ExecutiveSign Off Date April 2011 Implementation Date 26th March 2012 Next Review Date February 2015 Author/Contact for Information Dave Shrimpton, IT Security Manager Policy to be followed by (target staff) All Trust Staff, Contractors and Affiliates Distribution Method Intranet, Internet Related Trust Policies (to be read in 08088 Acceptable Use of IT Policy conjunction with) 07011 Confidentiality Policy Document Review History Review No 1.0 – Added extra detail to section 4. 1.1 – Amendment to Appendix 1 2.0 – Scheduled Review Reviewed by D Shrimpton Review Date 03-08-2010 D Shrimpton D Shrimpton 11-07-2011 02-02-2012 It is the personal responsibility of the individual referring to this document to ensure that they are viewing the latest version which will always be the document on the intranet 1 Index 1. Purpose of Policy 2. Policy 3. Responsibilities 4. Remote Working Procedure 5. Terms & Conditions 6. Provision of Equipment 7. Health & Safety 8. Monitoring 9. Communications 10. Contact Point 11. References Appendix 1 - Approval for Remote Working Application Form Appendix 2 - Health & Safety Information Appendix 3 – IT Security Guide Appendix 4 – User Connection Instructions 2 1. Purpose of Policy 1.1 Information and information systems are important corporate assets and it is essential to take all the necessary steps to ensure that they are at all times protected, available and accurate to support the operation and continued success of the Trust. 1.2 The Trust acknowledges that it must demonstrate to third parties our expertise in security technology and implementing it. To achieve this it is recognised that we must protect our own assets as well as the environment. 1.3 To provide a secure method of promoting flexible working practices. 1.4 To define appropriate remote access and its use by authorise staff. 2. Policy 2.1 The Trust employees and authorised third parties (e.g. supplier support) can use remote access connections to gain access to the corporate network. Remote access will be strictly controlled, using one-time password authentication. 2.2 It is the responsibility of employees or authorised third party individual with remote access privileges to ensure any connection to the Trust is not used by nonemployees to gain access to the Trust’s information system resources. An employee who is granted remote access privileges must remain constantly aware that any connections between their location and the Trust are literal extensions of the Trust's corporate network, and that they provide a potential path to the company's most sensitive information. The employee and/or authorised third party individual must take every reasonable measure to protect the Trust’s assets. 2.3 Any employee found to have violated this policy may be subject to the Trust’s Disciplinary Policy. 2.4 The Trust will support staff who, in appropriate circumstances, wish to undertake a part of their work either at home or from a remote location. As such, the Trust wishes to promote flexible working practices, reduce unnecessary travel and give staff more control over their working lives. This policy covers all aspects of working practice for members of staff undertaking work outside their conventional workplace. 2.5 Developments in IT systems may develop over time which may involve changes in the equipment supplied. This policy covers all current and future equipment and procedures. 2.6 All breaches are to be deemed as Serious Untoward Incidents and investigated under that policy. 3 3. Responsibilities 3.1 Head of IT Ensure availability of appropriate equipment Has the authority to remove any remote working facility from any member of staff who is not adhering to policies and is putting the Trust IT facilities at risk • • 3.2 IT Security Manager • • • 3.3 Divisional and Service Leads • 3.4 Identify and authorise the staff who require this facility Line Managers • • • • • • 3.5 Ensure that remote working is appropriate Ensure that all staff working remotely have signed a Health & Safety declaration in relation to the environment that they are working in Ensure that all remote workers have read and understood the 08088 Acceptable Use of IT Policy Ensure that all remote workers have read and understood the 07011 Confidentiality Policy Are responsible for ensuring that all equipment is returned when staff leave the Trust Are responsible for notifying helpdesk of all leavers with remote working access so that accounts can be closed All Staff • • • • 3.6 Abide by all the applicable IT and Information Governance Policies, particularly those relating to Acceptable Use of IT and the Trust’s Confidentiality Policy Staff must identify themselves to the network by using their own logon credentials Maintain a safe working environment and sign the Health & Safety Declaration Return all equipment provided when ceasing to undertake remote working for the Trust Contractors – Third Party Support • 3.7 Provide up to date advice to Head of IT on the most appropriate and secure methods of home