Acceptable Use Policy (External)

Acceptable Usage Policy for Third Party and Partner Organisations

Policy title:

Acceptable Usage Policy for Third Party and Partner Organisations

 

Issue date: April 2018

 

Review date:  March 2021

 

Version: 1.0

 

Issued by: Chief Information Officer

 

The aim of this policy is to:

  • Clarify the responsibilities regarding acceptable and unacceptable use of internet, email services and network access
  • Reduce or avoid security threats by increasing awareness and disseminating good practice.
  • Cease the copying/distribution of copyrighted materials.
  • Encourage effective use of resources.
  • Protect against potential liability.

 

Acceptable Usage Policy pdf version

 References

Associated documentation:

17 REFERENCES

 

Internet Resources

General Data Protection Regulation (2016/679)

http://www.eugdpr.org/

Regulation of Investigatory Powers Act 2000. http://www.legislation.gov.uk/ukpga/2000/23/contents

Telecommunication (Lawful Business Practice) (Interception of Communications) Regulations 2000. http://www.legislation.gov.uk/ukpga/2005/13/contents

Employment Code of Practice, Information Commissioner’s Office. http://www.legislation.gov.uk/ukpga/2005/13/contents

Obscene Publications Act 1959.

http://www.legislation.gov.uk/ukpga/Eliz2/7-8/66/contents

Protection of Children Act 1978. http://www.legislation.gov.uk/ukpga/2005/13/contents

Criminal Justice Act 2003. http://www.legislation.gov.uk/ukpga/2003/44/contents

Criminal Justice and Public Order Act 1994. http://www.legislation.gov.uk/ukpga/1994/33/contents

Computer Misuse Act 1990. http://www.legislation.gov.uk/ukpga/1990/18/contents

Freedom of Information Act 2000. http://www.legislation.gov.uk/ukpga/2000/36/contents

Disability Discrimination Act 2005. http://www.legislation.gov.uk/ukpga/2005/13/contents

Sex Discrimination Act 1975. http://www.legislation.gov.uk/ukpga/2005/13/contents

Race Relations Act 1976. http://www.legislation.gov.uk/ukpga/2005/13/contents

NHS.NET Guidance

http://www.legislation.gov.uk/ukpga/2005/13/contents

Copyright, Designs and Patents Act 1988. http://www.legislation.gov.uk/ukpga/1988/48/contents

Regulation of Investigatory Powers Act 2000. http://www.legislation.gov.uk/ukpga/2000/23/contents

Telecommunication (Lawful Business Practice) (Interception of Communications) Regulations 2000. http://www.legislation.gov.uk/uksi/2000/2699/regulation/3/made

 

Associated Policies

Tameside and Glossop Integrated Care NHS Foundation Trust expect all 3rd party and partner organisations that have the use of their services to understand, adopt, and work to all the policies that manage the information security assurance agenda.

 

These include but are not limited to:

Information Security Policy

Remote Working Policy

Network Security Policy

Data Protection Policy

Information Governance Policy/Strategy

Information Risk Management Policy

Bulk Transfer of Information Policy

Mobile Device Policy

 

Appendices:

Appendix 1 Email disclaimer (if email provided by TGICFT)

Appendix 2 Guidelines on the use of email

Appendix 3 Further details of legal issues

Appendix 4 Internet Filtering

Appendix 5 Internet Activity Request form

Appendix 6 Equality Impact Assessment

Approved by:

Peter Nuttall (SIRO)

Date:

 

 

Review and consultation process:

The policy has been revised by the CIO and the Information Security and Information Governance Manager. The following groups had an input for the consultation process

  • Information Governance Lead

Responsibility for Implementation & Training:

 

 

V 1.0

Revisions:

 

Date:

Author:

Description:

V1.0

   

 

Distribution methods:

Email

Intranet

Information Governance Toolkit Requirements

TGICFT

 

1. INTRODUCTION

  • TGICFT and the 3rd Party recognises that computer based information systems and services have the potential for enormous benefit to employees. The facilities give tremendous support to the management and delivery of services, and for communicating with partner organisations and stakeholders. It is Department of Health policy, that all NHS staff have the facility of internet and email access available in their workplace.
  • It is acknowledged that third parties and partner organisations will manage acceptable use and good practice for systems with a suite of policies that manage their employees.
  • Therefore, it is essential for users of IT systems that are connected on to Tameside & Glossop Integrated Care Foundation Trust’s perimeter adhere to the same rules that applies to all employees, students, third parties, partner organisations, volunteers, and visitors when signing the Acceptable Use Policy to formally agree the behaviours, values, and policies in place by the Organisation.
  • Finally, it is also recognised that these services can be misused, and thus the associated risks and pressures, including litigation and security concerns, legal and regulatory compliance and productivity of staff must be addressed. A basic principle of employment law is that employers can be held vicariously liable for the actions of the employee in the course of employment. In the course of employment is interpreted by the courts very widely, and thus accidental or intentional misconduct of employees is often included.

 

2. SCOPE

  • This policy applies to all employees of the named 3rd Party, volunteers, other NHS and health organisations, and other contracted staff; having the facility to use email and internet services, plus anyone granted access to the network whilst engaged in work for the 3rd party at any 3rd party occupied location, and/or on any 3rd Party owned or 3rd party/TGICFT approved computer asset.
  • This policy manages access and ownership of all removable media devices.
  • The policy also covers:
    • Direct email
    • Webmail
    • Instant messaging
    • NHS mail accessed from Third Parties/Partner Organisations equipment via the Tameside & Glossop Integrated Care Foundation Trust’s network
  • The principles of this policy apply to staff who have been granted access to internet and email services from home for business reasons.

 

3. DEFINITIONS

 

Copyrighted Material

A set of exclusive rights granted by the law of a jurisdiction to the author, owner or creator of an original work, including the right to copy, distribute and adapt the work.

Corporate email

Email where the function is to distribute business information securely. Email domains such as gmail, hotmail, and other free webmail are not considered corporate emails and should be avoided.

Email

Is the facility to communicate messages or information electronically to:

  • TGICFT/3rd Party employees using NHS/TGH mail.
  • Other NHS organisations and supporting organisations.
  • Other contacts associated with the business.

Internet Services:

Is the facility for:

  • The use of the 3rd party connection via N3 to the internet domain or www/world wide web.
  • The use of 3rd party’s information servers, i.e. both the intranet and internet sites for the 3rd

N3

Is the NHS secure highway for transportation of information between NHS organisations and supporting organisations who are authorised to do so.

