Information Governance – Health Care Unit Guidance Requirement PH 314 Does the Health Care Unit control, monitor and audit the use of mobile computing systems to ensure their correct operation and to prevent unauthorised access? Objective: To ensure information security when using mobile computing or teleworking facilities. The security protection required should be commensurate with the risks these ways of working cause. When using mobile computing the risks of working in an unprotected environment should be considered and appropriate protection applied. In the case of teleworking the organisation should consider and apply protection to the teleworking site and ensure that acceptable arrangements are in place for this way of working. Mobile computing and communications Mobile computing is now commonplace in many NHS and other organisations, with users connecting remotely to required information services through laptops, mobile phones, palmtops, etc. Users are also connecting from a variety of locations – home, hotels, other NHS premises, and through wireless and dial-in technologies. Therefore, it is essential that the following are considered within a risk assessment: Theft, loss or damage of equipment. Equipment in transit is at particular risk of being damaged, lost or stolen. This is especially the case of equipment used by mobile workers who are likely to connect from a number and variety of locations. Training, procedures and written guidance should be put in place for users, to cover these threats. Staff members should be informed of some basic good practice steps, to ensure that equipment is not stolen and to ensure that patient confidentiality is maintained at all times. The good practice should include advice about: Locking the machine up overnight, or removal of the hard-drive if the machine cannot be locked away Not leaving the system unattended e.g. on the seat of a car Use of passwords to prevent unauthorised access to information stored on the computer How to ensure password security Reporting lost or stolen equipment promptly Unauthorised access to data. Unauthorised access can be gained in a number of ways. Users may leave equipment or data unattended in a place where it may be seen by unauthorised users. The use of a clear screen and desk policy together with user training can help alleviate this. Second, unauthorised use can be gained through technical means, e.g. from ‘network sniffing’ or through guessed 1 passwords on unattended laptops etc. Encrypted data transfer, strong access controls and user identification and authentication, and secure wireless networks should all be considered to counter technical hacking/cracking. It is recommended that ‘two factor’ authentication is used and token-based, biometric, smartcard, etc controls are implemented. Malicious and unauthorised mobile code. Care must be taken to ensure that all mobile devices have their anti-virus / anti-spyware components regularly updated to protect against these types of attacks. Data backups. Mobile devices such as laptops are best configured so that data processed on them is synchronised to the network at the end of a session. If data is merely saved to a local drive and the device is lost, so is the data. Mobile Working policy. There should be a policy (and written procedures) that covers all aspects of mobile working. If a staff member is able to remotely access the Health Care Unit system, e.g. by dialling in from home, or external location, this must only be allowed if there is a process of strong authentication through token or biometric mechanisms, e.g. fingerprint recognition. The type of authentication in place should be decided on in conjunction with Quantum, the PCT or Shared Services Agency if appropriate. Improvement plans Level 1 The Health Care Unit has a documented procedure on the use of mobile computing systems that contains guidelines for staff on appropriate information security and confidentiality practice. All staff wishing to work in this way must sign up to the procedure. The documented procedure for mobile computing should cover authorisation and approval of staff, authentication procedures to gain access to systems and set out how and by whom access will be monitored and audited, etc. Level 2 The Health Care Unit has implemented the procedure on the use of mobile computing systems. Robust remote access authentication solutions have been provided and users have received appropriate instruction in their use. All staff members working in this way have been appropriately approved and authorised to do so. Level 3 The Health Care Unit ensures the use of mobile computing systems is controlled via its staff approval and authorisation processes. Access to its systems is monitored and audited. Regular audits of mobile computing arrangements should be undertaken to ensure that all users are approved, that assets can be accounted for, that secure remote access is used, and that any sensitive or confidential information is securely 2 transported or stored in the remote location. Appropriate remedial or improvement action should be documented and taken where appropriate. Requirement checklist IS_PH_314_V7_Checklist_09-01-01.doc Key Guidance Document(s): NHS Information Risk Management: Good Practice Guidance The guidance is aimed at those responsible for managing information risk within NHS organisations including the Senior Information Asset Owner (SIRO) and the Information Asset Owners (IAOs). It reflects Government guidelines and is consistent with the Cabinet Office data handling report. System Level Security Policy (SLSP) A template for defining system level security arrangements. This template is relevant to the Good Practice Guide above. It should be read in conjunction with the section specifically addressing security policy. DH: Information Security NHS Code of Practice The code is a guide to the methods and required standards of practice in the management of information security for those who work within or under contract to, or in business partnership with NHS organisations in England. It is based on current legal requirements, relevant standards and professional best practice and replaces HSG 1996/15 – NHS Information Management and Technology Security Manual. BS ISO/IEC 27000 information security standards Note that only NHS Information Governance Toolkit (IGT) administrators may download a copy of the standards for their organisation. The administrator must be logged on to download the standards. NHSnet Remote Access Guidance An NHSIA Security Operating Procedure that defines the security requirements for connecting to NHSnet from a remote host, i.e. strong authentication and access controls. Please note: Security Operating Procedures are no longer updated. This will eventually be superseded by an NHS Connecting for Health Good Practice Guideline: NHS Network users only Exemplar materials: The following are not model publications but examples of real documents in use by organisations that represent elements of good practice. They have been made available for organisations to adapt, use and improve on as they see fit. Nottingham: Mobile Computing Guidelines for users 3 Walton Centre for Neurology and Neurosurgery NHS Trust Remote Working Standard Communications Standard (includes (remote communications) This document is part of a BS7799 certified Information Security management System. The full ISMS, suitably desensitised, is available here. Model Remote Access policy Local User Access Management policy A policy describing the registration and de-registration process for access to computer network (not suitable for specific applications). Useful website: Teleworking guidance for employers & employees General guidance issued (August 2003) by the Department of Trade & Industry. 4