Category Archives: Cyber Security

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CyberSecurity

NHS CyberSecurity lessons makes you WannaCry?

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NHS CyberSecurity lessons arising from the worldwide ransomware attack that occurred on the 14th of May is already prompting much debate for the NHS, much of which focuses on the failure of affected organisations to ensure adequate levels of investment on IT systems to mitigate the risk of this event.

The ransomware exploited a known issue with Windows XP, for which a patch had been issued earlier in the year. The biggest news headlines here in the UK concerned the impact this exploit had on the NHS, with a great many organisations appearing to have been caught out by the Windows XP vulnerability.

As is the case when the public sector suffers an adverse event, the call goes out for lessons to be learned, usually with an assumption that these are all new, but inevitably there will be those lessons that have already been learned, but just not put into practice.

Windows XP Legacy

Those that have been around NHS IT for a while will remember the last elected labour government’s implementation of the National Programme for IT (NPfIT) tasked to deliver a standard national NHS IT system. Regardless of what is thought about the success or failure of the programme, it did leave a lasting legacy long after it was cancelled.

Not least with those NHS organisations that had progressed to implementing NPfIT systems and solutions and in doing so, had tied themselves to technology standards defined by the program that could not be easily changed. In the commentary on following the ransomware event it has been highlighted that the legacy of NPfIT Windows XP implementations was the reason so many organisations were adversely affected.

In September 2011, the government announced the acceleration of the dismantling of the National Programme for IT*. Whilst at the time the impact of this decision was not significant, because NPfIT technology was still current and thus supported by providers, it should have perhaps been better recognised that this state was not sustainable in the long term. Especially for Windows XP, because the next version Windows 7 was already available (released Oct 2009) and being adopted across health in non NPfIT legacy environment.

Things finally came to a head for XP when Microsoft announced that it would be ending its patching and maintenance support for the platform in April 2014. Thankfully in acknowledging that there was still a dependency on this technology platform, the government took steps and signed an extra-ordinary deal with Microsoft** that secured continued support for XP across the UK public sector for another 12 months.

Critically, a condition of this agreement, was that any public sector body wishing to take advantage of this extended support arrangement, had to commit to development of a “robust plan” to move off Windows XP, Office 2003 and Exchange 2003 within the year.

Roll forward to 2015 and the next government decision on the matter was just as they had advised, that they would be closing down this extra-ordinary support arrangement ***, and is has to be said for good reason, on the basis that it was felt that continued central government funding of this deal was not consistent with the need to encourage organisations to urgently upgrade or migrate.

The question here however has to be, “was it reasonable to expect trusts to be able to find the funds for wholesale upgrade of unsupported operating systems in such a short time frame (this being equivalent to a single financial year)?

To further compound matters at the time, NHS organisations had been shielded from the full cost of wholesale systems upgrade throughout the time of NPfIT. A national licencing deal with major suppliers like Microsoft, removed the need for software costs to be met locally by NHS organisations ****.

Straight Out the PRINCE2 Textbook

It is accepted best practice that when a pre-existing programme or project is to be closed down, an impact assessment of the consequences should be undertaken. Not least so that the risk can be properly understood and adequate mitigations planned. If nothing else there is nearly always a financial consequence to closing programmes and projects and this is a very good example of one.

The NPfIT programme along with central licensing deals transformed the model of IT investment within the NHS for a decade. Switching these off and closing down the national deals the programme created was inevitably going to have consequences for participating organisations.

Some will argue that the implementation of the extra-ordinary support arrangements for legacy software was an act of risk mitigation. However, was it reasonable in 2014 to expect affected organisations to plan and implement an upgrade or migration of XP in a single financial year, without any additional financial support being provided?

The NHS had already been managing financial pressures for a good number of years before the decision to end XP support was taken. Certainly long enough for organisations to flag this to be a risk of significance, that without additional and extra-ordinary financial support, there was no way they were going to be able to take the steps needed to address the situation accordingly.

