ADHICS v2 Standard
ADHICS v2 Standard
TEMPLATE 5:
Standard
Document Title: Abu Dhabi - Healthcare Information and Cyber Security Standard
Document Control: Department of Health (DoH) - The Health Sector Regulator in the Emirate of Abu Dhabi
Any entity Including but not limited to, Healthcare Facility, Payer, Healthcare Technology
Applies To: and Service Provider in the Emirate of Abu Dhabi that generate, access, store, use,
process and/or transmit health information.
1
1.Standard Scope
The scope of Abu Dhabi Healthcare Information and Cyber Security Standard (ADHICS):
a) Any health sector (referred to as “entity”) including but not limited to, Healthcare Facility,
Payer, Service Provider in the Emirate of Abu Dhabi that generate, access, store, use, process
and/or transmit health information.
b) Any healthcare professional or other/support staff who has access to patient’s
health/diagnostic/personal information.
c) All information (in physical and digital forms), medical device and equipment, applications
and software, infrastructure, information system, physical infrastructure (data center, access
barriers, electrical facilities, HVAC systems, secure areas, etc.) and human resources (in
support of care delivery).
d) Any/all systems and applications fully owned by entity, as well as entity’s access and usage
of partners’ and third-party systems and applications utilized within Abu Dhabi Healthcare
ecosystem e.g., Shafafiya, Health information Exchange Platform, Electronic Medical
Records, Web and Mobile Application etc.
e) The content of the standard, while comprehensive, is not exhaustive. Depending completely
on the adoption and application of the Standard without due consideration of the actual or
tangible business requirements does not adequately discharge the healthcare entities’
management responsibility to provide and maintain health information security that
protects the information’s confidentiality, integrity, and availability. The entity shall consider
applicable laws, Federal/National and Local demands, regulatory requirements, and own risk
management while establishing and operating information security and data privacy
mandates.
The development and application of additional information security policies and procedures, or as
required by this Standard, is the responsibility of the entity.
2
2. Definitions and Abbreviations
3
when to upgrade or replace it, ensuring that it is properly maintained,
secured, and used effectively to achieve the organization's goals.
Data or images collected and stored (in a digital or hard copy format) and
2.19 the information systems that are used to generate, collect, store or
Assets exchange these data or images and/or support in entity operations for care
delivery
2.22 Back up (verb) To make a copy of data for the purpose of recovery.
4
Assessing the potential impacts on privacy of a process, information
Data Privacy Impact system, program, software module, device or other initiative which
2.31 processes protected health information for taking actions as necessary to
Assessment (DPIA)
treat privacy risk
Any event, regardless of cause, that disrupts (or has the potential to
2.34 Disruptive event disrupt) an organization’s ability to maintain identified critical functions.
A single physical location from which health goods and/or services are
2.36 Facility provided. A health care organization may consist of multiple facilities
Health Information Malaffi - that safely and securely connects public and private healthcare
2.39 providers in the Emirate of Abu Dhabi
Exchange (HIE)
5
Healthcare Any external party that provides medical device, system, application,
2.42 Technology and infrastructure or database, both individually or collectively that generate,
Service Providers access, store, use, process and/or transmit health information
Any technology used to place, keep, transport and or retrieve data. This
2.45 Media includes both electronic devices and materials as well as non-electronic
options e.g., paper.
Patient / Subject of One or more persons scheduled to receive, receiving, or having received a
2.48 health service
care
6
Personally Personally identifiable information (PII) is any data that could potentially
2.53 Identifiable identify a specific individual
Information (PII)
Protected health information (PHI), also referred to as personal health
information, is the demographic information, medical histories, test and
Protected health laboratory results, mental health conditions, insurance information and
2.54
Information (PHI) other data that a healthcare professional collects to identify an individual
and determine appropriate care.
Recovery Point Point in time to which data are to be recovered after a disruption has
2.55 occurred
Objective (RPO)
2.60 Standard Unless specified otherwise, the term refers to ADHICS Standard
A computer program that can copy itself and infect a computer without
2.65 Virus permission or knowledge of the user. Viruses usually corrupt or modify files
on a targeted computer.
7
3.Standard Requirements and Specifications
Section A
Introduction, Governance and Framework Definition
8
1. Abu Dhabi Healthcare Information and Cyber Security (ADHICS) Standard
Introduction
1.1 Introduction
Information and cyber security requirements are dynamic and ever evolving with technological
advancement and service capabilities. This document demonstrates the Abu Dhabi Government’s
commitment towards health information and cyber security, and identifies requirements and
enhancements needed to establish a cybersecure healthcare ecosystem. This document shall be formerly
referred as Abu Dhabi Health information and Cyber Security (ADHICS) Standard – Version 2 or ADHICS V2.
ADHICS V2 is aligned with the strategic demands of Abu Dhabi Healthcare information and Cybersecurity
Strategy, published in the year 2021, and supersedes the mandates provided by Abu Dhabi Healthcare
Information and Cyber Security (ADHICS) Standard V 0.9 of 2019, Internet of Medical Things (IoMT) Security
Standard V 0.9 of 2020 and Standard on Patient Healthcare Data Privacy V 0.9 of 2020, published by
Department of Health.
The provisions of this standard are harmonized with industry and international expectations towards health
information and cyber security, and it intends to ensure entities demonstrate their Information and
Cybersecurity compliance efficiently and address the specific management needs of the health sector in
their unique operating environments. The adoption of ADHICS V2 Standard by entities will facilitate secure
usage of medical technology and exchange of information, maintaining public trust in healthcare operations
and Government’s initiatives towards healthcare delivery.
1.3 Overview
The requirements of this Standard are based on governmental and industrial demands, and information
security and cyber security international best practices. DoH has invested time and efforts to understand
the demands, define Abu Dhabi Health Sector-specific Information and Cyber Security requirements, and
define timelines towards compliance.
9
Figure 1: Abu Dhabi Healthcare Information and Cyber Security Standard – Relational Representation
The standard focuses on the specifics of protecting and/or securing health information. It defines the
controls applicable for entities based on their capability, maturity, and risk environment. Compliance with
this Standard increases Information assurance and trust level between entities, public (citizens, residents,
and visitors) and governmental bodies.
10
1.5 Benefits
By adopting and complying with the provision of this Standard, entities demonstrate their commitment to
uphold Government’s values, and secure health information. The following are the benefits to be derived
by an entity from implementation of this Standard:
a) Comprehensive risk management and compliance towards Health information security
mandates and practices.
b) Protect entity’s reputation and build patient trust in entity operations health information.
c) Minimize entity’s network exposure to unauthorized accesses by adopting policies and
procedures.
d) Increased predictability of technology compromises and reduced uncertainty of business
operations by lowering information security-related risks to an acceptable level.
e) Safer use of medical devices and equipment for fast, efficient, and secure operations.
f) Secure digital transformation empowering entity to operate more efficiently, intelligently, and
effectively.
g) Minimize compliance failures in third-party and cloud services by incorporating security
requirements as part of their lifecycles.
h) Increased staff awareness on cybersecurity practices and due diligence to detect and prevent
cyber-attacks.
i) Avoid non-compliance penalties, by thoroughly evaluating the processes and technical
infrastructure for security gaps.
j) Contribute in DoH initiatives towards strengthening information security landscape of the
health sector of the emirate.
k) Avoid financial loss that is mostly due to theft of Personally Identifiable Information (PII and
PHI) investigation and Forensics, operational disruption, lost value of patient relationships, loss
of intellectual property by taking into consideration the accepted global benchmark for the
effective management of information assets.
l) Enable better and secure ways to process health related electronic transactions.
11
2. Abu Dhabi Healthcare Information and Cyber Security (ADHICS) Governance
The committees of the ADHICS Governance pyramid can be scaled down to match smaller entities
provided the three tiers’ roles are defined.
12
information security. It is chaired by the entity’s nominated/appointed senior/management resource and
includes Corporate/Business Leaders and Senior Management members from across the entity’s various
business lines. It shall have adequate power and authority, with a quorum strength of 60% to conduct
Committee meetings. The entity shall circulate minutes of meeting along with the action plan for each
committee meeting with the stakeholders. Important Committee decisions on the entity’s information
security affairs will be communicated to the Chair of Abu Dhabi Health Sector – HIIP Workgroup, through
entity HIIP – Workgroup.