Offensive material:

Is material that

  • Is pornographic or obscene.
  • Involves threats or violence.
  • Promotes illegal acts, racial or religious hatred or unfair discrimination.
  • Is found to be offensive by the recipient.

 

This list is not exhaustive: these are sample types of offensive material or practice.

Organisation

Tameside and Glossop Integrated Care NHS Foundation Trust and the wider health and social care services.

Network Storage:

This is a shared area on a storage area network (SAN), which allows folders, documents, emails, applications and data to be stored.

Endpoint:

Is any piece hardware or device that connects onto the network.

Third parties/partner organisation

Any entity that accesses Tameside and Glossop Integrated Care NHS Foundation Trust network services for business purposes.

 

Usually third parties are to be taken as commerical/private companies that are working to a contract to provide services.

 

Partner organisations are to be taken as public funded bodies that are working in conjuction with the organisation for a specific task.

4. DUTIES

  • The Chief Executive is responsible for ensuring that all Third Parties/Partner Organisations have effective policies to assist staff and control risks. The legal responsibility for employee for IT system use including emails and for internet misuse by an employee rests both with the Chief Executive and the employee responsible.

 

  • Senior Information Risk Owner

The Senior Information Risk Owner (SIRO) will:

  • Oversee the development of an Information Risk Policy, and a Strategy for implementing the policy within the existing Information Governance Framework;
  • Take ownership of the risk assessment process for information risk, including review of an annual information risk assessment to support and inform the Statement of Internal Control;
  • Review and agree action in respect of identified information risks;
  • Ensure that the organisation’s approach to information risk is effective in terms of resource, commitment and execution and that this is communicated to all staff;
  • Provide a focal point for the resolution and/or discussion of information risk issues;
  • Ensure the Board is adequately briefed on information risk issues

 

  • Director/Assistant Directors/Associate Directors

Has the responsibility for IT Services, which has an Chief Information Officer (CIO), through whom this policy will be delivered.

 

  • IT Lead

Is responsible for:

  • Overall responsibility for all IT services
  • Ensuring compliance to external standards and policies, e.g. NHS Digital
  • Keeping the policy under review in light of incidents and legislation.
  • Reporting non-compliance to this policy and other security violations via the Organisation’s risk management procedure.

 

 

  • Director of Quality & Governance

Is responsible for:

  • Advising on the security of personal data under Data Protection legislation.
  • Keeping the policy under review in light of incidents and legislation.
  • Reporting non-compliance to this policy and other security violations via the Organisation’s risk management procedure.
  • Maintaining the links with other Information Governance areas, principally the Corporate Records Management Policy and strategy.
  • Raising initial awareness of the policy at the corporate Organisation’s induction.

 

  • IT Services Department

Are responsible where applicable for:

  • Ensuring the availability of the internet and the supporting infrastructure.
  • Managing the security and integrity of data, via anti-virus, web filtering and content, and anti-spam products.
  • Managing the internet filtering and content by testing the integrity of web sites and categorisation of sites not yet categorised by the Organisation’s Web Management product.
  • Managing the establishment and maintenance of shared mailboxes, distribution lists and calendars on behalf of Organisation’s staff.
  • Undertaking programmed and ad hoc monitoring arising out of internet security products.
  • Maintaining the currency of Organisation’s employees in appropriate sources (starters and leavers).
  • Producing documentation and reports on internet and email usage and misuse.
  • Reporting non-compliance to this policy and other security violations via the Organisational risk management procedure.

 

  • Line Managers

Are responsible for:

  • Ensuring all staff read, understand, and sign the declaration.
  • Ensure that awareness to this policy is highlighted at their local induction programme.
  • Monitoring staff compliance to the policy.
  • Monitoring staff time spent on personal use of the internet and email services.
  • Instigating further investigations arising out of suspected misuse.
  • Taking action re misuse in accordance with this policy.
  • Reporting non-compliance to this policy using the Risk Management Policy
  • Taking care in relation to both external and internal emails that they cannot be considered to be contractually binding.

 

  • Staff

All staff are responsible for:

  • Complying with this policy and associated guidelines.
  • Reporting non-compliance to this policy and other security violations using the Risk Management Policy
  • Housekeeping of the mailbox store in line with guidelines.
  • Ensure that any personal information including patient and staff identifiable is held in a safe area with access to the approved people.
  • Adhering to the NHS mail Acceptable Use Policy when using NHS mail.
  • Ensuring that all materials used in publications/communications is not bound by copyright.

 

  • Third Parties/Partner Organisations

All Third Parties/Partner Organisations are responsible for:

  • Complying with this policy and the suite of Information Security Assurance policies
  • Timely reporting of non-compliance to this and the associated policies to the Tameside & Glossop Integrated Care Foundation Trust service desk
  • Ensuring that all information security risks identified are recorded with reasonable treatment
  • Ensuring that a robust identity management process, including starters and leavers is in place

 

5. POLICY STATEMENT

Computing facilities are to be used primarily for 3rd party business, but are available for general use providing the use complies with the standards set out in this policy. Authorised access to the internet and email services via the network will be granted to employees and/or authorised personnel who have read and signed this policy.

  • Inappropriate use of email and internet services will lead to disconnection and may lead to disciplinary action.
  • The Trust reserves the right to monitor all transactions transmitted to external sources via the Trust email system, and received from external sources, for inappropriate content. 
  • Specific software is employed to protect the network and enforce compliance with this policy, and with legislation. Therefore the overall patterns of internet and email usage, e.g. attempts to access blocked sites, use of inappropriate language are routinely monitored. In so doing, Tameside & Glossop Integrated Care Foundation Trust and Third Parties/Partner Organisations will at all times seek to act in a fair manner and respect staff rights for privacy of their personal data under the Human Rights Act 1998 and the Data Protection Act (2018).
  • Access to websites that contain offensive material, or which are deemed not to contribute to the business, e.g. gaming and shopping or social networking are prohibited. This includes the usage of copyrighted material copied from the internet or external sources.

 

6. LEGAL ISSUES

  • All staff using internet and email must clearly understand the legal issues involved from both their own perspective and from that of the 3rd The laws of defamation, obscenity, discrimination and harassment, copyright and confidentiality all apply to staff use of email and internet.
  • Further details of the legal issues are given for reference purposes at Appendix 3.

