Purpose
This document provides the overarching governance policy for the protection and security of London Borough of Enfield (LBE) data and information.
The policy aims to define the high-level governance of Cyber Security within the council.
Objectives
The main objectives of this policy are to:
- present the management approved requirements, control objectives and principles for Cyber Security
- define the structure and roles within LBE’s Cyber Security structure
- maintain confidence that LBE’s Cyber Security governance meets its corporate and Digital Service (DS) risk appetite
- maintain confidence that LBE’s Cyber Security governance meets the requirements of the law including the data protection regulations, the guidance on government use of cloud services and other compliances as required
Scope
This policy applies to all LBE DS systems, data and information directly or indirectly via third parties.
Policy mandate, approval and maintenance
This policy is approved by the Information and Data Governance Board (IDGB) with delegated authority from the Assurance Board.
The policy will be reviewed regularly and at least annually, and in case of any impacting changes (for example, changes to HMG policy, legislation, regulation, industry standards or LBE DS environment), to ensure it remains current, appropriate and applicable.
Policy
Requirements, control objectives and principles
Risk appetite
LBE has a defined risk management process and this process will follow the LBE risk appetite defined there.
Compliance
LBE is required to comply with law and with certain regulations. This policy mandates compliance with, at a minimum:
- Data Protection Act 2018 and the UK General Data Protection Regulation (GDPR / DPA)
- UK Minimum Cyber Security Standard
- Payment Card Industry Data Security Standard (PCI-DSS)
- Public Sector Network Code of Connection (PSN CoCo)
Roles
Data Owner. The person responsible for the data and compliance in a particular area or system. Generally, this will be a head of service or above. The Data Owner is recorded in the GDPR Workbook for each information asset area.
Senior Information Risk Owner (SIRO).The risk decision maker for the authority.
Chair of Information and Data Governance Board (IDGB). The person who is overall the decision maker on information and data governance matters, delegated by the Assurance Board.
Deputy Chair IDGB. The person responsible for the IDGB in the absence of the Chair.
Data Protection Officer. The independent person providing advice to the authority on compliance, dealing with public complaints and acting as interface to the regulator.
Caldicott Guardians. The person(s) responsible for managing data supplied from NHS.
Security Manager. Person responsible for security management and implementation.
Head of Operational Support Hub (NHS Registration Manager). This role is mandated by some of the NHS sharing agreements.
Head of Legal Services. Responsible for legal advice to the council.
Complaints and Access to Information Manager. Responsible for management of cases (for example,
Data Governance Officer. Responsible for ensuring continuous improvement in data quality.
Corporate Records Manager. The owner of records management across the council, responsible for ensuring records are preserved and destroyed appropriately.
Boards
Information and Data Governance Board
The strategic forum working on behalf of and reporting to the Assurance Board that is empowered to:
- set the strategic direction for and approve applicable information, governance, privacy (including surveillance) and security policies on behalf of the Executive Management Team (EMT) and SIRO
- Assure EMT that risks are being managed effectively in accordance with their risk appetite and policies and controls are adequate and enforced
- receive reports on the IG, privacy and security status of the organisation, including internal audit, and ensure effective investigation of and organisational learning from complaints, incidents and near-misses
- ensure compliance with required standards and legislation, overseeing training and testing and making recommendations to EMT as appropriate
- oversee registration with the ICO, the council’s privacy statement and data sharing protocols
- ensure effective records and data management across the organization
- provide reporting to Assurance Board, Caldicott Guardians, Executive Management Team and Audit Committee
- produce an Annual Report on Information and Data Governance to EMT, Assurance Board and Audit Committee
Security Team responsibilities is to:
- develop IS policy and associated IS implementation strategy and plans, and/or maintain the currency of the policy
- prepare an annual IS assessment for sign off by the EMT/Assurance Board
- develop LBE’s IS work programme and ensure that implementation of IS is co-ordinated across LBE
- ensure that LBE’s approach to IS is communicated to all staff and made available to the public as appropriate
- assist with coordination of activities of staff given IS responsibilities
- receive reports from operational and project teams and monitor LBE’s IS activities to ensure compliance with policy, standards, contracts and law
- ensure that IS training is made available by LBE
- provide a focal point for the resolution and/or discussion of IS issues
- review issues/incidents related to IS
- evaluate information received from security testing and the monitoring and reviewing of information security alerts, events, and incidents, and recommend appropriate actions in response to identified trends, threats, incidents, weaknesses or assessed risks.
- approve methodologies and processes for information security, such as, risk assessment, information classification
- review impact analysis for all new (or significant changes to) systems/processes to ensure that security functionality and data security are not adversely affected
- manage risks and review the adequacy of risk and control measures
- offer support and guidance to the IG, data protection, and DS architectural, design, development, deployment and operational functions within LBE
Applicable standards
There are a number of standards applicable to Cybersecurity and Information Management that the council is required or recommended to adhere to. These are:
- Data Protection Act 2018 (including the UK version of the General Data Protection Regulation created by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019)
- Freedom of Information Act 2000
- Section 224 of Local Government Act 1972
- ISO 15489 International Standard for Record Management
- ISO 27000 family of information security standards
- E-Government Interoperability and Metadata Frameworks
- UK Gov Minimum Cybersecurity standards
- PCI-DSS requirements
- PSN Code of Connection requirements
- Access to Health Record Act 1990
- BS 10008 Evidential weight and legal admissibility of electronically stored information (ESI)
- Common Law Duty of Confidence
- Human Rights Act (Article 8)
- Caldicott Principles
Policy exceptions and violations
Any employee, contractor, partner, service provider or other entity who is requested to undertake an activity which he or she believes is in violation of this policy, must provide a written formal complaint or Exception Request, via his or her manager or other manager or Human Resources Department to the council’s SIRO. Complaints may be dealt with by managers and the HR Department. All Exception Requests must first be approved by the Chair of IGB in conjunction with the SIRO.
Any violation of this policy may result in disciplinary action, up to and including termination of employment. LBE reserves the right to notify the appropriate law enforcement authorities of any unlawful activity and to cooperate in any investigation of such activity. LBE does not consider conduct in violation of this policy to be within an employee’s or partner’s course and scope of employment, or the direct consequence of the discharge of the employee’s or partner’s duties. Accordingly, to the extent permitted by law, LBE reserves the right not to defend or pay any damages awarded against employees or partners that result from violation of this policy.
Policy details
Author – Security
Owner – Information and Data Governance Board
Version – 1.6
Reviewer – Security
Classification – Official
Issue status – Final
Date of first issue – 11.07.2017
Date of latest re-issue – 30.05.2024
Date approved by IGB – 19.05.2024
Date of next review – 30.04.2025