The Committee will shall have the following roles:
a) Set up the goals of health information security and data privacy.
b) Review and approve entity’s information security Policy.
c) Review and approve quarterly progress and compliance reports and ensure submission to the
Department of Health.
d) Update the entity’s top Executive on the performance and progress of the entity’s information
security program.
e) Provide management oversight and direction for both physical and logical aspects of
information security.
f) Provide direction and recommendations to the entity’s HIIP - Workgroup on the overall
strategic direction and priorities in support of the Government’s interest, public trust and
entity objectives concerning Information Security and Technology.
g) Enforce ADHICS standards and related policies, and monitor compliance.
h) Recommend and communicate information security budget requirements and allocate
adequate to the executive management budget allocation towards entity Information Security
initiatives.
i) Provide sufficient resources to establish, implement, operate, monitor, review, maintain and
improve Information Security.
j) Acts appropriately on HIIP team reports concerning information security performance metrics,
security and privacy incidents, investment requests etc.
k) Approve the criteria for accepting the risk and acceptable levels of risk.
l) Decide information security action plan and keep track of the initiatives.
m) Ensure that internal information security and data privacy audits are conducted.
n) Ensure that corrective actions are taken basis on the outcome of internal audits/assessments,
management reviews, security incidents, and external audits etc., thus promoting continual
improvement and ensuring that the information security achieves its intended outcomes.
The Committee relies on feedback and reports from the HIIP and other personnel from various functions
namely: Strategy, Medical & Clinical Affairs/Practices, Internal Audit, Enterprise Risk Management,
Compliance, Legal and others to ensure that the principles, axioms and policies are adhered and followed
with in the practice.
13
2.1.2 Health information Infrastructure Protection (HIIP) Workgroup
The next layer of Governance is led by Health information Infrastructure Protection (HIIP) Workgroup. It
coordinates activities with “Implementation Stakeholders” across various functional/business verticals,
ensuring that suitable policies and procedures are well implemented to support Abu Dhabi Health
information and Cyber Security Standard.
The HIIP - Workgroup will shall have the following roles:
a) Identify processes and systems that are vital in health care.
b) Identify legislative, regulatory, and contractual requirements, including those for the
protection of health information.
c) Develop Information Security policies and ensure their compliance with the principles
approved by the ISGC.
d) Coordinate and manage the information security initiatives and its control demands.
e) Periodically review the information security policies to ensure the efficiency and effectiveness
of control/risk environment and recommend improvements where necessary.
f) Review and monitor compliance with the policies and assist in Internal Security audit and self-
assessment processes.
g) Address information security risks related to projects and deliverables throughout the project
life cycle.
h) Identify significant trends and changes in information security risks and, conduct periodic risk
assessment and where appropriate propose changes to the control’s framework and/or
policies.
i) Review critical security incidents and, where appropriate, recommend strategic improvements
to address any underlying root causes.
j) Periodically report on the status of the security controls to the ISGC and to the Chairperson of
the Abu Dhabi Health Sector HIIP – Workgroups.
14
• Local entity needs and risk environment.
• Industry specific needs
d) Act as entity ‘s point of contact to coordinate information security related matters with sector
regulator, along with representation from various business and support verticals as needed.
e) Define and maintain information security and risk management frameworks.
f) Manage achievement of cybersecurity objectives and goals
g) Maintain information security policies and coordinate review and approval.
h) Oversee implementation of controls in line with the requirements of information security
policies and procedures.
i) Manage the implementation of information security training and awareness programs.
j) Ensure the security of medical devices and equipment.
k) Coordinate or assist in the investigation of security threats or other attacks on information
assets.
l) Periodically report security incidents and violations of entity’s information security Policy and
Standards to the ISGC.
m) Supervise or manage preventive or corrective measures when a cybersecurity incident or
vulnerability is discovered.
n) Ensure information security effectiveness through audits, objectives/ KPI measurement and
reporting.
o) Ensure management reviews are conducted as per defined frequency and as required.
p) Ensure implementation of program/initiatives as needed by the government and/or sector
regulator.
15
e) Ensure active participation in initiatives such as training and awareness, internal audits, and
reviews.
f) Report to HIIP – Workgroup, on confirmed or suspected policy violations (Information Security
Incidents) affecting the entity’s information assets.
g) Evaluate compliance with the information security policies through regular self-assessment
process and internal audits.
16
3. Information Security Risk Management
Risk assessment can guide an entity in determining the level of efforts and resources needed to secure and
protect their data assets and information processing environments The entity shall define an information
security risk management procedure, with a step-by-step approach on how to perform the risk assessment
and risk treatment. The process of risk management will enable entity to identify threats to assets, and
associated vulnerabilities resulting in the likelihoods of occurrence being evaluated and potential impacts
estimated. The results of risk assessment shall align with risk remediation measures. The entity, regardless
of its type, shall undertake the following activities, as a minimum to meet its obligation in managing risks
towards health information ecosystem.
The entity shall apply the information security risk assessment process to identify risks associated with the
loss of confidentiality, integrity, and availability for its information assets by:
a) Defining the scope of the risk assessment exercise; Identify business functions/services.
b) Identifying information assets supporting business critical functions/services within the scope
and boundary of the risk assessment.
c) Calculating asset criticality value by rating Confidentiality, Integrity, and Availability on a scale
of 1 to 5 for each in scope information asset
d) Doing threat and vulnerability analysis for information assets
e) Assessing realistic likelihood of the occurrence and impact
f) Documenting associated risk and calculating levels of risk
g) Identifying existing information security controls
h) Defining mitigation plans for the identified risks and the expected completion dates.
i) Identifying the risk owners and the expected target date for closure of the control
implementation
17
• Risk Avoidance - Avoiding the activity causing risk.
• Risk Transfer - Transferring risk to another party
b) Establish and maintain policies in support of risk mitigation demands.
c) Define procedures in support of established policies.
d) Not limit control adoption as per this standard and identify all the controls that are necessary to
implement the treatment options.
e) Consider the risk acceptance criteria of the entity while selecting controls.
f) Determine the residual risk and evaluate likelihood and impact ratings after implementation of the
controls.
g) Identify proposed start and target completion dates for risk treatment plan implementation.
h) Identity responsibilities and priorities for managing information security risks.
• Control adequacy
• Control gaps
• Control enhancements
• Additional control requirements
• Policy updates and amendments
• Control withdrawal/termination
18
4. Statement of Applicability
The entity shall produce a Statement of Applicability (SOA) to justify specific security controls selected for
entity’s unique information security needs, aiding compliance, and risk management.
Statement of Applicability should contain:
a) The controls that have been identified as necessary.
b) Reasons for identification of these controls
c) Current status of implementation
d) Justification for exclusion of any of the “risk-based applicable” controls contained in these
Standards.
UAE IAR Reference: M2.3.4
19
Asset Classification Classification Factor and Criteria
Information destined to be used in public domain or public use, and
has no legal, regulatory, or organizational restrictions for its access
Public and/or usage.
Intended purpose from the creation, access and use of the information
is the general advancement of society, promotion of the interest of the
organization and of the country, providing essential information
equipping citizens, patients and other stakeholders understand better
the country’s/governmental/organizational vision and values.
Information that must be afforded limited confidentiality protection
due to its use in the day-to-day operations. Disclosure of such
information could have limited adverse impact on the functioning or
Restricted reputation of the entity or the government.
Information that relates to the internal functioning of the entity and
will not have general relevance and applicability to a wider audience.
Although individual items of information are not sensitive, taken in
aggregate they may reveal more information than is necessary if they
were to be revealed.
Information that requires robust protection due to its critical support
to decision-making within the entity, and across health sector and
government.
Confidential Information that could disclose designs, configurations, or
vulnerabilities exploitable by those with malicious intent.
Information that the entity, or through government or regulatory
mandates, has a duty of care to others to hold in safe custody (e.g.,
critical personal information, health/health information, government
information, financial information etc.).
Information that requires substantial and multilevel protection due to
its highly sensitive nature.
Secret
Disclosure of such information could have a serious and sustained
impact upon the government, national security, social cohesion,
economic viability, and health of the nation.
Information disclosure could potentially threaten life or seriously
prejudice public order.
20
6. Control Adoption, Compliance and Audit
The Abu Dhabi Health information and Cyber Security Standard sets out the minimum requirements
essential to secure health information and processing entities. The control requirements specified by
ADHICS Standard are grouped into four categories (individually referred as standard, in the context of the
area/section under consideration or being discussed), applicable to entities based on their perceived risk,
value of health information under custody service eligibility/ability of the entity. Entities shall define road
map for initiatives towards complete compliance/implementation of ADHICS Standard, consistent with
Government interest and objectives, and entity risk environment. Entities shall review and submit their
updated compliance status to DoH, as part of periodic compliance reporting, highlighting road map
timelines and deviations. Entities shall invest time, effort and resources to progress their compliance to full
compliance.
Control categories are based on continual improvement aspect of information security life cycle, which
ensures capabilities are continuously adapted and evolved in line with changing environments and maturity
level. To attain “Transitional” level, the entity must meet all demands of “Basic” and “Transitional” criteria
for each specific requirement/section. Similarly, to attain an “Advanced” level, demands of all applicable”
Basic”, “Transitional” and “Advanced” criteria for each specific requirement/section must be met.