 

7 ACCEPTABLE USE

7.1 General

  • Users must ensure that they terminate each session and all computers, printers and peripheral hardware must be shut down at the end of the working day.
  • All devices are to be restarted at least once every 24hrs. This is a departmental responsibility.
  • The internet and email services are provided primarily for business use, and must be used responsibly.
  • Access outside of normal working hours will be at the discretion of the line manager or head of department, but in accordance with the standards in this policy

7.2 Email

Staff should:

  • Ensure that the identity of the receiving recipient’s email address is correct, and that messages or data sent by corporate email do not cause distress or offence to the receiving recipient, including chain mail messages, and jokes
  • Guard against accidental breaches of confidentiality by entering a wrong address or forwarding a message to inappropriate recipients
  • Initiate the Out of Office assistant on the corporate email service giving details of alternative contacts or arrangements for planned periods of absence
  • Set up shared email accounts and calendars, for managers/consultants and their secretaries through the Local Service Desk, rather than sharing usernames and/or passwords
  • Ensure delegation rights are set up when and where appropriate to give peers and/or assistants rights to administer mailboxes either routinely or in the event of absence
  • Use the sensitivity categories on email carefully (normal, personal, private, confidential) wherever possible
  • Clearly state to the recipient when material is private and confidential
  • Include ‘private’ within the title of the email in private emails . These emails will not be opened, unless they contravene other rules of the monitoring software or providing they do not contain profanity or for other good reasons such as being involved within a specific investigation
  • Inform their line manager if unsolicited offensive or sexually explicit emails are received, who will be responsible for deciding whether further investigation or disciplinary action is appropriate

Only send attachments that meet the size limit of the Organisation.

7.3 Internet

Staff should:

  • Use newsgroups and web discussion boards only in relation to business needs.
  • When using newsgroups and web discussion board ensure that the Organisational behaviours/values are represented.
  • Use the internet when appropriate to do so, in order that the productivity of the department is not compromised.
  • Exit a site immediately on finding that they have inadvertently accessed a site containing offensive or sexually explicit material, and report the web address or URL to the Local Service Desk.
  • Use approved images or corporate templates when creating documents and/or slideshows.
  • Use the approved 3rd party image library for inserting approved images onto webpages which are available using the content manager.

7.4 Removable Media

Staff should ensure that

  • Removable media shall only be used when an identified and agreed business use is required.
  • The use of removable media by Third Parties/Partner Organisations must be subject to the same risk assessment and authorisation process.
  • Only removable media that have been approved for use are to be used.
  • Removable media may only be used to store and share NHS information that is required for a specific business purpose.
  • Where person identifiable information or business sensitive information is being taken out or brought into the 3rd party, a departmental process must be in place to record the information stored on the device.
  • All incidents involving the use of removable media must be reported to the IT Services immediately and in accordance with Incident Reporting procedures.
  • Removable media should not be taken or sent off-site unless a prior agreement or instruction exists. A record must be maintained of all removable media taken or sent off-site, or brought into or received by the organisation.
  • Removable media must be physically protected against their loss, damage, abuse or misuse when used, where stored and in transit.

7.5 Network Storage

Staff should:

  • Ensure that information is stored on the network storage area. Information should not be stored locally on the device.
  • Housekeep files and folders on the network storage area to minimise duplication, wasted storage space and poor version control, but with due regard to retention periods set out in the 3rd parties Policies.

7.6 Access Control

  • All staff and contractors shall be given network access in accordance defined by their roles.
  • All staff and contractors must agree and sign the Acceptable Use Policy.
  • Diagnostic and configuration ports shall only be enabled for specified business reasons.
  • Segregation of networks shall be implemented as determined by the results of the risk assessment.
  • Network administrators shall group together information services, users and information systems as appropriate to achieve the required segregation on networks.
  • All users shall ensure that they lock their screens whenever they leave their desks to reduce the risk of unauthorised access.
  • All users shall keep their passwords confidential and unique user identities shall not be shared.
  • Access to information systems shall be granted using a formal user registration processes.
  • Managers shall approve user access rights notify the IT Service Desk of any changes to user roles and responsibilities.
  • Managers will contact the IT Service Desk when a user account is no longer required, e.g. through staff resignation or a change in duties to disable the account immediately.

 

8 UNACCEPTABLE USE

Below is a list of unacceptable use of internet and email services which can be defined as actions which could bring the the Organisation or the Third Party/Partner Organisation into disrepute, interfere with the 3rd Parties/TGICFTs business, or jeopardise the security of data, networks, equipment or software.

 

Inappropriate email messages going out of or coming into the Organisation or the Third Party/Partner Organisation may be subject to quarantine and removal by the message content management process. Inappropriate web sites are subject to restriction by the web content management process. This list is not an exhasutive list:

8.1 General

Staff must not:

  • Use the internet and/or email services for personal financial gain, or for personal or private advertising.
  • Use another staff member or party’s username or password to access the business networked services, or allow another user to use his/her own reference or accessed services.
  • Use another staff member or party’s means of access with or without their knowledge.
  • Attempt to introduce and transmit material (including but not restricted to, computer viruses, Trojan horses and worms) designed to be destructive to computer systems, or to try to get round precautions designed to prevent such material.
  • Display any sexually explicit images or documents, or any other images that are discriminatory, including screen savers.
  • Delete other users’ files or interfere in any way with the contents of their directories, particularly if given temporary or shared access.
  • Remove computer software such as desktop icons, wallpaper or screensavers from its location or tamper with it in any way.

8.2 Email

Staff must not:

  • Send any emails containing Personal Identifiable Data to any recipient that is not protected.
  • Use email to engage in activities or to transmit content that is harrassing, discriminatory, menacing, threatening, obscene, defamatory, or in any way objectionable or offensive. This includes disparagement or defamation concerning race, religion, colour, sex, sexual orientation, national origin, age, or disability, and incorporates sending, receiving, soliciting, printing, copying or replying to such messages.
  • Express personal views in such a way that they are likely to be interpreted as being the official policy/view held by the organisation.
  • Use personal email software/webmail (hotmail etc) for business or personal communications whilst at work.
  • Send unwanted email (junk email or unsolicited marketing material commonly known as SPAM), chain letters and offers, hoax virus warning, amusing animations and graphics, unsolicited mail or communication lists via the email system, as these can impact systems and disrupt email services.
  • Use email services to harass any other person external or internal to the 3rd party/TGICFT.
  • Use their own disclaimer on email messages sent to recipients outside of the Third Parties/Partner Organisations.
  • Disclose colleagues’ email addresses or personal information to either NHS and non-NHS sources. Such requests should be forwarded to the person in question, for them to decide. It should be noted that the forwarding of an email that has the names of other recipients in the header is a disclosure that may not be appropriate. When necessary to hide email accounts staff must use the bcc (Blind Carbon Copy) function or remove names. Using the bcc function will also users to send emails to many recipients without disclosing the other recipients.
  • Deliberately release confidential information. This is a disciplinary offence, as set out in this policy.
  • Use email services to forge email signatures.
  • Initiate a SPAM attack from within Organisation or Third Party/Partner Organisation.

