Change Control Notice
Change Reference: – 0022 20191127
Date: 27th November 2019
Title: – HSCN Obligations -Technical and Security Obligations
Change to:- Obligations Framework 4.3.3 – SMOP11
Dialogue: – Removal of CAS-T reference. The obligation will now read as follows.
‘The HSCN Supplier’s services shall be monitored to ensure that they meet the minimum service level.
HSCN service components detailed within the scope of service shall be subject to a Business Impact Assessment, resulting in defined Recovery Time Objective (RTO), Recovery Point Objective (RPO) and Maximum Tolerable Period of Disruption (MTPD) that support the delivery of service to the minimum service level (evidenced by a commitment that they will comply with the HSCN Minimum Compliance Baseline, or a valid ISO/IEC-22301:2012 certification which includes the requirements of the Obligations Framework within it)
The delivery of services shall be subject to formal review to ensure that they are appropriate in terms of delivery and resourcing (evidenced by a commitment statement as per the ‘Compliance Addendum, or ISO/IEC-9001:2008 certification) ‘ and the HSCN Compliance process.
If the HSCN supplier already has a certified Business Continuity Management System and/or a Service Management System, it is required that the HSCN service be incorporated into the respective management systems (incorporating the requirements of the Obligations Framework and HSCN Minimum Compliance Baseline.’
NCSC have stated that CAS T is no longer in use. Whilst a new security standard is being established by NCSC, we have established a position where previous CAS(T) requirements are now covered by ISO27001, Annual ITHC and BCDR plans. A statement has already gone to CN-SPs so they are aware of the current situation regarding re-certification.
Change reason – To meet a regulatory requirement.
Change Level – Major.
Comments due back on 27th December 2019. No comment is assumed to be acceptance.
- Not accepted. All CNSPs consume services/products from communication providers, greater understanding of the implications of this proposed change is required.
- This has been discussed at the CAS(T) forum [but not with CN-SPs] and there was an interim solution published by NHS Digital which was designed to maintain the standard with minimal impact to CNSPs. This was shared as part of the change request. The only further demand on CNSPs is that their ISO27001:2013 certification is awarded from a UKAS affiliated auditor. Unfortunately the removal of CAS(T) was beyond the scope of NHS Digital. The NCSC website has a statement around the removal of CAS(T) and that can be located on the following link. https://www.ncsc.gov.uk/information/cas-t-policy-and-guidance-documents
- A commercial review of the proposed changes is required.
- Please can some more information around this comment be provided. NHS Digital don’t believe that the move to Secure Boundary from ANM means any change to the commercial model.
- A call is requested with NHS-Digital to walk thorough the changes.
- A call is arranged for 9th January @ 10:00.
The following CN-SPs are consulted
- Convergence (Group Networks) Limited
- MLL Telecom Limited
- Redcentric Solutions Limited
- AdEPT Telecom PLC
- British Telecommunications PLC
- Piksel Limited (Carelink)
- Daisy Communications Limited
- Exponential-e Limited
- IT Professional Services Limited
- KCOM Group Public Limited Company
- CenturyLink Communications UK Limited
- Node 4 Limited
- NYNET Limited
- OCSL Managed Services Limited
- Updata Infrastructure (UK) Limited
- The Networking People (Northwest Ltd)
- Virgin Media Business Limited
- UKFast.net Limited
- Gamma Telecom
- High Speed Office
- Intercity Technology Ltd
- IQVIA Solutions UK Ltd
- Telefonica UK Limited
- CANCOM UK Managed Services