All Healthcare Technology and Services Providers are required to implement controls as per the “Service
Provider” control category defined in the table below.
Control
Definition, Applicability (Entity Type) and Timelines of Compliance
Category
Control demands outlined in this category are the absolute minimum essentials of
information security and shall be considered a high priority to be complied with. The
control implementation shall protect Information assets from critical threats and shall
be considered foundational to build on assurance capabilities.
Applicability: Control demands of this category is always applicable. All in scope
entities shall comply with the provisions of this category. However, if the control
Basic
demands are not relevant to an entity’s business operation, the entity shall produce
valid business justification as part of their reports to DoH, along with necessary
supporting evidence and records.
Timeline for compliance: Within six months of official program induction/on-boarding
or official release of this standard, whichever comes first.
Control demands outlined in this category are high priority controls to enhance
security posture of entities. The control implementation shall protect information
assets from a wide range of threats, inclusive of critical and high impact threats, based
Transitional on the value of information assets owned, managed, and handled by the entity. The
control implementation directly complements in redefining/improve entities risk
environment.
21
Applicability: Control demands of this With bed capacity 1 to 20
category are applicable based on an
entity’s risk posture. They are
applicable to the following types of
entities: Hospitals
Center Any Center including but not
limited to Diagnostic Center,
Dialysis Center, Fertilization Center
(IVF), Rehabilitation Center
Payers Insurers
Third-Party Administrator (TPA)
Timeline for compliance: Within 6 months of official program induction/on-boarding
or official release of this standard, whichever comes first.
Note: All controls categorized as “Basic and Transitional” are considered essential and
are applicable by default.
22
The control demands of this category shall protect healthcare technology from critical
threats and shall be considered foundational for a secure healthcare service and
solution.
Applicability: Control demands of this category are applicable on any external entity
that is providing healthcare technology and service that generate, access, store, use,
process and/or transmit health information in any format of information, such as text,
video, audio, photos and images
These healthcare technology and services providers include but not limited to:
Service
Provider • Medical device or technology Providers
The standard establishes the potential security controls to cover a range of information security domains.
Each domain area includes various security best practices and controls that entity should consider for
implementation in a phased manner, based on its risk level and resource availability. Information security
controls shall be monitored periodically to ensure they are adequate, appropriately implemented,
maintained and that associated responsibilities, deliverables, and timelines are documented and reported.
Any policy established, in support of the implementation of this standard, shall have:
• Statement of management commitment
• Objective of the policy
• Scope and applicability of the policy
• Policy Statement
6.1 Compliance
The entity, regardless of its type, shall identify and maintain records of all legislative, regulatory, and
governmental executive orders and circulars relevant and applicable to its business. Such records shall
establish:
• Compliance checklists.
• Reporting obligations.
• Escalation demands.
23
Compliance with, and deviations from the provisions of such legislative, regulatory, and governmental
executive orders (Laws/Circulars/Standards/Regulations/Mandates etc.) shall be monitored and reported
to relevant internal and external authorities periodically. Risk of such non-compliance shall be recorded in
the entity’s enterprise risk manual and shall be suitably managed. The entity shall also demonstrate
compliance with applicable intellectual property rights (IPR) and the export/import and use of cryptographic
keys and mechanisms.
It is essential that the entity establishes reliable metrics and measurement to identify the state and
effectiveness of compliance with required controls. This shall produce comparable results through
timelines.
24
25
Section – B
26
1. Human Resources Security
Human resources are critical and valuable assets essential to conduct organizational business and are
considered the weakest link within the Information Security Framework. Healthcare entities shall take
adequate measures to ensure that qualified resources, are hired to deliver the right values, are equipped
to safeguard organizational interests, and are relieved in a manner that shall not impact organizational
assets, values, reputation, and financial conditions at any time, current or future.
Objective:
To ensure qualified and competent resources are hired and utilized to support secure delivery of
organizational objectives and services and are relieved in a manner that does not impact organizational
assets, value, reputation, and financial conditions any time current or in future.
Supporting or dependent entity policy references:
i. Information Security Policy
ii. Acceptable Usage Policy
iii. Compliance Policy
Control Criteria
Control Demands
Basic/Transitional/Advanced
27
UAE IAR Reference: M3.1.1, M4.1.1
HR 2 Prior to Employment
Control Criteria
Control Demands
Basic/Transitional/Advanced
28
HR 2.2 The entity shall establish specific terms and condition of
employment as part of the employment contract
The entity shall:
1. Include control requirement specific to employees,
contractors and third parties, relevant to their roles and
risk profiles.
2. Include information security responsibilities of the entity
and of the employees, contractors and third parties.
3. Ensure employees sign a Non-disclosure Agreement (NDA)
with the entity, as required.
4. Ensure the contract includes disciplinary action in case of
violation or non-compliance with the information security
requirements of the entity.
5. Ensure the Terms and conditions are read, understood,
Basic
agreed and signed by employees, contractors and third
parties.
6. Conduct mandatory briefing sessions to employees,
contractors and third parties on standard and specific
information and cyber security requirements of the terms
and condition.
7. Maintain adequate records on employee, contractor and
third-party briefing(s)
8. Maintain Terms and Conditions, Non-disclosure
Agreement (NDA) signed by employee, contractor and
third-party resources in-line with entity retention
requirements
9. Review and update any existing contract with employees,
contractors and third-party users, as required
29
HR 3 During Employment
Control Criteria
Control Demands
Basic/Transitional/Advanced
30
HR 3.3 The entity shall develop new or modify existing information
security and privacy education and training program to include
requirements of governmental and organizational information
security and privacy demands The entity shall:
1. Ensure all employees, and where relevant contractors
and third-party users, receive information security and
privacy training as part of their onboarding process
2. Ensure that an awareness and training program is
formally launched and effectively managed Transitional
3. Review and update the training content, as required
4. Assess and identify skill and competency gaps on
information and cyber security, data privacy compliance
demands
5. Implement skill and competency development programs
6. Periodically review training records to ensure that all
participants have received the required instruction
31
UAE IAR Reference: M3.2.1, M3.3.1, M3.3.2, M3.3.3, M3.3.4, M3.3.5, M3.4.1, M4.3.1, M4.3.2
Control Criteria
Control Demands
Basic/Transitional/Advanced
HR 4.2 The entity shall ensure recovery of all organizational assets upon
termination of employment, contract or agreement.
The entity shall:
1. Ensure all organizational assets are recovered and
necessary acknowledgement and clearance is obtained
from appropriate stakeholders
Basic
2. Ensure all information, with special focus on health
information, has been recovered and cannot be misused
anywhere, anytime
3. Ensure resources leaving the entity formally acknowledges
and conforms that no information is under their direct or
indirect possession or use
32
HR 4.3 The entity shall remove physical and logical access rights and
revoke privileges of individuals upon exit, termination of
employment, contract or agreement.
The entity shall remove access to systems, applications,
information, secure areas, and work areas.
The entity shall:
Basic
1. Ensure access to systems, application, information, secure Service Provider
areas, work areas and identified critical areas are revoked
in a timely manner within 24 hours upon exit termination.
2. Communicate with DoH and the entity being served to
revoke any relevant system and application access upon
termination
33
2. Asset Management
Asset Management is an essential part of effective health information Security management. In order to
be effective and supportive of organizational business and security objectives, entities shall maintain an
updated version of asset inventory, available to relevant management, business and support stakeholders.
Information assets include data/information in all its form, as well as the underlying application,
technology, physical infrastructure to support its processing, storing, communicating, and sharing and
people who have access to data/information.
Information Assets include, but are not limited to:
• Medical device and equipment used for diagnosis, therapy, monitoring, rehabilitation,
and care etc.
• Information system
• Physical Infrastructure (Data center, Servers, access barriers, electrical facilities, HVAC
systems, etc.)
Objective:
The regulatory structure surrounding nearly every facet of the healthcare operations, from protecting
patient data and improving health outcomes, to reporting on compliance-related issues, necessitates
entities to monitor and record the use of information assets.
34
AM 1 Asset Management Policy
Control Criteria
Control Demands
Basic/Transitional/Advanced
AM 1.2 The entity shall pay specific attention to medical devices and
equipment’s while defining policy, and shall categorically
address the following demands:
1. Maintain an inventory of medical devices and equipment,
and link them to patients while ensuring that sensitive
patient information is redacted and not visible
2. Roles that will be allowed to access, use and maintain
medical devices and equipment shall be established
3. To the extent possible, medical devices and equipment to Basic
authenticate users, based on entity’s authentication and Service Provider
authorization process
4. The need for handling procedures for each medical
device and equipment in use shall be defined and
updated as required to stay current
5. The need to establish and maintain risk log concerning
medical devices and equipment
6. Decommissioning and/or secure disposal of medical
devices and equipment
35
AM 2 Management of Assets
Control Criteria
Control Demands
Basic/Transitional/Advanced
36
AM 2.4 The entity shall establish and enforce policy on the
acceptable use of information assets to which users have
access:
1. The policy shall be communicated to all employees,
contractors and third-party users in support of care
Basic
delivery, and shall be read and acknowledged by all.
