Directorate / Programme Infrastructure Security Status Approved Owner James Wood Version 4.1 Author Daryl Kayes Version issue date 21/04/2015 Logical Connection Architecture About this Document This document is used to provide a coherent, comprehensive and concise description of the security controls which will protect access to N3 and personal data. It is completed by all non NHS organisations that require a connection to the N3 network as part of the Information Governance Statement of Compliance (IGSoC) process, or that have an existing connection to N3 which they wish to modify (including changes to the local network). Applicants should read the introductory notes on page 4 before completing the form as it contains important information regarding the IGSoC process, N3 connectivity and responsibilities of the applying organisation. Copyright ©2015 Health and Social Care Information Centre Document Management Revision History Version 3.1 Date 19/10/2011 Summary of Changes Published on the CFH website 4.0 30/03/2015 Revised and updated in line with the HSCIC standards. 4.1 21/04/2015 Minor formatting updates. Reviewers This document must be reviewed by the following people: Reviewer name Title / Responsibility Operation Security Team Deputy Lead Matt Wyatt Operational Security Team Adam Goodwin Date Version 26/02/2015 4.0 26/02/2015 4.0 Approved by This document must be approved by the following people: Name Signature James Wood James Wood Title Head of Infrastructure Security Date Version 21/04/2015 4.1 Glossary of Terms Term / Abbreviation What it stands for Document Control: The controlled copy of this document is maintained in the HSCIC corporate network. Any copies of this document held outside of that area, in whatever format (e.g. paper, email attachment), are considered to have passed out of control and should be checked for currency and validity. Page 2 of 22 Copyright ©2015 Health and Social Care Information Centre Contents Introduction 4 Scope 4 Objective 4 Intended Audience 4 Limitations of Connection 5 Responsibility for Data Security 5 Logical Connection Architecture 6 1 Background 6 2 Location of N3 Connection 6 3 Person Identifiable Data (PID) 8 4 LAN Segregation 12 5 Access Control 13 6 Remote Access 14 7 Wireless Networks 17 8 Access to/from External Networks (Including Internet) 18 9 Patching Regime 19 10 Network Topology 20 11 Security Policy 20 Appendix A - Network Topology 21 Appendix B – Security Policy 22 Page 3 of 22 Copyright ©2015 Health and Social Care Information Centre Introduction The Logical Connection Architecture (LCA) document is used by non-NHS organisations to provide a coherent, comprehensive, concise and accurate description of the network security controls which will protect access to the NHS National Network (N3) and Person Identifiable Data (PID). It forms part of the Health and Social Care Information Centre (HSCIC) IGSoC process that non-NHS organisations wishing to connect to N3 are required to complete. N3 faces numerous threats to security as a result of improperly protected partner networks or connections to uncontrolled external networks such as the internet. These threats are continually evolving in both strength and frequency; ongoing vigilance against these threats and the maintenance of strict security standards are essential to the continuing success of N3. The LCA and the IGSoC process as a whole are intended to enforce a minimum standard of security for organisations wishing to connect to N3. The HSCIC maintains a range of Good Practice Guidelines, providing advice on specific areas of Information Security and its Governance. Copies can be obtained from the HSCIC Infrastructure Security Team website: http://systems.hscic.gov.uk/infogov/security/infrasec/gpg Scope Non-NHS organisations who wish to directly connect to N3 are required to complete and submit an LCA that accounts for each connection they’re applying for. A revised version of this document is required whenever additional connectivity is required, or where it is proposed to change the local infrastructure that is connected to N3. Note that a revised document is not required where organisations simply require an increase in N3 bandwidth, unless a new circuit is to be installed. Objective The objective of the LCA is to establish the agreed architecture and associated security controls of the local network that the non-NHS organisation wishes to connect to N3. The HSCIC will review the LCA to determine whether it meets the network security requirements for connection to N3. Once approved, the agreed architecture and security around it will form the baseline for any audit by the HSCIC or its designated auditors. Changes to the agreed architecture and/or security around it need to be notified to the HSCIC IGSoC team, by means of an updated LCA document e-mailed to exeter.helpdesk@hscic.gov.uk Intended Audience This document assumes a general familiarity with the fundamentals of Information Security, including the use of Firewalls, Encryption, Access Control, Wired and Wireless networks. Persons completing the LCA should have a good understanding of these principles and of issues of confidentiality surrounding Person Identifiable Data (PID). If the applying organisation does not have suitable in house expertise they should consider using the services of a specialist consultancy. Note