Data Security Standard 1
All staff ensure that personal confidential data is handled, stored and transmitted securely, whether in electronic or paper form.
Personal confidential data is only shared for lawful and appropriate purposes. Staff understand how to strike the balance between sharing and protecting information, and expertise is on hand to help them make sensible judgments. Staff are trained in the relevant pieces of legislation and periodically reminded of the consequences to patients, their employer and to themselves of mishandling personal confidential data.
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Data Security Standard 2
All staff must understand their responsibilities under the Data Security Standards, including their obligation to handle information responsibly and their personal accountability for deliberate or avoidable breaches.
All staff understand what constitutes deliberate, negligent or complacent behavior and the implications for their employment. They are made aware that their usage of IT systems is logged and attributable to them personally. Insecure behaviours are reported without fear of recrimination and procedures which prompt insecure workarounds are reported, with action taken.
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Data Security Standard 3
All staff complete annual security training that is followed by a test, which can be re-taken unlimited times but which must ultimately be passed. Staff are supported by their organisation in understanding data security and in passing the test. The training includes a number of realistic and relevant case studies.
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Data Security Standard 4
Personal confidential data is only accessible to staff who need it for their current role and access is removed as soon as it is no longer required. All access to personal confidential data on IT systems can be attributed to individuals.
The principle of ‘least privilege’ is applied, so that users do not have access to data they have no business need to see. Staff do not accumulate system accesses over time. User privileges are proactively managed so that there is, as far as is practicable, a forensic trail back to a specific user or user group. Where necessary, organisations will look to non-technical means of recording IT usage (such as sign in sheets, CCTV, correlation with other systems, shift rosters).
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Data Security Standard 5
Processes are reviewed at least annually to identify and improve processes which have caused breaches or near misses, or which force staff to use workarounds which compromise data security.
Past security breaches and near misses are recorded and used to inform periodic workshops to identify and manage problem processes. User representation is crucial. This should be a candid look at where high risk behaviors are most commonly seen, followed by actions to address these issues while not making life more painful for users (as pain will often be the root cause of an insecure workaround). If security feels like a hassle, it's not being done properly.
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Data Security Standard 6
Cyber-attacks against services are identified and resisted and NHS Digital Data Security Centre security advice is responded to. Action is taken immediately following a data breach or a near miss, with a report made to senior management within 12 hours of detection.
All staff are trained in how to report an incident, and appreciation is expressed when incidents are reported. Sitting on an incident, rather than reporting it promptly, faces harsh sanctions. Their Board understands that it is ultimately accountable for the impact of security incidents, and bear the responsibility for making staff aware of their responsibilities to report upwards. Basic safeguards are in place to prevent users from unsafe internet use. Anti-virus, anti-spam filters and basic firewall protections are deployed to protect users from basic internet-borne threats.
Read more about NHS Digital Data Security Centre security advice
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Data Security Standard 7
A continuity plan is in place to respond to threats to data security, including significant data breaches or near misses, and it is tested once a year as a minimum, with a report to senior management.
A business continuity exercise is run every year as a minimum, with guidance and templates available from NHS Digital Data Security Centre. Those in key roles will receive dedicated training so as to make judicious use of the available materials, ensuring that planning is modelled around the needs of their own business. There should be a clear focus on enabling senior management to make good decisions, and this requires genuine understanding of the topic, as well as the good use of plain English.
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Data Security Standard 8
No unsupported operating systems, software or internet browsers are used within the IT estate.
Guidance and support is available from NHS Digital Data Security Centre to ensure risk owners understand how to prioritise their vulnerabilities. There is a clear recognition that not all unsupported systems can be upgraded and that financial and other constraints should drive intelligent discussion around priorities. Value for money is of utmost importance, as is the need to understand the risks posed by those systems which cannot be upgraded. It’s about demonstrating that analysis has been done and informed decisions were made.
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Data Security Standard 9
A strategy is in place for protecting IT systems from cyber threats which is based on a proven cyber security framework. This is reviewed at least annually. NHS Digital Data Security Centre assists risk owners in understanding which national frameworks do what, and which components are intended to achieve which outcomes.
Security standard nine expands the organisations cyber security framework to detail the granular technical controls expected to meet mandated MCSS and NIS requirements. For example, DSPT assertion 9.3.6 mandates that the organisation is protecting data in transit (including email) using well configured TLS 1.2 or better.
There is a clear understanding that organisations can tackle the NDG Standards in whichever order they choose, and that the emphasis is on progress from their own starting points.
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Data Security Standard 10
IT suppliers are held accountable via contracts for protecting the personal confidential data they process and meeting the Data Security Standards.
IT suppliers understand their obligations as data processors under the GDPR, and the necessity to educate and inform customers, working with them to combine security and usability in systems. IT suppliers typically service large numbers of similar organisations and as such represent a large proportion of the overall ‘attack surface’. Consequently, their duty to robust risk management is vital and should be built into contracts as a matter of course. It is incumbent on suppliers of all IT systems to ensure their software runs on supported operating systems and is compatible with supported internet browsers and plug-ins.
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