Service Provider
2. Entities shall maintain records of user acceptance on
the acceptable use of information assets.
The policy shall consider general requirements and industry
best practices and shall have management requirements to
reduce probabilities of information leakage/loss/theft and
system compromises.
AM 2.5 The entity shall identify and implement “Bring Your Own
Device (BYOD)” security controls, to ensure secure usage of
employees personally owned electronic devices for official
purposes.
37
AM 3 Asset Classification and Labelling
AM 3.1 The entity shall classify all information assets in line with the
information asset classification scheme.
The entity shall:
1. Determine classification considering the criticality of the
information it holds and ensure it is more
restrictive/deterrent based on the entity’s tolerance of
financial and reputational impact due to compromise of
the information considered.
2. Ensure the classification scheme is uniform across the
entity and well communicated.
Basic
3. Establish process for information labelling in accordance Service Provider
with entity’s information asset classification scheme.
4. Establish process to reassess and/or update information
classification, based on the following:
38
AM 4 Asset Handling
Control Criteria
Control Demands
Basic/Transitional/Advanced
• Storing Basic
• Communication/sharing
• Printing
• Removal and disposal
2. Security requirements based on asset criticality shall be
considered in the handling procedures
39
AM 4.3 Access and privilege allocation for medical devices and
equipment shall be provided to defined roles, with essential
qualification and experience required to operate.
The entity shall: Basic
Service Provider
1. Secure and safe-guard medical devices and equipment
with adequate security controls in accordance with its
classification scheme and risk factors
40
AM 5 Asset Disposal
Control Criteria
Control Demands
Basic/Transitional/Advanced
AM 5.1 The entity shall ensure assets, both digital and physical,
when no longer required are disposed beyond recovery.
The entity shall
1. Dispose information assets, when no longer required:
• by the entity
• Disposal authorized by
41
3. Physical and Environmental Security
Physical and environmental security measures shall be implemented to ensure processing facilities are
physically protected from unauthorized access, damage, interference, and equipment is protected from
physical and environmental threats.
These security measures or controls shall protect entities from loss of connectivity, availability of
information processing facilities, storage (backup and archival) equipment(s)/facilities and medical
equipment’s/devices caused by theft, fire, flood, intentional destruction, unintentional damage, mechanical
failure, power failure, etc.
Objective:
To ensure that information assets receive adequate physical and environmental protection, and to prevent
or reduce probabilities of physical and environmental control/security compromises (loss, damage, theft,
interference, etc.)
Supporting or dependent entity policy references:
i. Clear Desk and Clear Screen Policy
42
PE 1 Physical and Environmental Security Policy
Control Criteria
Control Demands
Basic/Transitional/Advanced
43
PE 2 Secure Areas
Control Criteria
Control Demands
Basic/Transitional/Advanced
PE 2.1 The entity shall define and use security perimeters to protect
areas that contain information and information systems.
The entity shall:
1. Identify secure areas and define security perimeters,
based on information assets contained within or
information being processed.
2. Ensure adequate security countermeasures are applied
to identified secure areas to protect information and
information systems within
Basic
3. Consider the impact of compromise of confidentiality, Service Provider
integrity and availability of information or information
assets while applying security controls.
4. Ensure secure areas are protected by appropriate control
measures and only authorized personnel are provided
access and authorized activities are being conducted.
5. Control access of mobile, portable and surveillance
devices/equipment/utilities to secure areas
44
7. Escort contractors or third parties while inside the secure
areas
8. Deploy closed circuit television (CCTV/surveillance
camera) in identified vantage points of secure areas as
required by Monitoring and Control Centre (MCC) Abu
Dhabi
9. Preserve CCTV footage for a period as required by
Monitoring and Control Centre (MCC) Abu Dhabi
PE 2.4 The entity shall nominate owners for each identified secure
area.
Nominated owners of secure areas shall:
1. Review access records/logs and surveillance footage in
accordance with entity policy or in case of any security
incident, whichever is earlier.
2. Reconcile list of authorized users, having access to secure Transitional
areas
3. Maintain a list of physical key inventory, as with whom
the keys of secure areas are with
4. Ensure to change the combinations and keys for any
entity-defined secure zones, entry/exit points, and
cabinets, when compromised
PE 2.5 The entity shall design and apply physical protection against
natural disasters, environmental threats, external attacks
and/or accidents.
The entity shall:
1. Implement and maintain environmental control systems
for data center’s, that monitor, maintain, and test the
consistency of temperature and humidity conditions in
accordance with regulatoryrequirements.s
Basic
2. Ensure appropriate fire suppression systems (e.g., Service Provider
sprinklers, fire extinguishers) are located throughout the
entity.
3. Ensure fire detectors (e.g., smoke or heat activated) are
installed on and/or in the ceilings and floors.
4. Ensure that fallback equipment, device, system and
backup media are protected from damage caused by
natural or man-made disasters.
45
5. Ensure availability of power backup to provide power to
key information systems and critical data centre
infrastructures
PE 2.6 The entity shall have segregated delivery, loading areas and
shall establish control measures over entry and exit.
The entity shall:
1. Establish access procedures to loading and unloading
areas to restrict access to only authorized personnel. Basic
2. Inspect and register incoming and outgoing materials, in
accordance with entity’s asset management procedures.
3. Physically segregate incoming and outgoing materials, as
applicable
PE 3 Equipment Security
Control Criteria
Control Demands
Basic/Transitional/Advanced
46
PE 3.3 Power, telecommunication, and cables carrying data shall be
secured and protected.
The entity shall:
1. Ensure that power, telecommunication and data cables Basic
are protected against physical tampering.
2. Segregate power and telecommunication/data cables
to avoid interference
PE 3.5 The entity shall define and enforce a clear desk and clear
screen policy for paper documents, removable storage media,
and information processing systems.
The clear desk and clear screen policy shall:
1. Define user responsibilities with respect to clear desk
and clear screen requirements.
Basic
2. Be appropriate to the purpose and objectives of the
entity.
3. Be read and acknowledged by all employees and
contractors of the entity.
4. Ensure that health information is not left unattended
UAE IAR Reference: T2.3.1, T2.3.2, T2.3.3, T2.3.4, T2.3.5, T2.3.7, T2.3.8, T2.3.9
47
4. Access Control
Access control processes enforce security requirements such as confidentiality, integrity, and availability of
information assets to prevent unauthorized use of resources. Access controls shall be developed by entity
to control access of employees, contractors, and third-party users to entity’s information assets and to
manage their access in reference to internal network, operating systems, and applications to ensure
appropriate protection of entity’s infrastructure health information protected health information. Entity’s
management shall be aware of the risk environment and outcomes of unauthorized access, and are
accountable for all consequences and impact on Abu Dhabi Government, Abu Dhabi Healthcare-ecosystem
or Health Sector, Patients concerned and the entity itself.
Objective:
To ensure access to information/information systems are controlled, and to minimize probabilities of
information leakage/compromise, tampering, loss or system compromises.
Supporting or dependent entity policy references:
i. Physical and Environmental Security Policy
ii. Clear Desk and Clear Screen Policy
The level of applicability of above-mentioned policies will vary depending on the individual entity.
48
AC 1 Access Control Policy
49
6. Mandate the usage of unique identity and complex
password where relevant, define access control measures
and provisions for portable/mobile devices, including user
owned devices, that handle the entity’s data or host the
entity application(s) to conduct business transactions.
7. Include control requirements for the access and use of
network services.
8. Include management actions on violations and deviations.
9. Define roles and responsibilities for actions expected
Control Criteria
Control Demands
Basic/Transitional/Advanced
50
AC 2.2 The entity shall restrict and control allocation of privileges, based
on principles of need to know.
The entity shall:
1. Ensure normal user accounts are not used as service
accounts or to conduct privileged application and system
level activities.
2. Control and restrict from sharing privilege user IDs to
multiple users.
3. Ensure users privileges are restrictive in nature, and are
assigned based on needs to conduct business activities
supported by necessary approvals. Transitional
Service Provider
4. Ensure Privilege or administrative accounts are only used
for system administrator activities and not for daily day to
day operations.
5. Ensure usage of service accounts are controlled, and are
not hardcoded in application codes or scripts.
6. Enforce multifactor authentication scheme for all privilege,
administrative and remote access.
7. Ensure remote access is controlled and monitored
51
AC 2.3 The entity shall establish a process for secure allocation, use and
management of security credentials.