In summing up, it is clear that although the NPfIT national licencing deals themselves had been closed down some years earlier in 2010, the impact of this decision on local investment plans going forward, was never properly qualified or understood, and that further opportunities to address this in 2015 were missed and all the way up to 14th of May this year, 7 years on!

Shout to the Top

As an acknowledged risk, the XP issue should have been raised on the Information Governance (IG) Risk Register and flagged as a serious concern to the Senior Information Risk Owner (who by now and as a result of improvements to NHS IG standards) was a role assigned to a senior management representative on the board of the organisation.

Additionally, given the dependence on technology in meeting clinical outcomes, the risk should have also featured on the Clinical Risk Register, which would have flagged it up to the Chief Medical Officer, also a member of the board.

Just a cursory glance at most organisations annual reports and board papers will expose the fact that IT barely gets a mention, certainly any reviewer will be hard pressed to find any mention of XP specifically in the dealings of the boards in any one of the organisations affected, at any stage of the timeframe of this being an ongoing concern.

This therefore exposes a potentially bigger issue in that information technology investment and dependence is not a matter adequately represented at the board level, then or now.

This clearly is a matter of concern, given as the recent event exposed the criticality of the services dependence on the information technology in the performance of its primary function, delivery of treatment and care.

Frustratingly some of the commentary on the event included the phrase “IT is not the primary business of the NHS”, suggesting therefore it is not the NHS responsibility to ensure the reliability and safety of the tools it uses to deliver care, this is clearly nonsense.

It is perhaps partly this attitude that has excluded proper IT representation at the board level? Given the next stage of investment required and proposed by “paperless at the point of care” and “integrated digital health and care plans” and additional dependence on technology this will deliver, it is now time for IT to have a seat at the top table.

Information Governance STILL Maturing?

The NHS has an excellent online tool and system of guidance and assessment addressing information systems, security and good practice management standards (NHS Information Governance Toolkit). The tool is well established having been around and in use for more than 15 years with NHS organisations status reports openly published and available for review.

In April 2014 in a blog article entitled Patient Record Access – A Perspective 2 Years On I set out the more fundamental data protection and information governance challenges that the NHS needed to address to maximise the benefits potential of digital engagement. Not long after the original 2015 target for achieving patient record access was deferred to 2018 and linked to the “paperless at point of care” requirement.

Then and still today, technology innovation is widely acknowledged and accepted to be the primary method by which transformation of current health and social care models, and opportunities to deliver service effectiveness improvements and efficiencies at a substantial scale (£20bn+) going forward is to be achieved.

NHS 2020 digital roadmaps across the country outline ambitious plans addressing technology integration and innovations requirements needed to achieving “paperless at the point of care” and “integrated digital health and care record”. The levels of investment are significant, but then so is the benefits potential. For the first time in the history of health and social care, the technology to support transformation to a more pro-active and well-being orientated model is possible.

Success however will be heavily dependent on the digital engagement of patients and their carer’s and how effectively this is achieved. In this respect information governance will be a key deliverable and factor in how much and how quickly the benefits of patient digital engagement are secured and maintained going forward. Patients will need ongoing assurance that digital engagement is safe, and that their right to privacy is being properly protected.

Of the 33 major NHS organisations (community and acute hospitals) identified to have been affected, all have reported a “satisfactory” rating in the information governance self-assessments completed in March this year, in particular for the following requirements:

Information Security Assurance
14-301 A formal information security risk assessment and management programme for key Information Assets has been documented, implemented and reviewed
14-307 An effectively supported Senior Information Risk Owner takes ownership of the organisation’s information risk policy and information risk management strategy
14-309 Business continuity plans are up to date and tested for all critical information assets (data processing facilities, communications services and data) and service – specific measures are in place
14-310 Procedures are in place to prevent information processing being interrupted or disrupted through equipment failure, environmental hazard or human error
14-311 Information Assets with computer components are capable of the rapid detection, isolation and removal of malicious code and unauthorised mobile code
14-313 Policy and procedures are in place to ensure that Information Communication Technology (ICT) networks operate securely

 

The recent CyberSecurity event serves to remind the NHS, that despite all the good work done in the development of the information security and governance standards and despite all the resources that have been provided to help organisations get good at this, there is so much more to be done, and this too is going to require additional investment at the local organisational level.