that the HSCIC are not able to provide consultancy, advice or guidance in these areas, and are only able to assist with queries relating to the overall process. Page 4 of 22 Copyright ©2015 Health and Social Care Information Centre Limitations of Connection Connection to N3 is typically provided through a dedicated line connected to a router at the applying organisation’s site. Connection and router are both supplied and managed by the N3 Service Provider (N3SP). Note that this router is not under the applying organisations control and will be provided with a fully open inbound Access Control List. It is therefore strongly recommended that that applying organisation purchases their own compliant firewall to be used at the N3 ingress point as the HSCIC cannot guarantee the type or volume of traffic originating from N3 that may be destined for the organisation. N3 connections for non-NHS organisations provide connectivity to a restricted number of sites and services on the N3 network only. They do NOT provide general Internet access. Organisations wishing to access the Internet must do so via their own Internet gateway. Responsibility for Data Security N3 is a private Wide Area Network (WAN). Connection is strictly limited to authorised endpoints. All organisations wishing to connect to N3 are responsible for ensuring that their connectivity does not compromise its security. Information is unencrypted when transmitted within N3, except for encryption applied by specific applications. Confidentiality of sensitive information in transit over N3 is not assured, and Department of Health (DH) guidelines stipulate that PID must be kept confidential. It is therefore the data owners’ responsibility to ensure appropriate controls are in place to secure data in transit, which in general terms means applying appropriate encryption. Approval under the IGSoC process (including the LCA) in no way obviates the responsibility of NHS organisations, wishing to exchange data with the applying non-NHS organisation, from performing due diligence prior to allowing end-to-end connectivity with the applying organisation. Page 5 of 22 Copyright ©2015 Health and Social Care Information Centre Logical Connection Architecture For completion by the applicant. All questions MUST be answered or marked N/A. Organisation ODS (formerly NACS) Code Version Date Author Description 1 Background 1.1 Reason for LCA submission Notes Reasons for requiring an LCA may be either: A new connection at a location not previously connected. A change to an existing connection where there has been a change to the infrastructure or security associated with it. Type of N3 access being requested Response Or 1.2 Notes Type of N3 access may be either: Response A physical connection Or N3 Remote Access token 1.3 Description of products or services being delivered Notes Response This should include details of What products or services will be delivered by the applying organisation How they will be delivered How the N3 connection will be used to support this delivery Other NHS systems used Whether the systems used are locally hosted or remotely accessed It is best to explain using general terms for those unfamiliar with your organisation, products and services. Page 6 of 22 Copyright ©2015 Health and Social Care Information Centre 2 Location of N3 Connection 2.1 Enter full postal address of the location where the N3 link(s) will be installed. Include the full name, telephone number and e-mail address of the applicant’s principle contact for completion of the IGSoC Process. Notes Response Please state The full postal address of the location where the N3 link(s) will be installed The key contact within the organisation: o name o telephone number o email address Who owns and manages the location It must be clear if the location is owned / managed by the applying organisation or another organisation. It is acceptable for the connection to be hosted by a third party but this must be made clear and the third party must not be permitted physical or logical access to the N3 circuit being purchased. ___ For N3 Remote Access tokens the response should be the main site where the tokens will be used or the head office of the organisation. Confirm that there will be one N3 Remote Access token per user (not device). Page 7 of 22 Copyright ©2015 Health and Social Care Information Centre 3 Person Identifiable Data (PID) PID is defined as any data that can identify an individual because of the way in which the information has been collated, the context in which it is or may be used, or as a result of other information held. This term represents a combination of Patient Identifiable Data and Personal Data (Data Protection Act 1998). Examples (not exhaustive) include name, address, date of birth, age, occupation, place of residence, NHS number, specific medical conditions, etc. 3.1 State whether PID is to be digitally viewed, stored, processed or transmitted by the organisation. Notes Response (Yes/No plus brief explanation) Viewed: Please answer Yes or No to each along with a brief explanation for each. If ANY response is Yes, the additional questions in this section MUST be answered. Viewed means the viewing of PID in human readable form either on screen or in printed form. Stored: Processed: Stored means the holding of PID in any form of storage mechanism, even if