working Has the authority to remove any remote working facility from any member of staff who is not adhering to policies and is putting the Trust IT facilities at risk Keep Remote Working policies and procedures current and up to date Abide by all the applicable IT and Information Governance Policies, particularly those relating to Acceptable Use of IT and the Trust’s Confidentiality Policy Information Governance Group Receive and consider all breaches of this policy 4 4. Remote Working Procedure 4.1 This section outlines the control procedures in place for remote working. • • • • Remote working must be approved by the employee’s line manager Connection will only be made to the Trust network via secure broadband access Connectivity may be gained by a single entry point that will control access to the network, e.g. firewall and secure ID Token. Users must authenticate to the network, by using two-factor authentication, i.e. Secure Token across a broadband line and Trust network user credentials (User name and password) Or by using a Trust owned and supplied laptop with IAG installed. Again users must use their trust supplied logon credentials 5. Terms and Conditions 5.1 Two-factor credentials must be kept confidential at all times. 5.2 Lost tokens must be reported immediately so accounts can be disabled, this would be documented as a security incident. 5.3 Any agreement on remote working is not permanent and may be brought to an end at any time by the member of staff or the Trust. An authorisation will be based on the needs of the Trust, the job, and the department. 5.4 The authorisation is based on full, written agreement to the Trust's policy on remote working, see Appendix 1 and completion of a satisfactory health and safety risk assessment which must take into account all foreseeable risk arising from the work activity, and at the remote workplace. See Appendix 2. 5.5 The Trust monitors who logs into the network and can monitor which Internet and NHSnet sites are visited by any one user. Access to the remote access server is provided on the understanding that this is understood and accepted. 5.6 Any hardware or software provided by the Trust remains the property of the Trust and shall be returned at the end of the remote working arrangement. Products, documents and other records used and/or developed while working remotely remain the property of and will be available to the Trust. This information is subject to Trust policies regarding confidentiality and access, including the Caldicott recommendations. 5.7 Trust owned software may not be duplicated. Staff working remotely using Trust software must adhere to the manufacturer's licensing agreements. 5.8 The member of staff working remotely is responsible for setting up and maintaining an adequate workspace at the remote workplace and for ensuring that it is maintained to the same standards as apply to the conventional workplace. 5.9 Purchasing and maintenance of appropriate personal office furniture or equipment e.g. desks, filing .cabinets, answering devices, etc, is the responsibility of the member of staff working remotely. 5 5.10 Remember: You are bound by the “NHS Confidentiality Code of Practice”. Ensure you do nothing which would breach this guideline. E.g. displaying confidential/sensitive material in a public place. Examples – on a train, in a coffee shop etc. 6. Provision of Equipment 6.1 The Trust will not provide or maintain a home PC or broadband connection, but will provide the necessary additional equipment to enable remote connection to the Trust's network if necessary and required. This equipment could include: • An active Token, synchronised to the network to provide once only passwords for secure login. This may be a “Smartcard” or “RSA” token. 6.2 Laptops are not primarily for home working but for staff who need to regularly move from one workplace to another in the course of their normal work 6.3 The Trust is not liable or responsible for the support of home equipment except in respect of the equipment and software detailed above and directly relevant to remote access the Trust's systems. 7. Health and Safety 7.1 The Trust has a duty to ensure that the Display Screen Equipment (DSE) which the Trust owns or uses, is constructed, operated and maintained in a manner which ensures the safety of its operatives. 7.2 Knowledge of the minimum Health and Safety requirements for work with DSE is regarded as a basic requirement for all staff employed defined as a “user” by Mid Essex NHS Trust. This requirement is achieved by the manager responsible ensuring that those persons receive appropriate information and guidance. DSE guidance, applies to staff working remotely as well as when working in their conventional workplace. Authorisation for remote working is subject to satisfactory completion of Appendices 1 and 2. 