8.3 Internet

Staff must not:

  • Use non-work related chat-rooms or similar services.
  • Surf the internet for non-work related subjects during contracted work time.
  • Play computer games across the network and/or the internet on a device owned by the Organisation.
  • Copy, use, or alter any material from the Internet which is protected by copyright law.
  • Use ‘cloud’ storage for work related information/data.
  • Access sites containing offensive material, or download any material from such sites. This includes but is not limited to sexual content, extreme political content.

This list is not exhaustive, but indicates the types of activity that may be regarded as misconduct. Staff should always bear in mind that they may be called upon to justify the use of internet and email to their manager, both in terms of time and content.

8.4 Instant Messaging

· Instant messaging is a way of communicating from one user to another and differs from email in that the conversations happen in real-time.

  • The service should not be used for personal use.
  • Refer to 3rd Party policies for details of approved (if any) instant messaging services

8.5 Streaming Media

Media that is distributed over a data network can be streamed such as radio or television or non-streamed such as video or audio. The user does not have to wait to download a large file before seeing the video/TV programme or hearing the sound, because it is sent in a continuous stream that is played as it arrives. This uses a great deal of bandwidth, potentially affecting other business use of the internet.

Staff must not:

  • Use streaming media for personal or private use.

8.6 Social Networking and Personal Sites

A social network service focuses on the building and verifying of online social networks for communities of people who share interests and activities, or who are interested in exploring the interests and activities of others.

Most social network services are primarily web based and provide a collection of various ways for users to interact, such as chat, messaging, email, video, voice chat, file sharing, blogging, discussion groups.

Staff must not:

  • Use Social networking sites for personal or private use unless required a part of their job role.

8.7 Network Storage Access

Staff must not:

  • Store any database or information system that holds Personal Identifiable Data.
  • Delete or remove any database or information system without consulting and adhering to the relevant Policies.
  • Store any information on the computer’s hard drive. The data will not be backed up which in the case of a hard drive failure may render the information lost. Or in the event of theft PID and other sensitive information may be lost.

8.8 Removable Media

Staff must not:

  • Use removable devices to permanently store information.
  • Loan removable media devices to anyone.
  • Attempt to install applications / or programs from removable media onto any TGICFT/3rd party computer assets
  • Use of USB drives or other mechanisms to subvert the security controls is expressly forbidden.

 

9 PRIVATE USE

Staff should refer to their own policy in regards to private use, however there are some aspects of use which come under the purview of Tameside & Glossop Integrated Care Foundation Trust

  • Personal use should not include operating a business, campaigning for political causes or candidates, or promoting or soliciting funds for a religious or other personal cause, and must comply with the provisions of this policy.
  • It is not permissible to use the email accounts for private correspondence, or for delivery of goods purchased over the internet.
  • Out of hours usage does not lessen the Organisation’s legal responsibility regarding inappropriate material and/or harassment, misrepresentation and other issues, and thus the principles of this policy apply to private use as well as business use.
  • Where an email is identified as private in its header, the message content will not be accessed, unless that message contravenes the rules built into the monitoring software. Where an employee is suspected of abusing the privilege of private use of email, the volume of misuse will be the major focus of investigation. However, if the Organisation suspects an employee of engaging in criminal activity in the workplace and reasonably believes that this may involve the sending or receipt of emails, the Organisation will have a right to access the contents of messages marked as private.

 

10 MONITORING OF USER ACTIVITY

10.1. It is the responsibility of the IT Services Department to undertake more in depth investigation where appropriate.

This can involve the reading of business and personal email contents and attachments to verify the validity of the content. A similar process is undertaken to assess and categorise web pages and webmail. The specialist software includes monitoring tools which can produce activity reports, on request from managers and heads of departments. Restrictions can be imposed on individual machines or groups of machines, and this can be at the request of the IT leads or Managers or Head of Departments. The Internet Activity Request form can be used for these requests at Appendix 5.

10.2. Anti-virus

Is implemented on:

  • Email gateways
  • Client and server machines.
  • This means that all staff’s email and outside connections will be scanned for viruses as a normal part of network security. 

10.3. Mail Content

Email gateways.

  • This software scans incoming and outgoing emails for inappropriate material such as language, images, and certain file types. It also places restrictions on file size and file type, and adds the authorised Trust disclaimer on outgoing messages.
  • Messages found to be in contravention of the rules set up within the software are quarantined, and assessed for release or deletion in line with the IT Services operational procedures. Ad-hoc processes are also carried out as requested via the Local Service Desk.

10.4. Web Filtering

Is active on all devices and block access to websites that have been categorised in the webfilter as:

  • Weapons based
  • Private homepages
  • Criminal activities
  • Suspicious
  • Drugs
  • Bandwidth
  • Extremist sites
  • Adult material
  • Streaming media
  • Gambling
  • Webmail
  • Social networking

Regular reports on staff access are viewed by Senior Management Teams, and ad-hoc audits can be made upon request.

10.5. Anti-spam

Is implemented on:

  • Dedicated email server.
  • Email gateways.
  • These services trap, quarantine/remove incoming mail that appears to be spam.

10.6 Removable Media

Removable media such as USB memory devices and DVDs are prohibited on site with few exceptions, these exceptions will require approval please contact the IT Service Desk for more information.

 

11 POLICY DEVELOPMENT & CONSULTATION

The policy has been revised by the Chief Information Officer and the Head of Quality Assurance to include wider IT issues than the original policy, which dealt with Internet and Email only. The previous policy was developed in consultation with the Deputy Director of Human Resources. The following groups had an input for the consultation process:

  • Human Resources Policy Development Group
  • Staff Partnership Forum
  • Local Negotiating Committee

 

12 IMPLEMENTATION

The Policy will be published on the intranet and external website. Third Parties/Partner Organisations that are using these services and are required to open an account with Tameside and Glossop Integrated Care NHS Foundation Trust will be subject to a sponship process.

 

13 MONITORING OF POLICY COMPLIANCE

Any breach of this policy will be investigated in accordance Trust’s Conduct and Disciplinary Policy.

Routine monitoring reports at aggregate level concerning the use of the web-browser may be made available to Directors and Managers on request.

