NSTS Service Management Team Security Advice on Exchanging Person-Identifiable Data via e-mail When sending data about a single person (patient/client/service user) or group of persons to a colleague by e-mail, the data must be properly protected if the data is detailed enough that the individual(s) could be identified from it (i.e. if it is person-identifiable data). Sending person-identifiable data (PID) by e-mail thus requires the data to be encrypted sufficiently that makes it extremely difficult for it to be read if intercepted, either deliberately or accidentally. What is person-identifiable data (PID)? PID includes such data as: name and date of birth; name and address; full name (though not forename or surname alone, usually); full address. Since we know that the NHS Number can uniquely identify an individual, this should be considered as PID in this context. In the context of resolving data queries about persons (or patients) on NSTS, it is likely that any communication about such data queries will necessarily include PID. What methods of protection are acceptable? NHS CFH Information Governance guidelines confirm that it is acceptable to do the following: 1. To exchange PID within an NHSmail (previously called Contact) e-mail. This is the standard means of exchange that we are working towards as it requires no additional protection since the e-mails and their attachments are encrypted. Note that both sender and recipient must use NHSmail accounts for the protection to work. 2. Protect the PID within a file encrypted using the Advanced Encryption Standard (AES). There are several software tools that can do this usually using 128- or 256-bit keys (256-bit is preferred, especially over the Internet). Acceptable AES encryption tools include: Utimaco’s SafeGuard® Private Crypto; WinZip® (v9 and above), but not the standard Zip 2.0 encryption which is weak; PGP® (Pretty Good Privacy). Notes: Both the Utimaco and PGP products can produce a ‘self-decrypting archive’ (SDA) file which has a .exe extension. This is an executable file which does not require the person receiving it to have the software (Utimaco or PGP). However, in tests we found that SDA files were often stopped by Fire Walls even if we changed the .exe extension. All three tools produce encrypted files which can be decrypted by the recipient with the appropriate software tool (i.e. both sender and recipient need to have the same tool installed). We found that these encrypted files were less likely to be stopped by Fire Walls. 116095859 1 of 2 June 2006 What methods of protection are not acceptable? NHS CFH Information Governance guidelines suggest that it is not acceptable to: 3. Exchange PID ‘in the clear’ in an open e-mail, even over the NHS network, except within NHSmail (previously called Contact – see above). 4. Protect PID simply within a password-protected file (e.g. a Word document or an Excel workbook). Such protection is weak and can be circumvented relatively easily using software tools. 5. Protect PID within a WinZip file using the standard Zip 2.0 encryption. This too is known to be relatively weak, but has been the standard encryption method in WinZip for some time. Further information For further information on the about encryption tools, visit: Utimaco’s SafeGuard® Private Crypto: http://www.utimaco.com/privatecrypto WinZip®: http://www.winzip.com PGP®: http://www.pgp.com Recommended protection methods for typical PID e-mail exchanges TO: NHS user Non-NHS user1 Atos Help Desk2 NHSCR DST4 NHAIS support analysts NSTS SMT Atos support3 NHSmail or AES AES AES N/A N/A NHSmail or AES AES NHSmail or AES AES AES AES NHSmail or AES AES N/A N/A N/A N/A N/A N/A N/A NHSmail or AES NHSmail or AES NHSmail or AES AES AES N/A NHSmail NHSmail NHSmail AES AES N/A NHSmail NHSmail NHSmail AES AES N/A NHSmail NHSmail NHSmail AES AES N/A AES AES AES AES FROM: NHS user Non-NHS user1 Atos Help Desk2 NHSCR DST4 NHAIS support analysts NSTS SMT Atos support3 AES Protection Methods: NHSmail = preferred method: both sender and recipient(s) have NHSmail addresses (which always end in “nhs.net”) – e.g.fred.bloggs@nhs.net is NHSmail but fred.bloggs@org.nhs.uk is not. AES = encrypted in a file using AES 256-bit key encryption with one of the acceptable encryption tools – one or both of sender and recipient do not have NHSmail address. 1 Assumes non-NHS user has not got NHSmail account. Atos Help Desk does not need to receive PID – but, if they were to do so, then AES encryption would be necessary. Atos Origin do not have NHSmail e-mail, but can use WinZip v9 and above for AES-256 encryption. 4 NHSCR DST prefers NHSmail but can use Utimaco SafeGuard® PrivateCrypto for AES 256 encryption 2 3 116095859 2 of 2 June 2006