NHS DSPT Managing Risk - A1 Governance

A1.a Board Direction

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Key Point:
Effective management of information security must be led at board level and reflected in your organisation's policies.

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Overview:
To ensure strong governance in data protection, the board must play an active role in overseeing cyber security and information governance (IG) initiatives. Their guidance should influence the organisation's policies, procedures, and projects.

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How to Meet the Requirement:
Ensure that your board or senior management are actively engaged in your cyber security and IG efforts. They are responsible for setting the strategic direction, managing risks, and ensuring security practices are embedded throughout the organisation.

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In health and social care organisations, these board-level activities are primarily led by the Senior Information Risk Owner (SIRO), who ensures that information risks are communicated and managed at board level.

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Evidence to Provide:
To demonstrate compliance, consider submitting:

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• Minutes from relevant board meetings
• Policy documents evidencing board-level oversight
• Risk management reports
• Training records for board members

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Ensure that your documentation clearly references the board's role in overseeing and directing information security and governance.

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Indicators of Good Practice:

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• The board owns and manages policies related to cyber security and IG, and these are communicated effectively across the organisation.
• Regular board meetings are held to discuss data protection and security risks, based on accurate and timely information.
• Board members are accountable for overseeing cyber security and governance, and key roles are clearly defined.

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A1.b Roles and Responsibilities

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Key Point:
Clearly defined roles are essential for the effective management of information security and governance.

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Overview:
To ensure that your organisation's cyber security and IG activities are well-managed, roles and responsibilities must be assigned to a knowledgeable team. These roles should be well-defined and understood across all levels to ensure effective risk communication and management.

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How to Meet the Requirement:
Your organisation must establish and document roles related to cyber security and IG. This could include role descriptions, policies, processes, and appropriate training. All staff should understand their roles, and any resource gaps should be addressed promptly.

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Key Roles to Include:

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• Data Protection Officer (DPO)
• Senior Information Risk Owner (SIRO)
• Caldicott Guardian
• Information Governance Lead
• Cyber Security Lead

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These roles should be supported through contracts, policies, and regular training programmes.

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‍Evidence to Provide:

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• Organisational charts showing roles and responsibilities
• Job descriptions related to cyber security and IG
• Training records for staff in key roles
• Policy documents detailing roles and responsibilities

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Indicators of Good Practice:

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• Regular reviews ensure that key roles and responsibilities remain appropriate for the organisation’s needs.
• Clear processes are in place for managing risks and escalating issues where necessary.

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A1.c Decision-Making

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Key Point:
Senior management must ensure that decisions related to cyber security risks are made appropriately and align with organisational priorities.

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Overview:
Decision-making regarding cyber security and IG risks should involve the appropriate staff, guided by senior management. Risk management decisions should align with your organisation's risk appetite, which defines acceptable and unacceptable levels of risk.

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How to Meet the Requirement:
Risk decisions should involve staff from relevant departments, based on guidance from senior leadership. The risk appetite, approved by the board, should steer decision-making processes. Teams should regularly review risks and adapt to changes in the threat landscape.

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Evidence to Provide:

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• Records of risk management decisions and risk appetite statements
• Risk assessments and reports
• Documentation of change management processes

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Indicators of Good Practice:

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• Staff understand their role in making informed risk decisions based on the organisation’s risk appetite.
• Risk decisions are regularly reviewed to ensure their relevance in response to new threats.
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Ensure your organisation meets the NHS DSPT standards by implementing these best practices. If you need help with cyber security assessments, data protection, or compliance support, Periculo can assist you in navigating the complexities of the DSPT framework. Get in touch with us today to strengthen your organisation’s data security and governance!