Caldicott - Acute Trusts Knowledge base

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Information Security Assurance - Primary Care Trusts
Guidance
Requirement 309
Does the PCT have adequate procedures in place to ensure the availability of
information processing facilities, communications services and data?
Application systems should contain audit trails or activity logs and should
validate data entered or output. Routine procedures should be established for
carrying out an agreed system back-up strategy taking back-up copies of data
and rehearsing their timely restoration, logging events and faults and, where
appropriate, monitoring the equipment environment.
This requirement addresses ISO/IEC 17799 (revised 2005) controls ref 10.5 & 12.2
Information backup
The PCT must ensure that business data and software applications are regularly
backed-up and tested using the system supplier’s recommended technology and
configuration. PCTs must develop a risk based back-up strategy that documents the
procedures to be followed for each relevant information asset. PCTs that use the
services of third parties for data backup should ensure arrangements conform to both
the PCT’s information governance standards and the system supplier’s
recommended practices.
Business data is that entered by users into systems, such as patient data, or other
files created and saved by users. Networked data stored on servers should normally
be backed up on minimum of a daily basis by the system administrator or through
automatic process. Back-up media for the previous week (or as locally agreed)
should be compiled and stored securely at a suitably controlled remote location to the
server from which it was created. Consideration should be given to storing media in
a different building or site to ensure they are protected if the location where the
server is located is damaged causing disruption or unavailability.
Data back-up strategy is a local decision, however, best practice indicates that a
month’s worth of data should be compiled and stored securely at a different location
from the server. The weekly and monthly storage media should be stored to protect
them from unauthorised access and environmental threats such as heat, cold,
magnetic fields and liquids i.e. in a safe that is fire and water resistant. All media
should be clearly marked to show the date the data was captured, the origin of the
data and that it has been tested as reusable.
Instructions for backup should be made available in writing and more than one
person should know how to carry out the backup and restore. A log should be kept of
all start and finish times of backups, failed attempts and remedial actions, who
carried out the backup and who has had access to the media.
Media should only be used for the period recommended by the system supplier.
Media should be regularly tested to ensure data can be successfully recovered within
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the systems full operational configuration. Redundant media should be securely
destroyed using industrial strength tools.
Information that is not networked should be backed up on a daily basis and the
media clearly labelled and stored securely. Computers get stolen and hard drives fail
without warning so it is particularly important that users with data stored on individual
workstations are aware of this. Where possible, data should be stored on networked
servers and no critical data should be stored on stand-alone equipment. Local
workstations should be configured so that the network drive is set as the default for
the storage of data.
Input data validation
Computerised systems can be designed that allow control over what access a user
has, limited fields for entering data and an audit trail showing what information was
entered, by whom and when. Data can also be retrieved following system interrupts
or failures if appropriate backup arrangements have been planned and put in place.
Authentic data input is the direct responsibility of the person inputting the data,
supported by their line manager. All systems will include validation processes at data
input to check in full or in part the acceptability of the data.
Systems should report all data errors together with a helpful reason for the error or
rejection to facilitate its correction.
Error correction should be done at source of input as soon as it is detected. Such
correction is increasingly important as systems are linked and errors can be rapidly
transmitted between systems.
Any loss or corruption of data should be reported immediately to the relevant system
manager. The reporting process should involve invoking incident recording and
management mechanisms.
Control of internal processing
All systems should be designed to include controls that check for information
corruption that has resulted from processing errors or other possibly deliberate acts.
These controls should include:




Functions that are used to implement changes to existing information.
Procedures to prevent programs running in the wrong order or running after the
failure of a prior process.
Programs to recover from failures.
Protection against attacks that use buffer overruns/overflows.
Output data validation
Within systems that process highly structured data, functions can be included to
check the consistency of the data. Where a high level of integrity is essential,
systems should carry out cross-checking between identical records stored in
alternative repositories and/or carry out some form of checksum check to ensure
continued data integrity. Integrity of data transmission can be assured by using
cryptographic techniques but the validity of the data will depend upon checks carried
out at input.
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In some instances it may be necessary to institute manual processes such as batch
testing in order to provide a level of assurance as to the validity of data entering,
processed and output by a system. The responsibilities of the system users with
respect to checking data validity at input and output should be considered and
defined. All user training should emphasise the importance of inputting accurate data.
Improvement plans

Level 1
The PCT should assign responsibilities for developing and implementing
procedures and controls to ensure the integrity and availability of information
processing facilities, communications services and data held.
The documented procedures and controls should be approved by the Board or
delegated sub-group.
 Level 2
The PCT should implement the planned controls and procedures to maintain the
integrity and availability of information processing facilities, communications
services and data held.

Level 3
The PCT should regularly review its documented controls and procedures, and
regularly test its back-up and recovery arrangements.
Requirement checklist
IS_PCT_309_V5_Checklist 07-04-26.doc
Key Guidance Document(s):
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 17799:2005 & BS ISO/IEC 27001: 2005 BS7799-2:2005
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.
NHS Connecting for Health Good Practice Guidelines NHS Network users only
 Destruction of Data and Media containing Sensitive Data
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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.
Walton Centre for Neurology and Neurosurgery NHS Trust
 Physical & Environmental Standard
 Anti-virus and Housekeeping Standard (includes backup)
 Network monitoring Standard
These documents are part of a BS7799 certified Information Security management
System. The full ISMS, suitably desensitised, is available here.
Information Backup
Comprehensive 57 page document covering procedures to back-up data, test that
back-ups work, storage of backed-up data and restoration of lost data
Operator & Fault Logs
10 page example process for recording and maintaining a faults log
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