only temporarily. Transmitted: Processed means the manipulation of PID in order to extract, modify, or delete information contained within it or to change its format in order to present it in an alternative form. Transmitted means the sending of PID between two or more devices. Note: this includes transfer of PID on backup tapes and other removable media. Page 8 of 22 Copyright ©2015 Health and Social Care Information Centre 3.2 State the level of encryption employed to maintain confidentiality whilst PID is in transit, and (if applicable) stored at the applicant’s site. Notes Response You must provide details of the encryption standard used for PID transmitted/viewed over N3 and stored at the applicant’s site (if applicable). Include the type and strength of the encryption algorithm (with any applicable key size), for example AES 256, Triple DES (168 bit), etc. It may be best to identify all flows of PID and provide encryption details for each type of transfer and storage. Consider: PID viewed/transmitted over N3 PID viewed/transmitted over the internet PID stored on desktops, laptops, tablets, etc. PID stored on servers and databases PID stored on removable storage and backups PID transferred to paper or other media If encryption is determined by a system out of your control, this must be identified in the explanation. NHS encryption guidance for the protection of sensitive information can be found at NHS Encryption Guidance HSCIC Approved Cryptographic Algorithms Where other methods are employed in secure areas, you must provide as much detail as possible to show they provide at least equivalent levels of protection to an encryption solution. Note: It is not sufficient to say you will comply with any required standards. You must specify the type and strength of encryption to be used. If this is dependent on the encryption used by the NHS organisation being supported then you should establish the requirements with them and include them here. Page 9 of 22 Copyright ©2015 Health and Social Care Information Centre Describe how PID (if displayed on the applying organisation’s PCs or in the organisation’s premises) will be secured from oversight by unauthorised parties. Notes Response 3.3 This section covers prevention of PID being viewed by those not authorised to see it. It includes prevention of ‘Shoulder Surfing’ and unauthorised physical access to equipment capable of displaying PID. Consider the physical access controls, such as: Staff access controls to buildings Staff access controls to rooms with PID Visitor access to buildings and rooms Patient access to buildings and rooms Position of computer screens Use of privacy screens Controls at locations used for remote access Identify specific references to the policy statements in the organisation’s policy documents which support the response. For example: - document <doc>, page z, section x.y <title> 3.4 Describe the policy and controls in place to prevent the unnecessary printing of PID. Notes Response The HSCIC recognises that there may be occasions when PID is required to be printed, such as letters to patients. You should briefly outline your organisation’s policy on printing PID and include this in your overall security policy. Also Identify specific references to the policy statements in the organisation’s policy documents. For example: - document <doc>, page z, section x.y <title> Describe any technical controls in place to enforce the policy Explain how they are implemented Page 10 of 22 Copyright ©2015 Health and Social Care Information Centre 3.5 Describe the policy and controls in place to prevent the unnecessary copying of PID to removable media. Notes Response The HSCIC recognises that there may be occasions when PID is required to be transferred to removable media, such as back-ups of data. You should briefly outline your organisation’s policy on copying of PID and include this in your overall security policy. Also Identify specific references to the policy statements in the organisation’s policy documents. For example: - document <doc>, page z, section x.y <title> Describe any technical controls in place to enforce the policy Explain how they are implemented Note that Department of Health Policy dictates that any PID stored on removable media MUST be encrypted. The implementation of this encryption must be described in Section 3.2. 3.6 Will PID be Viewed, Stored, Processed or Transmitted outside England? Notes Response (Yes/No) Current restrictions on the viewing, transport and storage of PID mean that it is not ordinarily permitted for connecting organisations to allow viewing or storage of PID outside of England. This includes remote viewing via services such as RDP by support staff. Organisations answering YES to this question MUST complete the ‘Offshore Support Requirements’ and ‘Information Security Management System (ISMS) template’ documents, available from the HSCIC website: The HSCIC IGSoC Offshore policy documents If you are required to complete these documents, your N3 connection will NOT be approved until you have done so, and they have been reviewed and assessed by the HSCIC, regardless of the outcome of your LCA submission. Page 11 of 22 Copyright ©2015 Health and Social Care Information Centre 4 LAN Segregation 4.1 Describe the method by which the local network that will be connected to N3 is to be protected from