7.3 The DSE Regulations state that “Portable DSE, such as Laptops and Notebook computers, is subject to the DSE Regulations – if it is consider prolonged use. “Prolonged use” shall be two hours or more in a single day or work period. Employees who use a laptop for less than this period are not generally considered to be at risk, though a risk assessment should be carried out to ensure this. 7.4 A laptop that is to be used for two hours or more in a single day or work period should be positioned and used, so far as possible, in the same way as full size equipment. The use of Docking Stations should be encouraged to allow the use of full size equipment. 7.3 The need for a risk assessment still applies and is particularly important. For further risk assessment details and access to the risk assessment for DSE form please refer to the Trust DSE policy. 6 8. Monitoring 8.1 Any breaches of the policy will be individually considered at the Information Governance Group who will make recommendations for any amendments that may need to be made to the policy to reduce risk. 8.2 This policy is covered by the IT Monitoring Policy. 9. Communication 9.1 Information Governance will publish this policy on the Trust’s intranet and website and notify all staff via Focus. 9.2 The author will notify all heads of services who will be responsible for ensuring that the policy is cascaded throughout their work areas. 10. Contact Points All communications regarding Remote Working will be handled by the IT Helpdesk initially. 11. References ISO/IEC 27001:2005 A.11.7.1 IG Toolkit V9, 9-314 NHS Confidentiality Code of Practice NHS Information Security Code of Practice 7 Appendix 1 Approval for Remote Working Form must be fully completed The member of staff named below has received express approval to work remotely and has read, understood and agrees to the conditions within the Trust's policy on remote working including: Acceptable Use of Information Technology Policy and Confidentiality Policy and IT Security Guidelines (appendix 3). I also acknowledge the receipt of the VPN Instructions for user’s document (appendix 4) Equipment being used Description/Type of Equipment ………………………..................................................................................................... ..................................................................................................................................... Asset Number …………………………………………………………….. Name of applicant ………………………………................... Signature ………………………………........................ Date ………………………………................................ Line Manager ……………………………….......................... Signature ………………………………........................... Date …………………………….................................….. An approved remote working application must be kept by the member of staff and a copy sent to the IT Helpdesk. 8 Appendix 2 Remote Working - Health and Safety Responsibilities The Trust cannot accept the responsibility for the health and safety of a remote working environment: • If the remote site is, another Trust or facility providing a service to Mid Essex Hospital Services NHS Trust the Health and Safety of the user will fall under the remote site’s health and Safety guidelines • If the remote user is working from home it will be the individual’s responsibility to ensure that they conduct any work for the Trust in a safe and practical manner as they would if situated in an office environment within Mid Essex Hospital Services NHS Trust The following list is a guide that the Trust recommends that a remote user should follow when working from home. Workplace Environment • Try to work in an environment where temperature, noise ventilation and lighting levels are adequate for maintaining your normal level of job performance • All stairs with four or more steps equipped with handrails • Do you have all electrical equipment free of recognised hazards that would cause physical harm (frayed wires, bare conductors, loose wires, flexible wires running through walls, exposed wires to the ceiling)? • Is the environment you have chosen, free of obstruction to permit visibility and movement? • If you have, any filing cabinets and storage closets are they arranged so drawers and doors do not open into walkways • Make sure that any chairs, which will be used for work purposes, have no loose casters (wheels) and the rungs and legs of the chairs are sturdy. If possible use adjustable chair to help with posture when working for any prolonged period of time • Tidy all phone lines, electrical cords, and extension wires so that they are secured under a desk or alongside a skirting board 9 • Try to keep office space neat, clean and free from clutter that could become a hazard • Try to keep any floor surfaces clean, dry, level and free of worn or frayed seams in your chosen working environment and carpets are well secured to the floor and free of frayed or worn seams? • Ensure you have enough lighting for reading • Try to have a basic first aid kit in your home • If you do not have one fit a smoke alarm • Try to use an area of the home were you can set up your computer so that the monitor and keyboard are in the correct position for a combatable and safe working area with plenty of space • Set the computer up so that you can easily read the text on the screen • Try to use a document holder • Make sure you have enough legroom at your desk or chosen working area The Trust will however take responsibility for equipment that it provides to a remote user and will ensure that it is in full working order when handed over to the user. The Trust will also maintain the equipment while the remote user is under the employment of Mid Essex Hospital Services NHS Trust. 