The entity shall:
1. Ensure to change default credentials for all information
assets before deployment to operational environment.
2. Ensure that passwords are prohibited from being displayed
when entered.
3. Ensure passwords are always hashed and stored in
encrypted format.
4. Communicate details of user account and password in two
different communication modalities
5. Enforce complexity requirements on password characters,
and shall have at least:
Basic
a) Twelve characters
Service Provider
b) One number, one upper-case and lower-case
character, and a special character
6. Ensure passwords, including that of service accounts and
privileged accounts, are changed periodically.
7. Ensure account lockout features are configured to block
the users after at least 5 failed attempts.
8. Ensure that password history is maintained, and shall
restrict users from using immediately used previous
passwords (at least 3 previous passwords)
9. Ensure to change password post remote maintenance
session which requires sharing of password.
10. Educate users to adopt good practices while selecting and
using passwords
52
AC 3 Equipment and Devices Access Control
Control Criteria
Control Demands
Basic/Transitional/Advanced
AC 3.2 The entity shall control access to equipment, devices, system, and
facilities at teleworking sites.
The entity shall:
1. Ensure access to equipment, devices, system and facilities
at teleworking sites are authenticated, and their access to Transitional
entity resources are authorized based on need.
Service Provider
2. Ensure confidentiality and protection of health information
while providing/consuming services through teleworking
principles.
3. Maintain an inventory of assets in use at teleworking sites
53
AC 4 Access Reviews
Control Criteria
Control Demands
Basic/Transitional/Advanced
AC 4.1 The entity shall review access and privileges granted to its user.
The entity shall:
1. Establish process for the reviewing user access and
associated privileges to various entity resources
periodically.
Basic
2. Define responsibility for access and privileges review, based Service Provider
on entity resources being accessed.
3. Conduct user access review at least once a year or earlier,
as required by the entity’s risk environment.
4. Maintain an up-to-date inventory of access granted and
privileges assigned
Control Criteria
Control Demands
Basic/Transitional/Advanced
3. Ensure all remote login and access are only through secure
channels.
4. Identify all equipment and devices connected to its network,
and shall have mechanism to detect unauthorized
equipment and devices
AC 5.2 The entity shall have mechanism to identify all equipment and
devices connected to its network, and shall have automated Advanced
mechanism to detect unauthorized equipment and devices
54
AC 5.3 The entity shall control access to all information assets for the
purpose of diagnosis and configuration.
The entity shall:
1. Identify and whitelist all ports, services and utilities that are
used for troubleshooting, and for diagnostics and
configuration purposes. Advanced
2. Provide rationale or define security controls for the
diagnostic and configuration services and utilities that are
essential, and disable services and utilities that are not
required.
3. Restrict access for remote troubleshooting, diagnostic and
configuration to authorized roles and shall be allowed from
authorized workstations
AC 5.4 The entity shall define and implement network routing controls to
ensure information flow and system, medical devices and
equipment connections are not compromised.
The entity shall:
1. Establish processes for secure configuration and rules for
network routing requirements.
2. Always ensure source and destination address and services
or ports are used while defining and applying routing rules.
3. Enable routing protection countermeasures to avoid
manipulation of routing systems and tables.
Transitional
4. Define and implement network architecture that segregates
and isolates internal and externally accessible systems. Service Provider
55
AC 5.5 The entity shall ensure wireless access within the entity is secured.
The entity shall:
1. Ensure that internal wireless is not broadcasted.
2. Establish authorization process for wireless access and Transitional
usage.
3. Ensure only trusted devices and users gain access to internal
networks via wireless access
UAE IAR Reference: T5.4.1, T5.4.2, T5.4.3, T5.4.4, T5.4.5, T5.4.6, T5.4.7
Control Criteria
Control Demands Basic/Transitional/Adv
anced
AC 6.1 The entity shall establish and enforce secure log-on and log-off
procedures to control access to system, applications, services, medical
devices and equipment.
The entity shall:
1. Ensure that access to systems, applications, services, medical
devices and equipment that process, use or store health
information are authenticated.
Basic
2. Enforce automated locking of workstation/system after a Service Provider
predefined period of inactivity.
3. Automatically terminate inactive sessions after a predefined
period of session inactivity
4. 6. Display a logon banner that requires the user to acknowledge
and accept security terms and their responsibilities before
access to the system is granted
AC 6.2 The entity shall create unique identifier (user ID) for each user who
requires access to entities systems, applications, or services, and shall
implement a suitable authentication technique.
The entity shall: Basic
56
AC 6.3 The entity shall restrict and control the use of utility programs and
tools that might be capable of overriding system and application
controls.
The entity shall:
1. Identify essential system utilities and tools and enforce
appropriate controls for use. Advanced
2. Provide access to system utilities and tools based on
appropriate authorization.
3. Maintain inventory of access to system utilities and tools
4. Monitor use of system utilities and tools
57
5. Communications and Operation Management
Communications and Operations management aims to establish and/or strengthen entities processes and
efforts to improve and enhance control environment. Entity shall have controls in place to ensure the safe
operation of information processing equipment and the security of data while it is processed, stored and
transmitted across networks.
The domain addresses requirements of backup, security of network, secure electronic communication and
monitoring to ensure protection against malicious code and spyware.
Objective:
To ensure that activities concerning entities processes, support and maintenance of data, technology,
application, and communication are controlled and carried out in a standardized and secured manner to
reduce probabilities of errors and compromises, and to increase efficiency and security.
Supporting or dependent entity policy references:
i. Change Management Policy
ii. Capacity Management Policy
iii. Patch Management Policy
v. Backup Policy
58
CO 1 Communication and Operation Management Policy
59
CO 2 Operational Procedures and Responsibilities
Control Criteria
Control Demands
Basic/Transitional/Advanced
CO 2.1 The entity shall develop and enforce baseline and
recommended configuration and system settings for hardening
of information technology products, applications, virtual
machines (VM), medical devices and equipment The entity
shall:
1. Consider the following while developing baseline and
recommended configuration setting:
a) Requirements of this Standard
b) Manufacturer’s security recommendations Transitional
c) Industry best practices Service Provider
CO 2.2 The entity shall document and follow operating procedures for
all administrative, support, operational and maintenance
activities of information systems, applications, medical devices,
equipment or Cloud based systems and solutions.
The entity shall:
1. Disseminate operating procedures and ensure all
relevant internal stakeholders are aware of their
responsibilities as needed by their roles.
Advanced
2. Ensure all the involved third-party users (if any) are well
aware of the entity’s operational procedures and they
adhere to the same.
3. Ensure operating procedures are relevant and are
updated periodically or in case of any significant change,
whichever is earlier
4. Ensure system documentation includes up-to-date
diagrams.
60
CO 2.3 The entity shall establish, document, approve, communicate,
apply, evaluate, and maintain the policies and procedures for
managing the risks associated with applying changes to entity
assets including information systems, software’s, applications,
medical devices, equipment, infrastructure and technology
environment regardless of whether the assets are managed
internally or externally.
The entity shall:
1. Establish a Change Advisory Board to authorize changes.
2. Define and enforce a process that addresses the
following elements:
a) Identification and recording of significant changes.
b) Planning and testing of changes in test environment
c) Assessment of potential risks and impacts of changes
d) Formal approval procedure
e) Communication of change to all relevant
stakeholders
f) Identification of stakeholders responsible for the
“build, test, and implement” portion of the change. Transitional
g) Roll-back plan to be utilized during unsuccessful
changes.
h) Post implementation assessment
i) Monitoring of changes
j) Maintenance of change records
3. Maintenance of previous version of software, code, and
configurations. Maintenance of CMDB with updated
Configuration Items. Ensure that movement of system
and applications from development or project state to
operational or production state are managed through the
Authorization and Change Process
4. Identify and segregate roles of conflicting interests and
assign responsibilities accordingly.
5. Make sure the third party notifies the entity in advance
of any changes to the manner services are provided,
including but not limited to:
a) Relocation
b) Reconfiguration
61
c) Changes in hardware or software
d) Onboarding sub-contractor
e) Changes to operating environment
CO 2.4 The entity shall identify and maintain separate environment for
development, testing, staging and production.
The entity shall:
1. Identify the appropriate level of segregation and
protection between production, staging, test, and
development environments.
2. Document and apply clear processes for the transfer of
data, information, code, configuration, software and
Transitional
systems between environments.
Service Provider
3. Ensure as-is operational data, confidential data and/or PII
and PHI is not used in test environment.
4. Restrict usage/migration of test data into operational
environment.
5. Ensure to test the change in testing environment before
rolling it out in production state.