N3 and segregated from any wider (Corporate) network. Notes Response The applying organisation must describe the method of segregation used to restrict user and device access to N3 / HSCIC digital services to those authorised devices or users that are authorised to access them. It is the applying organisation’s responsibility to protect their network from unwanted traffic from N3. The HSCIC does not provide any assurance as to the volume or nature of traffic originating from or within N3. The HSCIC recommends that the applying organisation have a suitably configured firewall in place that is at least ITSEC E3 or Common Criteria EAL4 compliant. This firewall MUST be used solely for the applicant’s N3 connection. Common Criteria compliant devices can be found here: http://www.commoncriteriaportal.org/products/ ITSEC certified products can be found here: http://www.cesg.gov.uk/finda/Pages/ CCITSECResults.aspx Where a patch release of a vendor’s compliant product has not yet been approved it is acceptable to use the most recent version of that product pending its compliance status being confirmed. There are a number of methods available for ensuring adequate segregation between the N3connected LAN and the wider corporate environment including the use of Firewalls, VLANS or complete physical separation. In considering their approach to segregation applicants should also consider the physical security controls required to restrict access to N3 connected systems in conjunction with the requirements in sections 3 and 6. ___ For N3 Remote Access tokens the response can be limited to a compliant local firewall, such as the software firewall on a laptop/desktop. Page 12 of 22 Copyright ©2015 Health and Social Care Information Centre 5 Access Control Describe the method of access control within the applicant’s network that will prevent unauthorised users accessing N3. In all cases a user must be required to undergo local authentication before gaining access to local and remote services (including N3). Notes Response 5.1 All access to N3 services must be restricted to authorised persons only. The applicant must describe how this authorisation will be enforced and how users will be authenticated on the N3 connected network prior to gaining access to N3 services. This can include the use of Active Directory or other directory services, membership of user groups or use of software or hardware tokens among other means. A step by step analysis may be best to identify each type of access and authentication available. For each stage, please describe The method of authentication How the access is controlled In all cases, explicit confirmation is required from the organisation that all users are required to undergo local authentication prior to being able to access local or remote services (including N3 access). Note that where local user accounts are used, the organisation must confirm that these accounts are issued on a per-individual basis, are not shared and do not have administrative privileges. 5.2 Describe the policy for adding, managing and removing access control Notes Response You should briefly outline your organisation’s policy for adding, managing and removing access control and include this in your overall security policy. The policy may include measures for Designated approvers to grant access Process for staff joining and leaving Periodic audits of access requirements Identify specific references to the policy statements in the organisation’s policy documents which support the response. For example: - document <doc>, page z, section x.y <title> Page 13 of 22 Copyright ©2015 Health and Social Care Information Centre 6 Remote Access 6.1 Will any remote access users have access to N3 or to the N3-connected LAN? (Yes/No) (If the Response is YES, applicants MUST complete the additional questions in this section) Notes Response (Yes/No) Remote access is any access to N3 or to the N3connected LAN from outside of the organisation’s network environment. This includes access via the internet by home workers or remote support staff, or other external gateways. For N3 Remote Access tokens respond with Yes 6.2 Will remote access to N3 be available only to the applying organisation’s staff, using secure hardware provided by the organisation? (Yes/No) Notes Response (Yes/No) Only authorised employees of the applying organisation are permitted to access N3 services or systems via the organisation’s connection to N3. Access by third parties is strictly prohibited. Any remote access to N3 must be from secure systems. "Secure" means that this authorised hardware conforms to the applicant's security policy with regards to remote working, is under the applicant's control, and is in the opinion of the applicant fit for this purpose. PID MUST NOT be cached or stored on any remote machine, unless it is on an encrypted drive or to an encrypted container. 