Incidents with personal identifiable data leaving or coming into the Trust that has been caught in the email filter will be recorded via the Trust incident form and will be investigated Breaches of confidentiality may be subject to disciplinary action.

 

14 REVIEW

This policy will be formally reviewed three years after the approval of this updated policy, in April 2021, or earlier depending on the results of monitoring.

 

 

17 BIBLIOGRAPHY

  • The Legal Guide to Employee Monitoring, Hammonds.
  • Email Policy Best Practices: implementing and enforcing email policies to maximise regulatory compliance, Nancy Flynn, 2005.
  • How to write an Acceptable Use Policy, Surf Control.
  • Employee email and web use: a fresh perspective, Morgan Cole Information Security Team, 2003.
  • Email and Internet Policy, Glasgow Caledonian University.
  • Internet and Email Acceptable Use Policy, Hampshire Partnership NHS CCG.
  • Acceptable use of ICT Facilities Policy, Version 2.0, University of Salford.
  • Employment Practices Code, and Supplementary Guidance, the Information Commissioner.


APPENDIX 1: Tameside and Glossop Integrated Care NHS Foundation Trust EMAIL DISCLAIMER

 

DISCLAIMER : This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you are not the intended recipient, please do not disclose, copy or distribute information in this email or take any action on its contents. Any views or opinions expressed are those of the author and do not represent the views of Tameside and Glossop Integrated Care NHS Foundation Trust unless otherwise explicitly stated. The information contained in this email may be subject to public disclosure under the Freedom of Information Act 2000. Unless the information is legally exempt from disclosure, the confidentiality of this e-mail and your reply cannot be guaranteed. ************************************************************“Please support your hospital and encourage family and friends to become Foundation Trust members via the link below” http://www.tamesidehospital.nhs.uk/get-involved/foundation-trust-memberarea.htm Tameside and Glossop Integrated Care NHS Foundation TrustFountain Street Ashton-Under-Lyne OL6 9RW 0161-922-6000

APPENDIX 2: GUIDELINES ON THE USE OF EMAIL

1. Introduction

These guidelines apply to everyone in who employ the Organisational services to send communications, and should be read in conjunction with the Acceptable Use Policy.

 

2. The Purpose of Email Guidelines

  • Email is increasingly becoming the primary business tool for both internal and external communication and as a result should be treated with the same level of attention given to drafting and managing formal letters and memos. Email messages should not be treated as an extension of the spoken word because their written nature means they are treated with greater authority. As well as taking care over how email messages are written it is necessary to manage email messages appropriately after they have been sent or received.

 

  • There is a common misconception that email messages constitute an temporary form of communication. This misconception about how email messages can be used could result in legal action being taken. All email messages are subject to Data Protection and Freedom of Information legislation and can also form part of the corporate record. Staff should also be aware that email messages could be used as evidence in legal proceedings. These email guidelines set out the obligations that all members of staff have when dealing with email messages.

 

2.3. There are two main sections within these guidelines: the first concentrates on sending email messages, and the second concentrates on managing email messages that have been sent or received. Staff should ensure that they are familiar with the content of the guidelines and use them as a point of reference when dealing with email messages.

3. Sending emails and when to use email

Email is not always the best way to communicate information as email messages can often be misunderstood, sometimes as a result of email overload, when replies are not always thought through. It is the responsibility of the person sending an email message to decide whether email is the most appropriate method to communicate the information. The decision to send an email should be based on a number of factors including:

  • The subject of the message
  • The recipient’s availability
  • The speed of transmission
  • The speed of response
  • The number of recipients

 The Subject

  • Email messages can be used for different types of communication and can constitute a formal record of proceedings. The types of communication which email can be used for include general business discussions, disseminating information, agreement to proceed and confirmation of decisions made. Although email can be used for these types of communication, it may be necessary to consider whether the sensitivity of the information would be more appropriately communicated in a different way.

 

3.1.2. It should also be noted that there are certain subjects that should be avoided in email messages as they could be construed as discriminatory; this is covered in more detail in the section on email misuse within the Acceptable Usage Policy.

3.2 Recipient’s Availability

Email messages are often sent unnecessarily due to the ease and convenience of writing an email message. There are times when email might not be the most appropriate way of communicating with people, for example if a message needs to be passed onto a person in the same office speaking to them face to face might be more productive, particularly if they receive large volumes of email. If the person to whom the message is being delivered is not located in the office it might be better to phone them, depending on the subject or nature of the communication. When a message needs to be communicated to someone who is difficult to locate, for example they work in more than one office, then an email message should be sent in preference to speaking to them either face to face or via the phone.

 

3.3 Speed of Transmission

Email messages can be sent and delivered to the recipient quickly, which makes sending an email message a good way of transmitting information if the information is needed quickly and the recipient is expecting the information. However, where information needs to be communicated as a matter of urgency it is better to use the telephone.

 

3.4 Speed of Response

Although email message can be sent and delivered quickly there is no guarantee that the message will be read or acted upon immediately. One of the perceived advantages of using email is that it can be responded to at the recipient’s convenience. If a message needs to be acted upon immediately or requires a quick decision email is probably not the best way of communicating the information. Where an immediate action or response is required it is probably better to speak to the person directly and send email confirmation if it is deemed to be necessary.

 

Number of Recipients

  • Although email is often considered to be a good way of disseminating information to large groups it should be noted that there are some restrictions. The ability to send an email to everyone in the Organisation is restricted to relevant approved teams.
  • If an email needs to be sent to particular divisions or departments, or staff groups (e.g. senior managers) please use the pre-set distribution lists.

 

4. Writing Business Email Messages

Email communications are often perceived as being closer to informal speech rather than formal writing. Emails can be sent quickly and often with little thought regarding their contents. What the sender may construe as acceptable could be construed as rude and abrupt by the recipient. When writing business email messages it is important that consideration is given to the way in which the message is being conveyed. This includes thinking about the title, the text and the addressees. As a way of helping staff to draft emails in an appropriate fashion for business use guidelines to drafting email messages have been developed. These guidelines are intended to be a reference tool. It is up to the sender to decide to what degree to follow the guidelines, depending on their knowledge and level of familiarity with the recipient.

 

4.1 Subject Line

  • Ensure the subject line gives a clear indication of the content of the message.
  • Indicate if the subject matter is sensitive.
  • Use flags to indicate whether the message is of high or low importance and the speed with which an action is required.
  • Indicate whether an action is required or whether the email is for information only.

