Directorate / Programme Data Dissemination Services Project Data Sharing Audits Status Approved Director Terry Hill Version 1.0 Owner Rob Shaw Version issue date 02/11/2015 HSCIC Post Audit Review of Data Sharing Activities: Dr Foster Intelligence Copyright ©2015 Health and Social Care Information Centre Data Sharing Post Audit Report: Dr Foster Intelligence v1.0 Approved 02/11/2015 Contents Executive Summary 3 1 4 2 About this Document 1.1 Purpose 4 1.2 Audience 4 1.3 Outstanding Audit Areas 4 1.4 Conclusion 4 Status Page 2 of 6 5 Copyright ©2015 Health and Social Care Information Centre Data Sharing Post Audit Report: Dr Foster Intelligence v1.0 Approved 02/11/2015 Executive Summary This document records the formal closure of the data sharing audit of Dr Foster Intelligence on 17th and 18th March 2015 against the requirements of the Health and Social Care Information Centre (HSCIC) data sharing agreements covering Hospital Episode Statistics (HES) data, Office of National Statistics (ONS) mortality data and Summary Hospital-Level Mortality Indicator (SHMI) data. In total, three minor nonconformities and two observations were closed during the follow-up visit on 28th September 2015: No acknowledgment of deleted / destroyed data has been provided to HSCIC as required by the data sharing agreement (minor). The mandated HSCIC copyright statement specified in the data sharing agreements was not cited on publications and websites (minor). The information recorded in the asset register is not linked to specific data sharing agreements (minor). There is no evidence of the implemented controls and justifications as to the perceived risk reduction following the application of a control especially with respect to reductions in impact (observation). Version control of written documents needs to be improved (observation). Furthermore, all of the areas raised but not covered during the initial audit have been assessed and were found to be satisfactorily controlled. In summary, it is the Audit Team’s opinion that at the current time and based on evidence presented during the audit, there is minimal risk of inappropriate exposure and / or access to data provided by HSCIC to Dr Foster Intelligence under the terms and conditions of the data sharing agreements signed by both parties. Page 3 of 6 Copyright ©2015 Health and Social Care Information Centre Data Sharing Post Audit Report: Dr Foster Intelligence v1.0 Approved 02/11/2015 1 About this Document 1.1 Purpose This report provides an evaluation of the changes made by Dr Foster Intelligence following the Data Sharing Audit in March 2015 against the requirements of the Health and Social Care Information Centre (HSCIC) data sharing agreement covering Hospital Episode Statistics (HES) data, Office of National Statistics (ONS) mortality data and Summary Hospital-Level Mortality Indicator (SHMI) data. This evaluation was conducted on 28th September 2015. 1.2 Audience This document has been written for the Director of Data Dissemination Services. Copies will be made available to the HSCIC Community of Audit Practitioners, Assurance and Risk Committee and the Information Assurance and Cyber Security Committee for governance purposes. The report will be published in a public forum. 1.3 Outstanding Audit Areas The following areas were identified as requiring follow-up at the audit in March 2015: CCTV access / retention records; process for cleansing access cards before they are re-used; monitoring of customer access and usage logs; malware / firewall policy; authentication mechanism associated with the display of Imperial College held data; deletion of data with respect to retained backup tapes; review of risks by the Information Security Management Forum; and audit planning. All were found to be in place and fit for purpose. No new nonconformities were raised as a result. Dr Foster Intelligence also presented its ISO 27001:2013 certificate, dated 9th September 2015. 1.4 Conclusion All of the nonconformities and observations raised by the Audit Team are now deemed closed. Page 4 of 6 Copyright ©2015 Health and Social Care Information Centre Data Sharing Post Audit Report: Dr Foster Intelligence v1.0 Approved 02/11/2015 2 Status Table 1 identifies status minor nonconformities and observations raised as part of the audit. Ref Comments Designation Update Status 1 No acknowledgment of deleted / destroyed data has been provided to HSCIC as required by the data sharing agreement Minor Example of three completed data destruction notes and various covering emails to HSCIC were presented to the Audit Team. Closed 2 The mandated HSCIC copyright statement specified in the data sharing agreements was not cited on publications and websites Minor The current tool was viewed by the Audit Team and the HSCIC copyright statement was visible both on the webbrowser and in the pdf reports generated by the tool. Closed An entry has been added to a Project Manager’s checklist to ensure that the required copyright statements are included as required. 3 The information recorded in the asset register is not linked to specific data sharing agreements Page 5 of 6 Minor The content of the asset register has been expanded since the original visit and now included fields associated with each data sharing agreement. Closed Copyright ©2015 Health and Social Care Information Centre Data Sharing Post Audit Report: Dr Foster Intelligence v1.0 Approved 02/11/2015 Ref Comments Designation Update Status 4 Provide evidence of the implemented controls and justifications as to the perceived risk reduction following the application of a control especially with respect to reductions in impact Obs The risk methodology has evolved and has been subject to review by the external ISO 27001 auditor. Risks are reviewed by the ISMF, which sits approximately every six weeks. As such, Dr Foster Intelligence is comfortable with the approach taken and the level of scrutiny given within the organisation, though the Audit Team still expressed reservation with the extensive use of reducing impact following the application of controls. HSCIC expects that evolution of the process and analysis will be examined as part of the regular ISO 27001 surveillance visits. Closed A number of internal audits have been undertaken with respect to current processes/procedures and further ones are planned. These internal audits should ensure that practices are fit for purpose and are delivering necessary controls. 5 Version control of written documents needs to be improved Obs This continues to be improved, though a single error was noted. Closed Table 1: Nonconformities and Observations Page 6 of 6 Copyright ©2015 Health and Social Care Information Centre
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