6. Prepare a rollback strategy
UAE IAR Reference: T3.2.1, T3.2.2, T3.2.3, T3.2.4, T3.2.5, T7.6.1, T7.6.2, T7.6.3
62
CO 3 Planning and Acceptance
CO 3.1 The entity shall identify and document current and future
capacity requirements for information systems and
applications.
The entity shall:
1. Have the ability to monitor and measure the capacity of
current systems and estimate future information systems
and application demands.
2. Ensure there is sufficient capacity with information
systems to support good system performance and
reliability. Advanced
63
CO 3.2 The entity shall establish acceptance criteria for new
information systems, applications, medical devices, equipment,
and for changes, upgrades and releases, in addition to
satisfactory test results.
The entity shall:
1. Establish processes for system acceptance, and ensure
system acceptance is acknowledged by the relevant
authoritative individual.
2. Develop test cases for each of the requirements and
changes and ensure tests are carried out and test results
documented prior to usage in an operational Transitional
environment. Service Provider
3. Ensure testing is never performed on production
systems.
4. Ensure user (with permissions appropriate for the tasks)
involved in testing are different from the ones involved in
operational and development activities.
5. Ensure development tools and/or editors are not
installed on operational systems.
6. Ensure test data and accounts are removed completely
before the application is moved into production state
64
CO 4 Malware Protection
65
CO 4.2 The entity shall deploy gateway level protection mechanisms
for web and email traffic to detect and defend against malware
and viruses.
The entity shall:
1. Implement Email Authentication Solution to block Advanced
harmful or fraudulent uses of email such as phishing and
spam.
2. Check any attachments or downloads from email and
instant messaging for malware, before use
66
2. Perform backup of all identified systems, applications and
its critical data including the configuration
3. Establish a data restoration process and ensure data
restoration requirements for continuity and recovery are
adequately met.
4. Ensure data backups are tested for restoration in
accordance with the entity’s defined recovery plan
5. Ensure data backup of specific instances are not mixed,
accidently or deliberately.
6. Ensure backups are not stored on entity live environment
67
CO 6 Logging and Monitoring
CO 6.1 The entity shall establish and enforce Logging and monitoring
procedures for information systems application, cloud
services, medical devices, equipment etc.
The entity shall:
1. Ensure all critical technology (servers, database, network
devices, applications, medical devices equipment etc.)
are capable of generating logs and/or reports that can be
referred for monitoring.
2. Identify aspects system use, privilege activities, operator
and user activities, logon attempts, network, system and
application traffic, security events, changes, internal
processing, Exemption, information exchange,
integration, access, backup process etc.) to be monitored
3. Establish minimum information gathering requirements
for each monitoring activities.
4. Conduct real time monitoring or in a defined periodic Advanced
interval, subject to entity risk environment. Service Provider
68
CO 6.2 The entity shall preserve logs in a centralized log management
system.
The entity shall:
1. Control access to the centralized log management
solution
2. Ensure the centralized log management solution is
managed by individuals who do not have operational role
in implementing or maintaining information systems or
application.
3. Ensure logs are correlated to identify any security threats
or malicious activity. Advanced
4. Retain logs for a period commensurate with legal,
regulatory and entity demands.
5. Define use cases and dashboards based on the entity’s
needs and industry recommendations, and shall
consider:
a) System utilization and performance trends
b) Deviation from entity policy and procedures
c) Access control variances and violations
d) Any potential sign of security breach or attack
CO 6.3 The entity shall synchronize clock of all information systems and
devices with an agreed time source.
The entity shall:
1. Standardize date/time format and enforce the standard
time to be used in all systems. Basic
2. Ensure clock of medical devices and equipment are
synchronized with the connected systems.
3. Regularly check that the clocks of all relevant information
processing systems are synchronized.
UAE IAR Reference: T3.6.1, T3.6.2, T3.6.3, T3.6.4, T3.6.5, T3.6.6, T3.6.7, T7.6.
69
CO 7 Security Assessment and Vulnerability Management
Control Criteria
Control Demands
Basic/Transitional/Advanced
CO 7.1 The entity shall conduct periodic independent
(Internal/External) technical assessment to ensure critical
information assets are secure and always protected.
The entity shall:
1. Establish yearly schedules and conduct vulnerability
assessment and penetration testing of:
a) Entity’s system, network, infrastructures and
environment
b) Web and mobile applications accessible over internet
c) Connected medical devices.
2. Establish processes to conduct security testing and
authorization by authorized business and security
stakeholders for all new deployment and changes to
Advanced
information assets prior to production roll-out and/or use
Co-operate with DoH during DoH vulnerability Service Provider
assessment activity and ensure to provide all required
information.
3. Establish processes to mitigate and manage identified
findings and vulnerabilities
4. Share reports on identified findings and vulnerabilities
and the status of mitigation with entity’s management
5. Define timelines for tracking remediation of the identified
technical vulnerabilities
6. Periodically follow up on the progress and status of
mitigation measures with the appropriate stakeholders
7. Verify effectiveness and efficiency of mitigation measures
by performing revalidation assessment
70
CO 7.2 The entity shall ensure that assessment data is not available
with third parties engaged to conduct assessments beyond the
time of engagement
The entity shall:
1. Ensure that system, network, applications, devices,
equipment and security related information is shared
with third parties when they are on-site
2. Ensure that all information related to the entity’s system, Advanced
network, applications, devices, equipment and security Service Provider
infrastructures and environment and assessment
outcomes are erased from the involved third party’s
assets and environment after the completion of the
assessment activity
3. Ensure that all shared reports are suitably protected and
controlled
71
CO 8 Patch Management
Control Criteria
Control Demands
Basic/Transitional/Advanced
CO 8.1 The entity shall define and establish formal procedures for
updating and patching of information system and application,
medical devices and equipment
The entity shall:
1. Restrict the usage of obsolete
software/technology/medical devices/ equipment
2. Ensure all systems and devices that process or
communicate information are timely patched and
protected
3. Define criteria and process for application of standard,
urgent and critical patches
4. Ensure all critical security patches are applied as soon as Basic
practicable from the date of release. Service Provider
CO 8.2 The entity shall have mechanisms in place to keep track of the
Advanced
patches and updates
72
CO 9 Information Exchange
73
CO 9.2 The entity shall follow secure practices and capabilities for
health information exchange.
The entity shall:
1. Ensure health information is not transacted through
medium of mails., unless it is being shared with the data
subject.
2. Maintain chain of custody for information while in transit.
3. Connectivity with DoH (AD Healthcare Net) and provide
all required information.
4. Ensure secure integration of Electronic Medical Records
(EMR) platform to Abu Dhabi Health information
Exchange Platform (Malaffi)
5. Ensure that entity resources are given access to Malaffi
with the proper authorization and based established
need to provide healthcare services
6. Ensure health information (in any form) PII and PHI or its
copy is not stored, shared, processed, disseminated
and/or transferred outside UAE, except in cases where a
Basic
valid and specific exemption is issued by DoH is in place
Service Provider
7. Ensure that employees of the entity and third-party
involved in service delivery of any kind, fulfill their
responsibilities and provide assistance from within the
Health Sector Stakeholder premise, and from within UAE,
unless a valid exemption has been issued by the
Department of Health (DoH)
8. Not share identified or de-identified health information
with third parties, data processors inclusive of
counterparts and partners, unless authorized by
Department of Health
9. Ensure that information exchanged between entities, and
information sharing communities are protected
10. Ensure that username and password are communicated
using two different communication channels (email and
SMS-text, or email and phone, etc.)