6.3 Will remote access users outside of England have access to N3? (Yes/No) Notes Response (Yes/No) Current restrictions on access to N3 mean that it is not ordinarily permitted for connecting organisation to allow access from outside of England. This includes remote viewing via services such as RDP by support staff. Organisations answering YES to this question MUST complete the ‘Offshore Support Requirements’ and ‘Information Security Management System (ISMS) template’ documents available from the HSCIC website The HSCIC IGSoC Offshore policy documents If you are required to complete these documents your N3 connection will NOT be approved until you have done so, and they have been reviewed and approved by the HSCIC, regardless of the outcome of your LCA submission. Page 14 of 22 Copyright ©2015 Health and Social Care Information Centre 6.4 Describe the method of remote connection employed, with the level of encryption. Notes Response Applicants MUST specify the type of VPN used for remote access to the organisation’s network. For example IPSEC, SSL, etc. Include the type and strength of the encryption algorithm (with any applicable key size), for example AES 256, Triple DES (168 bit), etc. Detailed encryption guidance can be found at - HSCIC Approved Cryptographic Algorithms If some remote users will be unable to gain access to N3 then describe The additional controls which will prevent access to N3 How they’re implemented ___ For N3 Remote Access tokens the response can simply re-iterate that N3 Remote Access tokens with two factor authentication are being used. The encryption is controlled by N3SP. 6.5 Describe how the remote access VPN is terminated within the organisation’s network. Notes Response The remote access VPN session MUST be fully terminated within the organisation’s network before a connection to N3 is established. The purpose is to mitigate the risk of deliberate or inadvertent bridging of internet (or any other external network) traffic to N3. ___ For N3 Remote Access tokens the response can simply re-iterate that N3 Remote Access tokens with two factor authentication are being used. The VPN session is terminated on the N3SP VPN servers. Page 15 of 22 Copyright ©2015 Health and Social Care Information Centre 6.6 Describe the remote access two-factor authentication mechanism. The HSCIC insists that remote access users MUST undergo two-factor authentication within the organisation’s network before accessing N3. Notes Response Specify the two factors used to authenticate remote users before onwardly connecting to N3 services. Note, the different user authentication factors are: Something they know Something they possess Something that is part of them (biometric) ___ For N3 Remote Access tokens the response can simply re-iterate that N3 Remote Access tokens with two factor authentication are being used. Page 16 of 22 Copyright ©2015 Health and Social Care Information Centre 7 Wireless Networks 7.1 Are there any wireless LANs at the site requiring access to N3 or to the N3-connected LAN? (Yes/No) (If the Response is YES applicants MUST complete the additional questions in this section. Where the response is NO then consideration should be given to section 7.3) Notes Response (Yes/No) If the N3-connected LAN is physically separated from the corporate network hosting the wireless access points, and has no wireless access points or wireless capable equipment connected to it, then you may answer NO to this question. In all other cases where wireless networks are present then the answer must be YES 7.2 State the Wireless encryption and authentication standards employed. Notes Response The HSCIC minimum standard is WPA2-AES (Wi-Fi Protected Access with AES) for encryption, and 802.1X with one of the standard Extensible Authentication Protocol (EAP) types currently available for authentication. Applicants must state The type and strength of encryption - For example, WPA2-AES 256 The authentication standard - For example, EAP-TLS How the key is distributed - For example, RADIUS or Pre-Shared Key It is not sufficient to state that you will adhere to any required standards. You should establish what those standards are and detail them. 7.3 What additional controls will allow or prevent wireless users from accessing N3? Notes Response Provide details of any additional technical controls which will allow or prevent wireless users from accessing N3. Describe The additional controls How they’re implemented Identify specific references to the policy statements in the organisation’s policy documents which support the response. For example: - document <doc>, page z, section x.y <title> Page 17 of 22 Copyright ©2015 Health and Social Care Information Centre 8 Access to/from External Networks (Including Internet) 8.1 Does the proposed network architecture include any external network gateways, including internet? (Yes/No) (If the Response is YES applicants MUST complete the additional questions in this section) Notes Response (Yes/No) The purpose of this section is to mitigate the risk of the inadvertent bridging of Internet (or any other external network) traffic to N3. Even if access to the external network is outbound only, the Response must be YES 8.2 Give details of how the applicant proposes to secure each external network gateway (including Internet) of the local network that will be connected to N3. Notes Response Any external network gateway (including Internet) MUST be protected as a minimum by a suitably configured ITSEC E3 / Common Criteria EAL4 compliant firewall. This CANNOT be the same physical firewall that is protecting the organisation’s network from N3. Common Criteria compliant devices can be found here: http://www.commoncriteriaportal.org/products/ ITSEC certified products can be found here: http://www.cesg.gov.uk/finda/Pages/ CCITSECResults.aspx ___ For N3 Remote Access tokens this question is limited to the internet gateway and should be answered the same as Section 4.1. 