Information Security Policy 15 Supplier Relationships Lead Manager Head of Operations Responsible Director Director eHealth Approved By Information Governance Steering Group Date Approved December 2019 Review Date December 2021 Version No. N1.0 THIS DOCUMENT IS CURRENT AS AN ON LINE DOCUMENT Consultation and Distribution Record Contributing Authors IT Compliance Manager Consultation Process / Stakeholders Information Governance Steering Group Distribution All Staff Change Record Date Author 23 Feb 2017 20 Oct 2017 8 Feb 2018 24 July 2018 11 Mar 2109 1 Oct 2019 S Harris S Harris S Harris S Harris S Harris S Harris Change First created Updated Formatting Formatting Updated for NISD Updated for NISD Version No V0.1 V0.2 V0.3 V0.4 V0.5 V N1.0 THIS DOCUMENT IS CURRENT AS AN ON LINE DOCUMENT Contents 1 INTRODUCTION ............................................................................................................. 4 2 OBJECTIVES .................................................................................................................... 4 3 SCOPE ............................................................................................................................... 4 4 LOCATION ....................................................................................................................... 4 5 SUPPLIER RELATIONSHIPS : INFORMATION SECURITY IN SUPPLIER RELATIONSHIPS ..................................................................................................................... 4 6 5.1 Information security policy for supplier relationships ................................................ 5 5.2 Addressing security within supplier agreements ......................................................... 5 5.3 Information and communications technology supplier chain ..................................... 6 SUPPLIER RELATIONSHIPS : SUPPLIER SERVICE DELIVERY MANAGEMENT 6 6.1 Monitoring and review of supplier services ................................................................ 6 6.2 Managing changes to supplier services ....................................................................... 6 7 CONTRACTS AND CONFIDENTIALITY AGREEMENTS ......................................... 6 8 INFORMATION SECURITY POLICY FRAMEWORK (2018) CONTROL ................. 6 9 REFERENCES .................................................................................................................. 6 9.1 GG&C Standard/policy/guidance ............................................................................... 6 9.2 NHSS Standard/policy/guidance ................................................................................. 7 THIS DOCUMENT IS CURRENT AS AN ON LINE DOCUMENT 1 INTRODUCTION This Policy supports the implementation of the sub-control objectives relating to Supplier relationships : information security in supplier relationships and Supplier relationships : supplier service delivery management in the NHS Scotland Information Security Policy Framework (2018) as part of the Network Information Systems Regulations (2018). The Policy also supports the Supply Chain Guidance of the Scottish Government’s Public Sector Action Plan (PSAP). 2 OBJECTIVES The objective of this policy are To ensure protection of the organisation’s assets that is accessible by suppliers To maintain an agreed level of security and service delivery in line with supplier agreements 3 SCOPE This policy relates to all suppliers requiring access to GGC information assets or suppliers hosting GGC information assets.. 4 LOCATION Where the term staff is used it shall be taken to apply to full or part time employees, contractors, volunteers or third parties that work on behalf of NHS GG&C. 5 SUPPLIER RELATIONSHIPS : INFORMATION SECURITY IN SUPPLIER RELATIONSHIPS The two sub controls in this policy are designed to reduce the impact and likelihood of the following threats, as defined in the Information Security Risk Management Policy. Threat Number T1 T3 T7 T11 T13 T16 T17 T18 T19 T20 NHSGGC Commonly Identified Threats Deliberate unauthorised access or misuse by known outsiders (including supplier) Theft or wilful damage by outsiders of data or equipment Theft of data via Unauthorised Access by Hacker/ Malicious External Actor Breach of legislation, Privacy/Regulation issue Inadequate or absent audit trail Environmental failure like Loss of Electricity System or network software failure Supplier withdraws a key product in the solution or end of life Key supplier becomes insolvent Supply chain cyber attack THIS DOCUMENT IS CURRENT AS AN ON LINE DOCUMENT 5.1 Information security policy for supplier relationships GGC shall ensure that a full assessment of the potential security risks with using an outsourced provider or a supplier is carried out. This must include identification of what needs to be protected and why. GGC shall ensure that the risks associated with outsourcing are managed through the imposition of suitable controls, comprising a combination of legal, physical, technical, procedural and managerial controls. GGC shall ensure that there is an identified service and ehealth owner of each supplier GGC should consider the following when selecting an outsourced provider or a supplier: 5.2 Supplier’s reputation and history. Quality of services provided to other customers. Financial stability of the company and commercial record. Retention rates of the company’s employees. Quality assurance and security management standards currently followed by the company (e.g. certified compliance with ISO 9001 and ISO/IEC 27001, Cyber Essentials/Cyber Essentials +). Addressing security within supplier agreements Relevant information security requirements must be established with each supplier that may access, process, store, communicate or provide ICT infrastructure components for, the organisation’s information. Requirements must include specifying what data is held by or accessed by the supplier when data is held by the supplier the process of sanitization of storage media that is applied during contract and will be applied at contract termination the supplier to GGC has subcontracted any services access method who within the supplier will be managing he cyber risks for the delivery of the contract the basic staff training and awareness raising around cyber risk carried out by the supplier Cyber assurance accreditation eg Cyber Essentials, ISO27001 or equivalent These requirements must be specified in the Supplier Contract. THIS DOCUMENT IS CURRENT AS AN ON LINE DOCUMENT 5.3 Information and communications technology supplier chain Access to the Organisations’ assets shall include assurance procedures and must be in compliance with the GGC Third Party Access Policy. The contracted supplier must manage all accesses provided to it. Data can only be transferred by explicit agreement from GGC using a defined secure method. 6 SUPPLIER RELATIONSHIPS : SUPPLIER SERVICE DELIVERY MANAGEMENT 6.1 Monitoring and review of supplier services As a minimum as part of annual contract review each supplier will go through a reassessment of its access procedures and of the GGC accounts it has been allocated. 6.2 Managing changes to supplier services Suppliers must notify GGC of proposed changes to the provision of services and their impact on existing information security policies, procedures and controls. Risk Assessment must be carried out for the proposed new service. 7 CONTRACTS AND CONFIDENTIALITY AGREEMENTS The requirements of information security in supplier relationships, and supplier service delivery management must be included in supplier contract. 8 INFORMATION SECURITY POLICY FRAMEWORK (2018) CONTROL 36) Supplier relationships: supplier service delivery management Objective To maintain an agreed level of security and service delivery in line with supplier agreements. Sub-control (ISO 27001-CAF-ICO Ref. no.) Detail Organisations shall regularly monitor, review and audit supplier service delivery and associated security a) Monitoring and review of supplier services (ISO: provisions. A.15.2.1) (CAF: A4.a) b) Managing changes to supplier services (ISO: A.15.2.2) (CAF: A4.a) 9 9.1 Changes to the provision of services by suppliers, including maintaining and improving existing information security policies, procedures and controls, shall be managed, taking account of the criticality of business information, systems and processes involved and re-assessment of risks. REFERENCES GG&C Standard/policy/guidance THIS DOCUMENT IS CURRENT AS AN ON LINE DOCUMENT 9.2 NHSS Standard/policy/guidance Contract and supplier security: example policy (NHS Digital 2017) https://www.digital.nhs.uk/media/31609/Contract-and-Supplier-Security-ExamplePolicy/doc/Contract_and_Supplier_Security_-_Example_Policy_230517 THIS DOCUMENT IS CURRENT AS AN ON LINE DOCUMENT