11. Encrypt critical information before transferring and
ensure sharing decryption key using a different
communication channel
74
12. Ensure usage of appropriate interoperability standards
for the exchange or transfer of information between
systems and custom-developed applications
13. Identify and implement security requirements for
exchanging information and software with third parties
CO 9.3 The entity shall establish agreements between the entity and
the external parties for the exchange of information and
software
The entity shall, prior to the beginning of exchange of
information and software:
1. Brief and agree with the external parties on all security
requirements to be included in the agreement with
regards to the criticality and classification of the
information to be exchanged
2. Agree on the process of notifying sender of transmission,
dispatch and receipt
3. Clearly define roles and responsibilities of each party to
the agreement
4. Establish non-disclosure agreements for all disclosures
5. Agree on the expiration date of the agreement Basic
Service Provider
6. Include in the agreements:
a) Definitions of information to be protected
b) Classification of information to be shared
c) Security requirements to be considered for
information protection
d) Duration of agreement
e) Process for notification of leakage or incident
f) Ownership for data protection
g) Right to audit and monitor activities that involve
health information and personally identifiable
information
h) Control requirements in handling the information in
line with the defined asset handling policy
75
CO 9.4 The entity shall protect physical media containing information
during transit
The entity shall:
1. Identify and ensure that physical media containing
sensitive information is classified and labelled in
accordance with the established classification scheme
2. Ensure that physical media in transit containing sensitive
information is protected against:
a) Information disclosure or leakage
b) Loss of information or media
Basic
c) Modification Service Provider
d) Unauthorized access
3. Ensure that physical media in transit containing sensitive
information is adequately tracked
4. Ensure information in removable media is encrypted
before transit
5. Utilize trusted entity staff or courier service for
transporting media
6. Ensure that media is controlled and disposed as per the
relevant policy
CO 9.5 The entity shall restrict the usage of public domain email
Basic
address for any official purposes and ensure email IDs possess
Service Provider
email domains within the UAE
76
CO 9.6 The entity shall protect information involved in electronic
messaging
The entity shall:
1. Identify and categorize all means of electronic messaging
through which the entity information can be transmitted
2. Define specific control requirements for each identified
category of electronic messaging
3. Ensure exchange of information is based on need and are
addressed to authorized and legitimate resources Transitional
4. Ensure restrictions are implemented regarding
forwarding of communications (e.g., automatic
forwarding of electronic mail to external mail addresses),
as applicable
5. Ensure appropriate electronic signatures containing legal
disclaimers are used for electronic messaging
6. Educate employees about the best practices to be
followed for electronic messaging
77
CO 10 Electronic Commerce
Control Criteria
Control Demands
Basic/Transitional/Advanced
78
CO 10.3 The entity shall protect information available through the
publicly accessible system
The entity shall:
1. Identify all information available through the publicly
accessible system
2. Establish process to publish and maintain information on
the publicly accessible systems
3. Ensure information is sanitized and approved before
publication Advanced
4. Define security measures to publish information on
publicly accessible systems
5. Ensure that information available through the publicly
accessible system is always available and is protected
against unauthorized modification
6. Ensure non-public information is not available on publicly
accessible information systems and systems are hosted in
compliance with the applicable laws and regulations
79
CO 12 Network Security Management
Control Criteria
Control Demands
Basic/Transitional/Advanced
CO 12.1 The entity shall ensure that all networks and supporting
infrastructures are adequately managed, controlled and
protected
The entity shall:
1. Ensure that all network components and
interconnections are identified and sufficiently
documented, including documentation of updates and
changes incorporated via the change management
process
2. Ensure that network documentation includes up to date
network architecture diagrams and configuration files
of devices (e.g., routers, switches) Basic
3. Prohibit the use of insecure protocols like FTP, Telnet Service Provider
and use only secure protocols such as HTTPS, SFTP
4. Ensure information assets operate with only minimum
needed TCP/UDP ports and disable all
unused/vulnerable ports, services and protocols
5. Identify threats and vulnerabilities affecting network
components and network as a whole
6. Implement specific security controls to mitigate
identified vulnerabilities
7. Continually monitor implemented controls for their
efficiency and effectiveness
80
CO 12.2 The entity shall segregate physical, logical and wireless
networks based on criticality, nature of services and user
information systems
The entity shall:
1. Establish criteria for network segregation.
2. Establish and maintain appropriate network security
zones, allowing data flow through controlled path
3. Establish minimum and specific security requirements
for each of the segregated networks, zones and
Transitional
resources
4. Ensure medical device and equipment network and
Remote Patient Monitoring network is segregated from
corporate network
5. Implement network segmentation and access control
policy to allow permitted traffic to selected network
devices.
6. Periodically evaluate the adequacy of implemented
segregation strategy and identify areas of improvement
CO 12.3 The entity shall ensure that all wireless networks are
adequately protected
The entity shall:
1. Conduct site survey to determine the optimal physical
location for the placement of wireless access-points or
devices to avoid stray signal leaking outside the entity’s Basic
physical boundary
2. Ensure that wireless access points are configured to use
strong authentication and cryptographic methods
3. Ensure public and guest access are segregated and
isolated from the entity’s internal network
81
6. Data Privacy and Protection
Entities generate and utilize Personally Identifiable Information (PII) and/or Protected Health Information
(PHI) and establish relations with individuals to give the information a persistent value during its lifecycle of
usage and references. It is imperative that, entity implements controls to prevent the inappropriate,
unintentional, unauthorized or illegal disclosure of any PII and PHI/PHI and to ensure that this standard is
being followed.
PII and PHI are comprised of diverse range of data, including but not limited to:
a) Patient demographic data and general identifiers such as name, address, birth date, mobile
number, Emirates ID, Email Address, Image, Vehicle number/License plate, Biometric data, IP
Address etc.
b) Information on past, present or future physical or mental health condition and the provision
of health care to the patient, or details of medical insurance
d) Medical record number, Medical reports / records (Imaging/radiology and Lab reports,
Prescriptions, Vaccinations record, Diagnostic reports) whether it is in electronic or paper
format
e) Information about any organ donation to/by patient, any body part or any bodily substance
of that patient, or derived from testing or examination of body part
Objective:
To maintain privacy and ensure the security of PII and PHI in order to retain public confidence in the
government's interests and values and to maintain entity reputation while providing healthcare services.
Supporting or dependent entity policy references:
i. Information Security Policy
ii. Acceptable Usage Policy
82
DP 1 Privacy and Protection Practices
Control Criteria
Control Demands
Basic/Transitional/Advanced
DP 1.1 The entity shall develop, enforce and maintain a data privacy
policy that ensures management’s commitment to protect
privacy of PII and PHI generated, collected and processed by
the entity
The policy shall:
1. Define requirements on;
a) Data Generation
b) Data Collection
c) Data Processing
d) Data Security
e) Data Localization Basic
Service Provider
f) Data Disclosure
g) Data Retention
h) Data management
i) Data Subject
2. Identify and define government sanctions and legal
obligations.
3. Include reference to organizational disciplinary
process.
4. Include references to other policies and procedures,
as applicable
83
DP 1.2 The entity shall implement measures to take consent from data
subjects in the decision-making process while processing their PII
and PHI
The entity shall:
1. Restrict from processing PII and PHI without the consent of
the data subject, except for:
a) Processing shall be necessary to protect public interest.
b) Processing shall be related to PII and PHI which became
available and known by all by the act of the data subject.
c) Processing shall be necessary to establish or defend any
of the procedures for claiming or defending rights and
legal claims or related to judicial or security procedures.
Basic
d) Processing shall be necessary for the purposes of medical
Service Provider
diagnosis, provide health treatment, health insurance
services, manage health systems and services in
accordance with the applicable legislation.
e) Processing shall be necessary to protect public health and
include protection from communicable diseases and
epidemics or for the purposes of ensuring the safety and
quality of health care, medicines, drugs and medical
devices in accordance with the applicable legislation.
f) At the written request of the patient (UAE national or
non-national) not residing in UAE and getting non-
emergency medical services as a medical tourist in a
healthcare facility licensed by Department of Health, Abu
Dhabi
84
g) At the request of the regulatory body(ies) for the
purposes of inspection, supervision and protection of
public health.
h) Information exchange with Malaffi
i) Processing shall be necessary to protect the data subject
interests.
j) Processing shall be necessary to implement specific
obligations in line with applicable legislation.
k) Processing shall be necessary for the completion of
employment related activities.
2. Collect and store informed consent by the data subject or
his/her designated representative.
3. Ensure the consent is prepared in clear, simple, and
unambiguous way and is easily accessible (written or
electronic)
4. Include right of data subject to withdraw or modify the
consent to stop further processing of data
DP 1.3 The entity shall ensure Lawful, Fair and Transparent Processing of
PII and PHI
The entity shall:
1. Ensure to have an appropriate lawful basis (or bases if more
than one purpose) for processing personal data.
2. Collect sufficient and limited PII and PHI, necessary in
accordance with the purpose for which the processing has to
be carried out.
3. Implement measures to ensure that PII and PHI is not issued
Transitional
in a manner incompatible with the purpose.
Service Provider
4. Implement controls to ensure accuracy of PII and PHI
throughout lifecycle with measures for updating it, as
requested by data subject.
5. Implement controls for deletion of PII and PHI after the
purpose of processing has been exhausted or in line with
entity retention policy
6. Ensure compliance with requirements of applicable privacy
laws and regulations
85
DP 1.4 The entity shall implement appropriate technical and organizational
measures for maintaining security and privacy of PII and PHI
throughout its lifecycle.
The entity shall:
1. Implement information security policies, procedures, and
technical controls in accordance with the requirements of this
standard and the risks associated with processing PII and PHI.
These include but not limited to:
a) System controls: User access measures (E.g.: Physical and
Logical Access Controls), Network Security, Data Security,
Data concealment etc.).
b) Process controls: Data classification policies, data backup
and retention policy, compliance audits etc.
c) People controls: Signing of Non-Disclosure Agreements
(NDAs) and Data Processing Agreements (DPAs),
Trainings, awareness, Employee background checks, and
/ or any other project specific requirements.