8.3 Give details of any inbound access from any external network gateway (including Internet) Notes Response Where inbound firewall rules need to be configured to allow access from an external network (particularly Internet) to the N3-connected LAN, details must be given, including Type of allowed traffic Allowed protocols and ports IP address restrictions How traffic is terminated The HSCIC design rules dictate that any Internet facing solution (e.g. web service) must not have a shared N3/Internet front end. This means that back end resources may be shared, but access from N3 and the Internet gateway must be via separate physical paths and separate front end servers. The applying organisation should include reference to these design rules within their response and describe how they are adhered to. Page 18 of 22 Copyright ©2015 Health and Social Care Information Centre 9 Patching Regime – for devices within the organisation’s network that will interact with N3 9.1 Please specify the proposed regularity and method of checking and updating anti-virus and anti-spyware definition files and engines. Notes Response The HSCIC requires all devices connected to N3 have anti-virus software deployed and configured to ensure regular scans are carried out and alerts are raised when suspicious files are found regardless of the underlying operating system. The HSCIC recommend that appropriate mechanisms be in place to ensure virus definition updates are installed as soon as available or, if necessary, after stability testing by authorised personnel. Consider: All devices in scope – servers and clients Windows, Apple, Linux, Unix, etc. The source of the updates The delivery method – push or pull Applicants should be aware that access to N3 does not provide access to the internet. Applicants planning to use automated update services via the internet should ensure that they have a separate, properly protected gateway available to facilitate this. 9.2 Please specify the proposed method and regularity of checking and applying security and other patches to these devices. Notes Response The HSCIC recommend that appropriate mechanisms be in place to ensure security updates, operating system and application patches install as soon as available or, if necessary, after stability testing by authorised personnel. It is particularly essential that the patching of any server used to store PID is up to date. Consider: All devices in scope – servers and clients Windows, Apple, Linux, Unix, etc. The source of the updates The delivery method – push or pull Applicants should be aware that access to N3 does not provide access to the internet. Applicants planning to use automated update services via the internet should ensure that they have a separate, properly protected, gateway available to facilitate this. Page 19 of 22 Copyright ©2015 Health and Social Care Information Centre 10 Network Topology 10.1 A diagram of the local network that is proposed to be connected to N3 must be included. Notes Response A network topology is a diagram describing the physical and logical relationship of nodes in a Please attached your topology diagram in network. Appendix A. The following items must be present on the diagram to determine the pattern of data flow across the network and links connecting one or more networks: N3 Cloud N3SP Router Internal N3 connected LAN Servers or computers holding, accessing or displaying PID Interface to any Corporate LAN Internet Cloud (If applicable) Partner Networks (if applicable) Interface to aggregated network (applicable to aggregators only) All firewalls Wireless Access Points Applicants should note we do not need large detailed technical diagrams. For the purposes of the LCA we are only interested in those parts of the organisation connected to N3 and their interfaces to any wider corporate network and other external networks. An example diagram is included in Appendix A to indicate the level of detail required. 11 Security Policy Notes A copy of the organisation’s Information Security Policy should be included. Formatting can be preserved by inserting or pasting as a file so that it appears as an embedded icon. Response Please attach a copy of your organizations IT Security Policy in Appendix B. If file size restrictions mean this is not possible it may be submitted as a separate document, clearly named and associated with the LCA submission. This policy should reflect the Responses given in the LCA submission and address all policies and procedures that the organisation and its staff follow with regards to all aspects of IT and Information Security. The policy should be mandated by the applying organisation’s senior management. Please note that the documents will be used only for the IGSoC process by those in the HSCIC with an operational need to know, as explained by the IGSoC Privacy Policy. Page 20 of 22 Copyright ©2015 Health and Social Care Information Centre Appendix A - Network Topology Example topology diagram for a physical N3 connection: Example topology diagram for N3 Remote Access tokens: Page 21 of 22 Copyright ©2015 Health and Social Care Information Centre Appendix B – Security Policy Page 22 of 22 Copyright ©2015 Health and Social Care Information Centre