Links to Articles

* Gov Announces Dismantling of NHS National Programme for IT

** Government signs £5.5m Microsoft deal to extend Windows XP support

*** The UK government stopped funding Windows XP support to try and force people to upgrade

**** NHS loses massive Microsoft licensing rebate


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Digital Patient Engagement

Digital Patient Engagement or Participation?

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By 2018 patients should have access to their medical records online. By 2020 this should have evolved into a digital patient engagement solution as health and social care achieves “paperless at the point of care” working practices. But is it just about engagement, or should we be preparing more for active participation and ownership of health concerns and issues.

Digital Transformation of Service Delivery

Most concern I have had shared with me is that the NHS 2020 Digital proposals are still not making adequate plans to exploit the opportunity provided by Internet of Things (IoT), Wearables and Assisted Living technologies at the earliest.

The current focus is being given to resolving internal data integration / flow issues which do need resolving. Acknowledging that there are clinical and information governance concerns as well as care benefits needing to be addressed. But whilst these in the main deliver service quality and improved workflow for people already in the system. Their support for delivery of a transformed and more sustainable service delivery model is limited.

Transformation of the service delivery model and improvement in future sustainability of any significance for health and social care, is largely dependent on the digital patient engagement (or better – participation) and capabilities delivered by technology innovation incorporated to support pro-active participation. The opportunity and benefits potential is significant, when the service delivery model evolves from one that is largely re-active and after the fact, to an alternative and more sustainable pro-active and well-being orientated model.

These benefits are only going to be enhanced by any ability to integrate and exploit technology innovations and automation delivered by IoT, wearables, assisted living and health and care / well-being monitoring innovations and solutions. Adoption of these technologies will increase as they become more capable and with this increase the range of proactive information and data supporting opportunities for further cost saving interventions and / or preventions will also increase.

Data Governance and Management

Consequently the long-term objective of any digital health and care engagement solution, should be about providing the means to help us to live well, and if we are unfortunate enough to have one or more long term chronic conditions or disability, to be empowered to manage our situation as much and as well as we can. It is never though just about us and individuals, we pretty much all care for or are cared by somebody else. So we should be able to gain access to others information too.

All of the above inevitably leads to an explosion of information becoming available, and of the most personal and sensitive kind! Consent, data ownership / management quickly become the most important considerations in any engagement solutions design that needs to be open to accommodate future technology innovations delivering on the pro-active health and well-being opportunity.

It is, however, widely acknowledged that local developments and deployments are not being guided by core common engagement and consent model or universal data flow / integration standards, of concern consequently, the progress to a better model of health and care continues to evolve with massive variations in capability delivered differently across regions.

Conclusion

Until the need for core common standards on data consent, governance and interoperability are fully addressed, then the participation of patients and citizens with the digital solutions will likely remain inhibited, subsequently the opportunity to achieve the £20b of universal benefits from a transformed service delivery model by 2020 will very likely remain an elusive and much less assured target that it could otherwise be.

References and Links

Article produced in response to news item Health wearables firm Fitbit holds talks with NHS published by Digital Health


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Applaud Maude, for suggesting boardroom focus on IT security

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Minister for the Cabinet Office, Francis Maude, has urged businesses to make IT security a boardroom issue.The minister warned that security was no longer just an issue for IT departments alone.

Is it still the case that modern day businesses still need encouragement to make IT security a top priority? Is data protection legislation in itself failing to impress upon organisations, the need to adoption of a more business orientated approach to IT Security investment and management?

perhaps it is that many can be forgiven for thinking that IT security in this modern age is not being addressed properly within the business community, especially give recent high profile issues experienced by some of the top technology providers in the world. If well known technology powerhouses are unable to implement security measures to prohibit cyber attacks on their business then a concern for what hope there is for the rest of the business world is possibly well founded?