 

4.2 Subject and Tone

  • Greet people by name at the beginning of an email message.
  • Identify yourself at the beginning of the message when contacting someone for the first time.
  • Ensure that the purpose and content of the email message is clearly explained.
  • Include a signature with your own contact details.
  • Ensure your signature is not unnecessarily long.
  • Ensure that the email is polite and courteous.
  • The tone of an email message should match the intended outcome.
  • Make a clear distinction between fact and opinion.
  • Proof read messages before they are sent to check for errors.
  • Try to limit email messages to one subject per message.
  • Include the original email message when sending a reply to provide a context.
  • Where the subject of a string of email messages has significantly changed start new email message, copying relevant sections from the previous string of email messages.
  • Ensure email messages are not unnecessarily long.
  • Ensure that attachments are not longer versions of emails.
  • Summarise the content of attachments in the main body of the email message.

 

4.3 Structure and Grammar

  • Try to use plain English.
  • Check the spelling within the email message before sending.
  • Use paragraphs to structure information.
  • Put important information at the beginning of the email message.
  • Avoid using abbreviations.
  • Avoid using CAPITALS.
  • Try not to over-use of bold text.
  • Do not use emoticons.

 

4.4 Addressing

  • Distribute email message only to the people who need to know the information.
  • Using ‘reply all’ will send the reply to everyone included in the original email. Think carefully before using ‘reply all’ as it is unlikely that everyone included will need to know your reply.
  • Use the ‘To’ field for people who are required to take further action and the ‘cc’ field for people who are included for information only.
  • Think carefully about who should be included in the ‘cc’ field.
  • Ensure the email message is correctly addressed.

 

4.5 General

  • Be aware that different computer systems will affect the layout of an email message.
  • Avoid sending email messages in HTML format as if an email recipient is using an email system that does not allow HTML the layout will be affected.
  • Be aware that some computer systems might have difficulties with attachments.
  • Observe the restrictions on attachment size within the Organisation.
  • Try not to forward messages unnecessarily.
  • Never say anything in an email that you would not say face to face. Correspondence by email should never be used as an alternative to replace communicating with another employee in person.
  • The inappropriate use of upper case in email is generally interpreted as ‘SHOUTING’ and should be avoided.

 

5. Dealing with Sensitive Subjects

  • The privacy and confidentiality of the messages sent via email cannot be guaranteed. It is the responsibility of all members of staff to exercise their judgement about the appropriateness of using email when dealing with sensitive subjects. There is no guarantee that this will protect individual personnel from potential legal action if emails sent include unsupported allegations, sensitive or inappropriate information.
  • Staff must ensure that all information of a sensitive nature that is sent via email is treated with care in terms of drafting and addressing. Sensitive information sent via email that is incorrect might provide a case for initiating legal proceedings against the person sending the information and/or the Organisation that sent the email. Sensitive information can include commercial information, or information about specific individuals or groups.
  • When sending email messages that contain sensitive information the following aspects MUST be considered:
    • Email messages containing information that is not intended for general distribution should be clearly marked either in the title or at the beginning of the message, for example an email message containing comments about the performance of a specific staff member or a group of staff. This should decrease the likelihood of the message being forwarded to unintended recipients.
    • Email messages containing personal information are covered by the Data Protection Act and must be treated in line with the principles outlined in the Act. Under the Data Protection Act personal information includes opinions about an individual or the personal opinions of an individual. Email messages containing this type of information should only be used for the purpose for which the information was provided, be accurate and up to date, and must not be disclosed to third parties without the express permission of the individual concerned.
    • Email messages that contain information that is not supported by fact should indicate that it is the sender’s opinion that is being expressed.

6. Sending confidential information outside of the Organisational perimeter

Staff should only use the approved email accounts for sending personal identifiable data. Personal identifiable data includes staff details as well as patient data. Information can only be sent to bodies that have Government Secure E-Mail accounts. Any requests for communications outside of this that require any person identifiable data must apply to IT Services.

 

7. Managing Email Messages

7.1 Reasons for Organising your Mailbox

7.1.1. It is the responsibility of all members of staff to manage their email messages appropriately. It is important that email messages are managed in order to comply with Data Protection and Freedom of Information legislation. Managing email messages appropriately will also mean that work can be conducted more effectively as it will help to locate all the information relating to specific areas of business.

  • To manage email messages appropriately members of staff need to identify email messages that are records of their business activities as distinct from ephemeral email messages, e.g. availability for meetings, salutations and greetings etc.
  • It is important that email messages that are records are moved from personal mailboxes and managed with, and in the same way as other records. Temporary email messages should be managed within the mailbox and kept only for as long as required before being deleted. Mailbox stores should not be used as a filing system. They should be house kept regularly to ensure mailbox stores are not overloaded with unnecessary emails.

 

7.2. Making your Mailbox Manageable

  • Managing an email mailbox effectively can appear to be a difficult task, especially if the volume of email messages received is regularly of a large quantity. Managing an email mailbox should not be about following rigid classification guidelines; it is about following a methodology that works best for the individual.
  • There are a number of approaches that might aid the management of email messages, including:
    • Allocating sufficient time each day or week to read through and action email messages.
    • Prioritising which email messages need to be dealt with first.
    • Looking at the sender and the title to gauge the importance of the message.
    • Flagging where you have been ‘cc’d’ into email messages. These messages are often only for informational purposes and do not require immediate/any action.
    • Setting rules for incoming messages so they can automatically be put into folders.
    • Using folders to group email messages of a similar nature or subject together so they can be dealt with consecutively.
    • Identifying email messages that are records or need to be brought to other people’s attention.
    • Keeping email messages in personal folders only for short-term personal information. Emails that are required for longer purpose should be managed as records.
    • Deleting email messages that are kept elsewhere as records.
    • Deleting email messages that are no longer required for reference purposes from the in and out box.

 

8. Management of Shared Mailboxes

  • Shared mailboxes should be used where there are a group of people responsible for the same area of work. Where there are a group of people responsible for the same work using a shared mailbox can be a way of ensuring that queries are answered quickly when members of the team are away from the office. Access to a shared mailbox is initially given by request to the IT Service Desk and can then be granted by the person who owns the mailbox.
  • When managing shared email mailboxes, the sections of this email policy relating to, ‘reasons for organising your mailbox’, ‘making your mailbox manageable’ and ‘identifying and managing email records’ should be adhered to. There will also need to be some additional rules relating to when to delete an email message from the mailbox, how to identify an email message as having been answered and the types of email messages that should be treated as records. While it is the responsibility of the owner to ensure that there are specific rules relating to the management of shared mailboxes it is the responsibility of all staff members with access to shared mailboxes to abide by those rules.

