Data security
methods increase the risk of losing data before it can be destroyed, by adding transportation and storage into the equation, and generally demand further layers of verification. You will also find you are not insured against data loss whilst in transit. It might seem an attractive proposition to get the issue ‘off your desk’, but do remember that you are still responsible for the data, regardless of how you have arranged for its destruction. On-site methods enable you to stay close to the process and minimise risk: as you remain responsible, it makes sense to remain involved.
Beware of ‘free recycling’ services. Reputable service providers will recycle redundant equipment, or sell it on for re- use, and any value realised can be offset against the costs of data destruction and disposal. So, in fact, the process can be free, or can even generate a small profit, but each case is different. An unconditionally free service begs several questions: where is your proof of duty of care and due diligence, and how can a free service be properly legislated and contracted?
Have someone senior – the estates or IT manager are two options – in overall charge of the process, who can bring together relevant departments and allocate responsibilities, and who understands the consequences of poor security procedures. That person should always know what is happening with regard to the destruction of sensitive data within the Trust.
Run regular staff training for key people on information security procedures. If necessary, bring in specialists to advise.
Be mindful of data classifications. Aggregation and accumulation of data often occurs at the disposal stage, where assets of all types are merged together, and it is then impossible to distinguish between lower and higher risk types of data. You therefore have to treat all assets as ‘worst case’ scenario.
Ensure that you accurately itemise and identify all equipment marked for removal and its data-bearing status; this should be agreed at the point of sign- over and transfer. Maintain detailed records so that, if required, you can provide full end-to-end traceability. Discrepancies reported after the items have been transferred to a third party can only serve to prove non-compliance.
Do be vigilant about where any redundant equipment is stored before proper disposal. Stacking PCs in a corridor or unlocked storeroom potentially leaves your accountability in tatters; there may well be people for whom extracting a hard disk or other component from an ‘unwanted’ unit will not translate as stealing. Until the data is removed from your old equipment, it
54 Health Estate Journal September 2013
is more valuable than the new boxed equipment; so treat it as such; access should be secure and controlled.
Don’t be tempted to accelerate the process by removing hard disks before the specialists take over, as these must be tied up with serial numbers on the originating asset to fulfil traceability requirements. Any discrepancy not only risks a breach, but will also be recorded, and could potentially act as evidence of non-compliance.
Be extremely diligent when checking third party credentials, and ensure that you are confident about their systems and their personnel. For example, have they carried out Criminal Record Bureau (CRB) checks and Security Clearance (SC) with Counter Terrorist Checks (CTC) on staff, including any agency workers? Remember, you are still liable for their actions.
Have robust service agreements in place, and carry out regular audits; this will demonstrate that you have carried out your due diligence. Remember, a contract does not abrogate your responsibility; however, it may provide you with a course of action against the third party, as long as you can prove that they are in breach of contract.
Facing the future – minimising avoidable breaches There is no doubt that, as we become ever more reliant on electronically held data, the ICO will be kept busy, and more NHS Trusts will be subject to painful sanctions – due to what are often avoidable breaches in data protection. Estates have battled through a great deal of turmoil since Primary Care Trusts were effectively disbanded and reformed as Foundation Trusts or GP-led commissioning consortia. As estates become more fragmented, the issue of data protection and destruction becomes even more challenging. GP practices, for example, might run only a handful of PCs, but the sheer number of sites across a Trust area makes expert involvement with each one impractical. Your disposal partner should be able to provide a secure solution for your remote sites, without compromising on data security or regulatory compliance.
Budgetary cutbacks In 2011 budgetary cutbacks within the NHS led many Trusts to turn to ‘free’ recycling services. This strategy lost much of its gloss when the stark reality of risk versus return became apparent – the aforementioned record fine being a very expensive case in point. As finances become ever tighter, and skilled resources in shorter supply, it is likely that there will be a resurgence of ‘free’ IT asset disposal and data destruction services promising to lift the burden from a weary estates manager’s shoulders.
Do not, however, be fooled by empty
promises: there is a huge variance in the level of service offered and carried out. Currently a breach in this area can result in fines amounting to £1 million, and, as time moves on, these fines will undoubtedly increase as the regulators fight to control this ever-growing problem.
A responsibility for life Remember that the sanctions apply to you, not the third party; data protection is your responsibility for life. You may not always be able to prevent a careless colleague from dropping a memory stick in a taxi, or leaving a PDA in a briefcase on a train – hence the need for encryption. However, what you can do is fulfil your duty of care when your IT equipment reaches the end of its useful life. Dispose of it responsibly, carefully, and transparently, so that you and the thousands of people whose personal details you look after can sleep easier in their beds. In closing, I would like to point out the
ICO is not all ‘teeth’. The regulator is committed to reducing the number of data loss incidents, and offers a ‘Good Practice’ Review Service, where findings do not result in fines, but rather recommendations which you can go on to address. To request such a review, contact the ICO directly; or, for more information, visit
www.ico.gov.uk
Julie Pickersgill
Julie Pickersgill is the operations director for Advanced Digital Dynamics (ADD), which provides secure on-site data destruction and sanitisation services to companies looking to dispose of, and generate additional revenue from, their redundant IT equipment.With considerable experience in the IT sector, Julie Pickersgill and her team specialise in IT asset disposal procedures, including information governance and regulatory compliance.
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