It is possible however that a somewhat skewed perspective on matters concerning IT security is created by the penchant for only bad news to be reported in the more popular periodicals and on-line news services. With a little digging around it is possible to find some more positive news.

Investment in IT Security is improving

IT Security InvestmentAccording to a recent news and update bulletin posted on the ISO/IEC 27001 adoption rates of this international standard on IT security continue to improve on an ongoing upward trend basis, albeit in varying degrees in different countries around the world.

Here in the UK the trend is very positive, especially in comparison to that of our fellow members in the EU. According to the executive summary of the The ISO Survey of Management System Standard Certifications – 2013 the status of ISO/IEC 27001 gives the requirements for information security management systems, was:

At the end of December 2013, at least 22 293 ISO/IEC 27001 certificates, a growth of 14 % (+2 673), had been issued in 105 countries and economies, two more than in the previous year.

The top three countries for the total number of certificates issued were Japan, India and the United Kingdom, while the top three for growth in the number of certificates in 2013 were Italy, India and the UK.

Likely that in part, this growth is being driven by the emergence of new computing models, in particular transitioning to Cloud and outsourcing. However any increase in the application of recognised standards during what have been extremely taxing economic times must be something to be welcomed.

A More Positive Picture

ISO LogoSo with due respect t the very challenging economic times that we here in the UK are still yet to fully materialise, the news that in the last two years UK business investment in ISO accredited IT security standards has continued to increase, sufficient to maintain a UK top three ranking is very positive news indeed.

It should be pointed out that the difference in number of 27001 certificates awarded between the top ranking country Japan (7084), to that of India (1931) and the UK (1923) is quite significant, with Japanese businesses achieving more that twice that of the UK and India together in 2013.

So even whilst the UK is doing better than most, perhaps the answer to the questions posed above is “yes” and on both counts?

What else do you think could and should be done to increase focus and investment on improving the state of IT security where this is needed?

Article Links

Move security from IT up to boardroom, says Francis Maude.

World distribution of ISO27001 certifications displayed graphically


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Communications Data Bill published

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The UK Government has just published is proposed Communications Data Bill, a new regulatory framework refreshing the old Regulation of Investigatory Powers Act (RIPA) to ensure law enforcement agencies maintain the ability to tackle crime and terrorism as criminals use modern technology and new ways of communicating to plan and commit crime.

The main point of concern already being raised is that the powers will ensure that all data communication sent via mobile phones, emails and other Internet based means will be recorded for all citizens, and stored for a period of time.

Whilst tracking and storage of all communications might actually be necessary to identify those elements of society undertaking or planning to undertake criminal or terrorist activity, the safeguards that are to be in place to ensure the privacy of the law abiding citizen is protected, are not detailed enough to close this debate.

The publication website offers the following summary on the proposed bill, that new legislation will help ensure police can stay a step ahead of the criminals. But it will not:

  • enable unfettered access by the police to data about everyone’s communications
  • provide the police and others with powers to intercept and read your emails, phone calls or check your contacts lists
  • create a single government database containing your emails and phone calls to which the police and agencies can get unlimited and unregulated access
  • weaken current safeguards or checks in place to protect communications data
  • allow local authorities greater powers

The site goes on to provide commentary from a number of senior law enforcement professionals under the heading “protecting the public”, including:

  • Association of Chief Police Officers crime head Jon Murphy chief constable of Merseyside Police
  • Child Exploitation & Online Protection Chief Executive Peter Davies
  • SOCA Director General Trevor Pearce

One cannot help that an additional heading entitled “Protecting the Publics Privacy” with statement from the likes of the Information Commissioner and perhaps one or two privacy pressure groups on the basis of their being briefed and satisfied that privacy controls being implemented in support of the bill would do a lot to head of concern.

Whilst there can be little doubt of the need to ensure investigation and intelligence capabilities need to be able to keep pace with technology developments, however the lack of up-front assurance aimed at addressing what should be reasonably anticipated, specifically concerns on privacy, is somewhat perplexing?

Article Link

UK Gov Communications Data Bill publication


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