3...more like a 20 yr marathon First text message 1992 Internet early 1990sPay-as-you-go (which created mass consumer market) mid-1990sWireless LAN late 1990sGPRS/3G early 2000s (i-mode long before i-phone)‘Smart phone’ (PC, colour screen) early 2000sBoard IT teams know all about this...and generally good at managing it (e.g. WLANs)
4....bumps in roadVendors have tried to get a wireless ‘big bang’ (e.g. WAP phones, MMS and often fell flat):Lack of bandwidthLack of battery power in devicesScreen technology not advancedMobile applications still in infancyShort-range wireless initially slow catch on consumer marketHigh production costs for some components
5What is different now..? Key components for ‘tipping point’ have come together
6eHealth leads face a lot of background noise........
9R.O.I from existing tools All of this demand just at time when we are supposed to be squeezing value out of existing IT investment (mainly fixed cable)Far less money for .. buying more kit, putting in ever more complex support models for wireless
10Getting to the nub of the problem Boards now need to deal with implications of this wireless application ‘tipping point’ and derive benefits while managing riskTake into account consumer pressure/convenience (‘pester power’) of staff but all decisions must be in interests of business even if it is not always popularNeed to cut through all this ‘background noise’ and work out what really are the information risks, and how to work out how to deal with them
11Forget much of what you have heard and start on a clean sheet........ There is no such thing as 100% security‘several pinches of salt’ for whatever vendors claim about devices/service (“It meets xyz International standard”)Do not consider ITSOs, IG Leads or Caldicott Guardians as people as people who say ‘yes’ or ‘no’Do not think you must buy in security expertise every timeDo not consider wireless as necessarily any more or less ‘secure’Do not think confidentiality requirement drives all decisionsDo not think good security = encryption products
13Go for Information risk management approach NHS staff, clinical and managerial are already really good at ‘risk management’ every dayIdentifying risk (“this could happen to patient x given what I know about y”)Explaining risk to others (“you cannot move this patient because..”)Treating, avoiding, retaining risk (“we can treat x condition, but z condition can only be contained.”
14Looking at information risks in the round How often have you heard about privacy risks?“Hey, you cant do that, we have personal data to protect at all costs...”“not possible, because the product doesn’t do encryption”“someone might eavesdrop on that data”
15Remember: Information Assurance is C.I.A Confidentiality AND Integrity AND AvailabilityNHS does have important confidentiality requirements (legal and moral)But often this can dominate all discussion to the point where availability and integrity risks hardly get a look in......
16Information risks in round: Availability But how seldom you hear:“the need for availability of data to clinicians outweighs the very small risk of information loss”“I am worried that the chosen wireless solution could mean there are more service outages”
17Information risks in round: Availability (2) All wireless technologies are by their very nature intermittent (radio, infrared, microwave etc)So a upper most in our minds must always be the ‘availability risk’ (*hence title of this presentation)
18Broken cables rare event: have understanding single points of failure
20Information risks in the round: Integrity How seldom do you hear:“I am worried that mobile devices will lead to duplication of data, or data out of synch”“We seem to be procuring a separate device for each application...the data will be different from desk-tops“we have a pile of devices”
21When should you do an information risk assessment? Organisational level: e.g. whole board, team, processParticular service to be launched (e.g. prior to delivery) especially if critical and/or if there is a high element of ‘unknowns’ relating to securityAs result of a security incident (e.g. privacy breach)
22Who should do information risk assessment? Ideally, someone who is not in the project team and can provide an independent viewBUT, before you think to pick up phone to a consultancy etc there are lots of NHSScotland optionsYour ISOISO from another boardNeed to pool our skills much more internally
23Information risks: whole process Understanding business context (why is the service, which has wireless devices so important)Who might be the ‘owners’ of that serviceWhat are the impacts (worst case scenarios) relating to something going wrong with that service/process
24Information risk assessment DevicesHow they are expected to be usedHow they might be used in unexpected waysRelevant regulatory requirements (e.g. Data Protection)Types of attacker/motivationRisks and vulnerabilities relating to any aspect of the whole process
26Information risk assessment: reporting back to...?
27Who are the information ‘risk owners’? “A Caldicott Guardian is a senior person responsible for protecting the confidentiality of patient and service-user information and enabling appropriate information-sharing.NOT the same as a SIRO (Senior Information Risk Owner) or information asset owner
28Who may need to be in the room? RoleWhy?‘Owner’ proposed serviceThere is no such thing as a an IT project; the technology is there to enable a process/service that must be owned/run by someone elseProject ManagerTo explain exactly how requirements are met and broad risksIndependent Risk AssessorExplain results of risk assessment; and optionsCaldicott Guardian/IGCompliance with DP etc and best practiceeHealth leadIs the service suitable for current architecture, how will it be released into live environment?
29‘Creative tension’ between advisors/enforcers/owners
30Key questions to be posed? Which risks can and should be treated?What residual risk is still left even with treatment?Are the residual risks still too much to bear?Which risks can be avoided (e.g. not doing something)?Which risks can be retained?
31Example: ‘risk retained’ “smart phone, whole disk encryption not possible ...but there is encryption on the application”
32Residual risk....User error could mean sensitive personal data ends up on the un-encrypted part of the device (e.g. My Documents, Camera)*Revised NHSScotland mobile data says this is permissible up to ‘amber’ level.User training awareness only ‘control’ to reduce this residual risk further......
34B.Y.O.D: Fact or fiction? Commonly held assertion Reality? Staff are clamouring for it now...?Staff would prefer not to use different device for each purpose (not necessarily ‘own’ device)Vendors have ‘cracked’ security’ ?OK for services up to ‘amber’ and for . But many other problems relating to personally owned devices….not covered by encryptionCheaper to support BYOD than official devices?Not always; sheer range of variables can add to support costWe could connect our own devices to NHS services via the web?We do not currently have the web-architecture to do this. Few ‘online’ services. Our current remote access work on VPN/tokens/official devices etc
35Current situationNHSmail does allow use own mobile device (via Internet)Some staff use own devices for capturing information (e.g. notes from minutes). Do they ever save it in the right place??Not much else ?
36Emerging situation: move with caution..... What about ‘choose your own device’ C.Y.O.R??takes employee preferences into account but devices still owned and controlled by orgEmployees often complain about having multiple devices We could make a start by reducing the number of ‘official’ devices in workplace.Supporting all the variables relating to people’s own phones can be more expensive than just issuing official ones.
37B.Y.O.DNeed to sort out the ‘identity & access management’ and authentication aspects for remote users in generalLots of products to secure applications; but having an agent installed on a personally-owned device does not = securityNeed to think far more about how we classify information
38So what is role of Scottish Government in all this…?
39Balancing ActRemoving barriers to information sharing and innovation while upholding ministerial priorities and right degree of compliance…………..
41Priorities Information Assurance Strategy (working through it) Good practice guidance (based on risk assessments)Standards (where appropriate)Building communications ISO/IG communitiesBuilding capability (e.g. training, forums)Links with clinical and professional groupsLeading and influencing within NHSScotland governance structuresSignificant incident lessons learned….
42Final thoughts….Tackling some of the emerging security risks around mobile technology space can be scary…. BUT many of the current processes involving paper files and removable digital media are far scarier
44Mobile can help to improve security Secure to any device (not the dreaded fax machine)Patient portal accessed by smart-phone (not paper mail)Remote access to the app (not the CD or memory stick)Addresses/combination codes to homes of the elderly on secure tablet (not held on a paper print out)