10 Appendix 3 - IT Security Guidelines Security is everybody’s responsibility The following document provides a quick guide to IT Security. Please ensure that you have read the full Information Security Policies located on the Trust’s Intranet and Internet sites. In case of an IT Security Incident – whether actual or suspected, in the first instance please contact the IT Helpdesk on 01245 515000 (x5000) or email support@meht.nhs.uk and infosec@meht.nhs.uk • • • • • • • • • • • • • • • • • Never disclose your password to anyone. Password sharing so other individuals can access your account may lead to disciplinary action. Remember, you are responsible for network activity under your username. Always refuse to use another employee’s username/password if you are asked. Ensure your password is not guessable (at least 8 characters using a combination of letters, numbers and symbols). Never write down your password. When you leave your PC ensure that you ‘lock’ it by pressing Control, Alt and Delete (on the keyboard) and select ‘Lock Computer’. You should not wait for the screen saver to start for the PC to lock. Remember, you are responsible for network activity under your username. Only IT Hardware purchased, supplied and supported by the Trust can be connected to the network, e.g. you must not connect your home laptop to the network or your home PDA to the network. Do not save confidential files to the C: drive of any PC or unencrypted laptop. It could be accessed by another party and will not be backed up, and if lost cannot be recovered. Do not save confidential/sensitive files on a USB Memory stick, unless it is a Trust supplied encrypted memory stick. Password protection in Microsoft Applications is not secure and can easily be ‘hacked’. Do not rely on this to protect documents. Do not send confidential data on portable media unless it is encrypted and you have management approval. For further advice on portable and removable storage please see 08064 Encryption Policy on the Intranet. Do not leave laptops, Blackberry’s or PDA’s unattended in a public place and ensure that they are secure in transit e.g. locked in the boot of your car and not on view. Do not leave the mobile device unattended in the car – take it with you. The security or all portable hardware is the responsibility of the user. Only emails sent from nhs.net to nhs.net should be used for patient identifiable information, as they are automatically encrypted and can be guaranteed safe and secure. No sensitive or business confidential material should be sent to a public Internet address like firstname.lastname@somewhere.com Do not email work documents to your home email address. Do not produce/edit work documents on your home PC. If you do have a remote working requirement you should use a Trust supplied and encrypted work laptop and a secure access token. Please speak to your line manager in the first instance and refer to 09021 Remote Working Policy. Do not connect any non approved USB equipment to any Trust PC or laptop. You are bound by the “NHS Confidentiality Code of Practice”. Ensure you do nothing which would breach this guideline. E.g. displaying confidential/sensitive material in a public place. Examples – on a train, in a coffee shop etc. The Trust’s management maintains the right to monitor and review Internet use, e‐mail communications sent or received and data stored by users as necessary. 11 Appendix 4 ‐ VPN Instructions for users.doc First you will have to turn off your Internet proxy settings to enable your internet explorer to work from your home connection ‐ 1. Under "Tools" in the browser tool bar select "Internet Options". 2. In the "Internet Options" window that pops up, click the "Connections" tab at the top. 3. Click "LAN Settings" near the bottom of the "Connections" section. 4. If the "Proxy server" checkbox is marked with a check, click it to deselect/uncheck it. 5. See image below: (Image shown is from Internet Explorer 6) 6. Click "Ok" to close the "Local Area Network (LAN) Settings" window. Click "Ok" to close the "Internet Options" window. Now connecting to our network. Double click on the Cisco AnyConnect icon that's on the desktop. 12 Click 'select' as per the screenshot below – Just after this insert your Smart Card into your Smart Card reader. You will be prompted to enter your Smart Card pin number. Click ‘Yes’ to any prompts that you may get. You should then find that you are connected to the network as if you were in the office. 13