8.1.3. It is important to remember that any email that made a significant contribution to the discussion of the business being conducted should be kept as a record and not just the final conclusions. The discussions that take place in the mailbox folder will represent the context within which the final decision was made and must be maintained as a record of the proceedings.

8.2 Identifying an owner

When a shared mailbox is created one person must be identified who can take ownership of the mailbox. The owner should be responsible for developing rules governing how email messages are responded to and how this is communicated to other people using the shared mailbox. It should be noted that the IT Services Department has overall responsibility for maintaining shared mailboxes. If the owner has any specific problems with managing the shared mailbox these should be discussed with the IT Services Department.

 

8.3 The purpose

The creation of a shared mailbox should be done with a specific purpose, for example to answer queries on a particular subject. It is the responsibility of the owner of the shared mailbox to ensure that the mailbox is used for the specified purpose and to take appropriate action if it is not.

 

8.4 Access

For shared mailboxes access should only be granted to people who are able to answer the email enquiries that will be received. In shared mailboxes it might also be necessary for the owner to delegate some responsibility to other people who are granted access in terms of managing the emails and ensuring the mailbox is used for its specified purpose. In terms of people sending messages to the mailbox it will be necessary to ensure that a message is given to people who might want to send enquiries giving the email address and the purpose of the mailbox.

 

 

9. Identifying and managing email records

9.1 Essential Principles

Email messages can constitute part of the formal record of a transaction. All members of staff are responsible for identifying and managing emails messages that constitute a record of their work. When an email is sent or received a decision needs to be made about whether the email needs to be retained as a record.

 

9.2 Identification and Responsibilities

 

9.2.1 Identifying Email Records

A record is ‘information created, received, and maintained as evidence and information by an organisation or person, in pursuance of legal obligations or in the transaction of business.’ When deciding whether an email message constitutes a record, the context and content of the email message needs to be considered. A guiding principle on identifying email records might be that as soon as the email message needs to be forwarded for information purposes it should be considered as a record. Email messages that might constitute a record are likely to contain information relating to business transactions that have or are going to take place, decisions taken in relation to the business transaction or any discussion that took place in relation to the transaction. For example, during the decision to put out a tender document for a particular service, background discussion about what this should and should not include might take place via email and should be kept as a record.

 

9.2.2 Who is Responsible?

As email messages can be sent to multiple recipients there are specific guidelines to indicate who is responsible for capturing an email as a record:

  • For internal email messages, the sender of an email message, or initiator of an email dialogue that forms a string of email messages.
  • For messages sent externally, the sender of the email message.
  • For external messages received by one person, the recipient.
  • For external messages received by more than more person, the person responsible for the area of work relating to the message. If this is not clear it may be necessary to clarify who this is with the other people who have received the message so that it is unnecessary for all recipients to retain it.

 

10. Managing Email Records with Attachments

  • Where an email message has an attachment a decision needs to be made as to whether the email message, the attachment or both should be kept as a record. The decision on whether an email and/or its attachment constitute a record depends on the context within which they were received. It is likely that in most circumstances the attachment should be kept as a record with the email message as the email message will provide the context within which the attachment was used.

 

10.1.2. There are instances where the email attachment might require further work, in which case it would be acceptable to keep the email message and the attachment together as a record and keep a copy of the attachment in another location to be worked on. In these circumstances the copy attachment that was used for further work will become a completely separate record.

11. When and Where to Manage Email Records

 

11.1 When to keep

Most email messages will form part of an email conversation string. Where an email string has formed as part of a discussion it is not necessary to keep each new part of the conversation, ie every reply, separately. There is no need to wait until the end of the conversation before capturing the email string as several subjects might have been covered. Email strings should be kept as records at significant points during the conversation, rather than waiting to the end of the conversation because it might not be apparent when the conversation has finished.

 

11.2 Where to keep

Personal mailboxes should not be used for long-term storage of email messages. Personal mailboxes should be used for personal information or short-term reference purposes, when these emails are no longer required they should be deleted.

 

12. Cyber Security

12.1 The cyber security threat continues against both public and private computer based services. All users must be vigilant when viewing websites and emails.

The creation of email messages with a forged sender address is known as ‘spoofing’. This means that some emails purporting to originating from a reputableorganisations looks to be safe and acceptable. Phishing is a technique employed by scammers to gain access of your computer/network, or to gain financial information usually via ‘spoofed’ email.

 

The NHS has recently fallen victim to ransomware which most likely originated as a phishing attack. Here are some warning signs to look for when receiving emails. Remember not to open any attachments or click on any links if they do not look right. Report any suspected attacks to the IT Service Desk.

 

12.2 Ways to identify spoof/phishing emails.

  • Legitimate messages usually do not have major spelling mistakes or poor grammar. Read your emails carefully and report anything that seems suspicious. Create a new email using a known email address to clarify if the email received is legitimate. If it is not, delete it from your inbox and deleted folder.
  • Check for generic information. For example an email asking for you to check and approve the attached invoice when you ordinarily do not approve invoices is likely to be suspicious.
  • If the email asks for you complete or action something that you have no prior knowledge of.
  • Do not click on attachments or web addresses on emails that you are not expecting.
  • Do not respond to an email that you consider being questionable even if from a believed friendly source, hackers can spoof email addresses. Report all suspected spoof emails to the IT Service Desk.

 

APPENDIX 3: FURTHER DETAILS OF LEGAL ISSUES

 

  1. Employee Monitoring

Under the Regulation of Investigatory Powers Act 2000, and the Telecommunication (Lawful Business Practice) (Interception of Communications) Regulations 2000, employers can monitor communications on a private network, either with the consent of all parties to the communications, or for a specific reason, complying with the criteria set out in the Act and Regulations.

 

  1. Defamation and Libel

Defamation law protects the reputation of individuals and corporate organisations. It includes libel (a more permanent statement, which would cover email and web defamation) and slander (a transient statement).

 

Facts concerning individuals or organisations must be accurate and verifiable, and views or opinions must not portray their subjects in any way that could damage their reputation. Web pages and email messages are regarded as published material.

 

Each repetition of the statement may be a fresh defamation, so what may have been intended as a joke for a limited audience could spread across the Third Party/Partner Organisation and beyond, possibly attracting court action.

 

  1. Confidentiality

Third Party/Partner Organisation has a duty to protect the confidential information that it holds about patients and staff. The law surrounding confidentiality is constantly developing, but the essential elements are found in the common law duty of confidentiality, and the Data Protection Act 2018. The Act is based on a set of principles relating to the fair and lawful handling of data, and requires that Third Party/Partner Organisations have appropriate organisational and technological measures in place to safeguard the personal data that it processes. Failure to comply with the Act attracts penalties ranging from fines to criminal sanctions for directors.

