1 |
Information for patients/clients on the proposed uses of information about them |
No information provided, or limited to simple posters and leaflets in waiting rooms, etc |
An active information campaign is in place to promote patient understanding of NHS information requirements |
An active information campaign is supported by comprehensive arrangements for patients with special/different needs |
2 |
Staff code of conduct in respect of confidentiality |
No code exists, or staff not generally aware of it |
Code of conduct exists and all staff aware of it |
Code regularly reviewed and updated as required |
3 |
Staff induction procedures |
No mention of confidentiality and security requirements in induction for most staff |
Basic requirements outlined as part of induction process |
Comprehensive awareness raising exercise undertaken and comprehension checked |
4 |
Confidentiality and security training needs assessment |
Training needs not assessed systematically for most staff |
Training needs only considered as a consequence of organisational or systems changes |
Systematic assessment of staff training needs and evaluation of training that has occurred |
5 |
Training provision (confidentiality and security) |
No training available to most staff |
Training opportunities broadcast with take up left to line management discretion |
In house training provided for staff; for example, comparable to health and safety training provision |
6 |
Staff contracts |
No reference to confidentiality requirements in staff contracts |
Confidentiality requirements included in contracts for some staff |
Contractual requirements included in all staff contracts |
7 |
Contracts placed with other organisations |
No confidentiality requirements included |
Basic agreements of undertaking are signed by contractors |
Formal contractual arrangements exist with all contractors and support organisations |
8 |
Reviewing information flows containing patient identifiable information |
Information flows have not been comprehensively mapped |
Information flows have been mapped and senior management has been informed |
Procedures are in place for the regular review of information flows and the justification of purposes |
9 |
Internal information/data “ownership” established |
Information/data “ownership” has not been established for all information/data sets |
“Ownership” established for all information/data sets and register established |
All “owners” justifying purposes and agreeing staff access restrictions with the guardian |
10 |
Safe haven procedures in place to safeguard information flowing to and from the organisation |
No safe haven procedures used |
Safe haven procedures used for some information flows |
Safe haven procedures in place for all patient identifiable information |
11 |
Protocols governing the sharing of patient identifiable information with other organisations locally agreed |
No locally agreed protocols in place |
Partner organisations clearly identified and information requirements understood |
Agreed protocols in place to govern the sharing and use of confidential information |
12 |
Security policy document |
No security policy available |
Security policy exists but not reviewed within last 12 months |
Security policy reviewed annually and reissued if appropriate |
13 |
Security responsibilities |
No information security officer appointed, or existing officer is not appropriately trained |
An appropriately trained information security officer is in post |
Responsibility for information security identified in various staff roles, coordinated by the security officer |
14 |
Risk assessment and management |
No programme of information risk management exists |
A risk management programme is under way and reports are available |
A formal programme exists with regular reviews, outcome reports, and recommendations provided for senior management |
15 |
Security incidents |
No incident control or investigation procedures exist |
The security officer handles incidents as they arise |
Procedures are documented and accessible to staff to ensure incidents reported and investigated promptly |
16 |
Security monitoring |
No monitoring or reporting of security effectiveness or incidents takes place |
Basic reporting of major incidents or problem areas only |
There are regular reports made to senior management on the effectiveness of information security |
17 |
User responsibilities |
No guidance issued to staff for password management |
Users encouraged to change passwords regularly but this is at their discretion |
Password changes are enforced on a regular basis |
18 |
Controlling access to confidential patient information |
Staff vigilance, and/or an “honour” system control access. Some physical controls, lockable rooms, etc, may exist |
Access for many staff controlled by “all or nothing” systems. Staff groups requiring access identified and agreed with the guardian |
All staff have defined and documented access rights agreed by the guardian. Access is controlled, monitored and audited |