 

 

5. Obscenity

The Obscene Publications Act 1959 makes it an offence to publish, distribute, circulate, or sell any article, sound, film, record, picture (including cartoon images) or photograph that is obscene or the effect of which would “deprave and corrupt” those likely to read, see or hear the material. It is not an offence merely to hold pornography, unless it relates to children, but distributing or showing it is.

 

The Protection of Children Act 1978 makes it illegal to make indecent images of children, and show them. The Criminal Justice Act 1998 created the offence of mere possession of an indecent image of a child. The Criminal Justice and Public Order Act 1994 added pseudo photographs (computer generated images or those that alter images of adults to look like children). Downloading or emailing child pornography is deemed to be making an image or showing it.

 

Third Party/Partner Organisation, may be vicariously liable for the crimes of staff or people working in a capacity within the Organisation e.g. in circumstances where a manager encourages or condones the crime. The Third Party/Partner Organisation will be liable for a corporate criminal offence under the Protection of Children Act if the crime occurred with the consent or connivance of, or was attributable to the neglect on the part of any director, manager, secretary or other officer of the Third Party/Partner Organisation. That officer will also be personally liable as well as the employee who committed the offence.

 

6. Copyright Infringement

Under the Copyright, Designs and Patents Act 1988 and subsequent regulations, any uploading or downloading of information through on-line technologies which is not authorised by the copyright owner will be deemed to be an infringement of his/her rights. This includes copyright MP3 files, books, diagrams, photographs etc. Staff must not make, transmit or store an electronic copy of copyright material on the network without the permission of the author.

 

7. Computer Misuse Act 1990

It is a criminal offence to gain unauthorised access to a computer system to make any unauthorised modification of computer material (including the introduction of a computer virus) or to interfere with any computing system provided in the interests of health and safety.

 

APPENDIX 4 – INTERNET FILTERING RFC

INTERNET FILTERING RFC

CONFIDENTIAL

 

Date Raised

 

Incident Number

 

 

REQUESTER DETAILS

Name:

 

Job title:

 

Department:

 

Telephone number:

 

E-Mail address:

 

Requesters signature:

 

INTERNET FILTERING DETAILS

Website URL or category:

 

Name of user:

 

Group of users:

(specify on separate sheet and attach)

IP address:

 

Group of IP addresses:

(specify on separate sheet and attach)

Reason for internet filtering change:

 

AUTHORISATION - To be completed by Tameside and Glossop Integrated Care NHS Foundation Trust

Name:

   

Job title:

   

Date:

   

Signature:

   

WORK COMPLETE REPORT - To be completed by Tameside and Glossop Integrated Care NHS Foundation Trust

Name:

 

Job title:

 

Date:

 

Signature:

 

IT Services Contact Details:-

T: 0161 922 6969 ¦ E: servicedesk@tgh.nhs.uk

APPENDIX 5 – INTERNET ACTIVITY REPORT REQUEST

INTERNET ACTIVITY REPORT REQUEST

CONFIDENTIAL

 

Date Raised

 

Incident Number

 

 

REQUESTER DETAILS

Name:

 

Job title:

 

Department:

 

Telephone number:

 

E-Mail address:

 

Requesters signature:

 

INTERNET REPORT DETAILS

Name of user:

 

Group of users:

(specify on separate sheet and attach)

IP address:

 

Group of IP addresses:

(specify on separate sheet and attach)

Type of activity:

Allowed / Blocked / Both (Delete as appropriate)

Date range:

From:

To:

Reason for internet filtering change:

 

AUTHORISATION - To be completed by Tameside and Glossop Integrated Care NHS Foundation Trust

 

Name:

   

Job title:

   

Date:

   

Signature:

   

WORK COMPLETE REPORT - To be completed by Tameside and Glossop Integrated Care NHS Foundation Trust

Name:

 

Job title:

 

Date:

 

Signature:

 

IT Services Contact Details:-

T: 0161 922 6969 ¦ E: servicedesk@tgh.nhs.uk

 

APPENDIX 6: EQUALITY IMPACT ASSESSMENT

Name of Policy: Internet & Email Acceptable Use Policy

To be completed and attached to any procedural document when submitted to the appropriate committee for consideration and approval.(delete this advisory text when used in a document)

   

Yes/No

Comments

1.

Does the policy/guidance affect one group less or more favourably than another on the basis of:

   
 
  • Race

No

 
 
  • Ethnic origins (including gypsies and travellers)

No

 
 
  • Nationality

No

 
 
  • Gender

No

 
 
  • Culture

No

 
 
  • Religion or belief

No

 
 
  • Sexual orientation including lesbian, gay and bisexual people

No

 
 
  • Age

No

 
 
  • Disability - learning disabilities, physical disability, sensory impairment and mental health problems

No

 

2.

Is there any evidence that some groups are affected differently?

No

 

3.

If you have identified potential discrimination, are any exceptions valid, legal and/or justifiable?

No

 

4.

Is the impact of the policy/guidance likely to be negative?

No

 

5.

If so can the impact be avoided?

N/A

 

6.

What alternatives are there to achieving the policy/guidance without the impact?

N/A

 

7.

Can we reduce the impact by taking different action?

N/A

 

If you have identified a potential discriminatory impact of this procedural document, please refer it to Information Governance Department, together with any suggestions as to the action required to avoid/reduce this impact.

For advice in respect of answering the above questions, please contact Information Governance Department.(delete this advisory text when used in a document.

Request an Account; Declaration

Declaration

Applicants are required to complete the AUP declaration form in full.  All employment information is processed using the following legal basis model:

The lawful basis for processing the information related to staff is:
• General Data Protection Regulation, article 6 [1] [e]
• General Data Protection Regulation, article 9 [2] [b]
• Data Protection Act 2018, article 10
• Safeguarding Vulnerable Groups Act 2006 (DBS)

For more information on how we process personal information see the Privacy Notice https://www.tamesidehospital.nhs.uk/help/privacy-notice.htm

Email will be sent to servicedesk@tgh.nhs.uk

Service desk will forward the submitted form for approval by the appropriate CCG and Jr Dr’s Managers. An account will be created by the Service desk on receipt of the approved form.

Personal Details

Declaration

By ticking this box you are confirming that you are the named user requesting the account.  You have read, understood and agree to adhere to the IT Acceptable Use Policy of Tameside & Glossop Integrated Care NHS Foundation Trust.

 
 

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