2. Ensure printing of PII and PHI is limited to local printers and
avoid printing through uncontrolled printers
Basic
3. Ensure that only people who are physically present in the UAE Service Provider
or who have a valid license issued by DoH to practice their
profession there, have access to systems and applications
that contain PII and/or PHI. Any exemptions must be
approved by entity management and then submitted to the
DoH for approval.
4. Ensure health information and its copies in any form, whether
encrypted, anonymized, deidentified, pseudonymized, etc.,
are not stored, processed, or transferred outside the UAE.
Any exemptions must be approved by entity management
and then submitted to the Department of Health (DoH) for
further approval.
5. Access to health data shall be limited to healthcare
professionals, insurance processing individuals and/or
breach/compromise investigating individuals.
6. Access to health information, inclusive of personal health
information and personally identifiable information, by
healthcare professionals shall be based on established need
(e.g., Encounter with a patient) and for the purpose of
healthcare service delivery only.
86
DP 1.5 The entity shall prepare Data Processing Inventory to keep track of
PII and PHI stored, processed and managed and conduct Data
Privacy Impact Assessment (DPIA) before implementing or
acquiring information technology that stores, process, or transfers
PII and PHI and/or before initiating any processing activity if it is
likely to result in high risks
The entity shall:
1. Ensure that the Data Processing Inventory captures
information including but not limited to:
a) Description of the categories of PII and PHI
b) Details about the data subject
c) Individuals authorized to access personal healthcare
d) Period, purpose, limitation and scope
e) Details about data exchange/transfer
f) Mechanism of transfer, deletion, modifying or processing
g) Data related to the cross-border movement, if any Advanced
h) Technical and organizational measures related to
information security and processing operations
2. Ensure DPIA template includes at a minimum of the following:
a) Documented necessity, suitability and purpose of
proposed processing operations
b) Assessment of potential risks and impacts on the security
of PII and/or PHI
c) Documented plan of action to mitigate the risks and
ensure security of PII and/or PHI
d) Keep the Data Processing Inventory updated and
periodically review DPIA output to assess the processing
operations
3. Conduct a DPIA reassessment in response to changes in the
risks associated with the processing activity
87
DP 1.6 The entity shall implement measures to ensure that the involved
third parties and/or data processors have controls in place for PII
and PHI
The entity shall:
1. Only appoint a third party and data processor that has
sufficient technical and organizational measures that fulfil
the secure processing requirements
2. Document security requirements within the third-party
service level agreements
3. Address requirements in case of sub-contracting through Basic
contracts and service agreements Service Provider
4. Ensure the third party / data processor processes data only
for agreed purpose and duration and deletes the data once
purpose is accomplished
5. Ensure the third parties and data processor notify the entity
in case of:
a) Appointment of sub-contractors
b) Security incident and data breach
c) Processing PII and/or PHI beyond agreed time-period
88
DP 1.7 The entity shall ensure that PII and PHI breaches are detected,
reported, prioritized and handled effectively
The entity shall:
1. Inform DoH about breach at the entity and/or the relevant
third party/data processor within predetermined timelines.
Refer: Guidelines for the Implementation of the Abu Dhabi
Health information and Cyber Security Standard – IM 2 -
Information Security Incident Reporting matrix
2. Ensure the breach notification and further updates to DoH
include all information, as requested by DoH
3. Complete and submit the "Data Breach Form" in addition to
submitting incident notifications and updates. This form
shall be shared with the DoH within 72 hours of Basic
acknowledging the incident. Refer: Guidelines for the Service
Implementation of the ADHICS – Section 5- Data Breach Provider
Form
4. Document all evidence pertaining to data breaches
investigation and resolution and provide DoH with the
requested information within 30 working days after the
initial reporting
5. Inform the affected data subject about the breach including
the level of impact/damage and the measures undertaken
for correction and prevention, in case of a breach that is
likely to result in high risk to the data subjects
6. Entity Management shall establish process and controls to
minimize probabilities of data breaches, and are accountable
for any data breach involving their entity
89
DP 2 Appointment of Data Protection Officer
Control Criteria
Control Demands
Basic/Transitional/Advanced
DP 2.1 The entity and the involved data processor shall appoint a Data
Protection Officer (DPO) with sufficient skills and knowledge to
protect protected health information if:
a) Entity is processing large volumes of PII and PHI
b) There is high risk due to automated and processing
through technologies.
c) Entity is performing profiling and comprehensive Advanced
assessment of PII and PHI
The entity shall:
1. Ensure there is no conflict of interest between the DPO’s
role, and the tasks assigned
2. Ensure contact address of the data protection DPO is well
communicated to all Data Subject
90
DP 3 Data Subject Rights
DP 3.1 The entity shall ensure protection of data subject rights while
processing their PII and PHI
The entity shall:
1. Fulfil data subject’s request for:
a) Obtaining information about their PII and PHI i.e.,
Type of processing, purpose of processing, sharing of
data, security controls, breach management process
etc.
b) Transferring of their PII and PHI (to the data subject /
another data controller)
c) Correction and deletion of their PII and PHI
d) Restriction on further processing of their PII and PHI
or retaining the data for defending rights and lawsuits
e) Objection to results of automated data processing and
profiling
2. Keep records of PII and PHI information sharing and
disclosures Transitional
Service Provider
3. Based on request from the data subject, Transfer the PII
and/or PHI to the data subject in machine-readable format
4. Reject data subject’s request to exercise its rights, if the
following becomes evident:
a) Request is inconsistent with the judicial procedures or
investigations or matters of public interest
b) Deletion of data request conflicts with any applicable
legislation to which the entity is subjected to
c) Request may negatively affect the efforts of the
controller to protect information security
d) Restriction request conflicts with consent Exemption
conditions
e) Request violates the privacy and confidentiality of
others personal data
f) Prior contract or consent is available for automated
processing
91
7. Cloud Security
Cloud services and resources provide entities with options for quick adaptation and scalability. Its critical,
that foundational and essential aspect of security control are considered from the concept stage to better
handle threats, technological risks, and protections of cloud environments
Entity shall implement procedures, personnel, physical and technical controls through their cloud journey,
to ensure security of cloud-based data, applications, infrastructure.
Objective:
To ensure security while using cloud resources, and minimize probabilities of data compromises
Supporting or dependent entity policy references:
i. Access Control Policy
ii. Communications and Operations Management Policy
92
CS 1 Cloud Security Policy
Control Criteria
Control Demands Basic/Transitional/Advanc
ed
CS 1.1 The entity shall develop, enforce, and maintain a Cloud Security
Policy to protect the confidentiality, integrity and availability of all
IT applications, data, systems and network resources implemented
in a cloud environment and ensure cloud services are acquired,
used, managed, and terminated in conformity with all applicable
laws and regulations.
The policy shall:
1. Be relevant and appropriate to the entity’s cloud security
demands and applicable legal and regulatory compliance
requirements
2. Demonstrate management commitment, objectives and
directions
Basic
3. Establish a process that facilitates:
a) Selection of suitable cloud service provider and scope of
cloud services usage
b) Identification of suitable information security
requirements
c) Signing of Service Level Agreements (SLAs) and Non-
Disclosure Agreements (NDAs)
d) Assignment of roles and responsibilities related to use
and management of cloud services
e) Agreement on data retention, portability and destruction
requirements
93
CS 1.2 The entity shall identify and ensure implementation of information
security controls to protect their cloud environment against evolving
threats and risks:
The entity shall:
1. Implement the Shared responsibility model for information
security of the cloud and ensure that the duties for managing
information security in the cloud are assigned to recognized
parties, effectively communicated, and executed
2. Ensure cloud environment is physically hosted within UAE
without any of the environments, infrastructures, or systems
outside the country including backup and disaster recovery
3. Ensure data/health information stored in cloud is not extended
for access, use or support by;
a) Any other entity/party in a multi-tenant environment.
b) Any entity/party that provides analytical services, where the
data or copy of data is transferred/sent outside country
c) Any entity/party that provides remote support from outside
UAE
Transitional
4. Ensure data-at-rest, data-in-transit/motion is always encrypted Service Provider
5. Ensure the key used to encrypt data-at-rest and data-in-
transit/motion is not provided by the cloud service provider who
provides the application, infrastructure and data hosting services
6. Protect data during processing in a cloud environment
7. Procure cloud service that provides feature to generate or
configure entity’s own cryptographic keys to be used for
applications and services in cloud
8. Ensure the cloud service provider does not store and control the
entity's cryptographic keys
9. Ensure role-based security training and awareness is provided to
the resources handling cloud environment
10. Engage independent external party to conduct testing of service
design, service components and implemented security controls in
the cloud
11. Ensure procedures are in place for ease of migration/portability
for on-prem to cloud and cloud-to-cloud infrastructure, as
required
94
12. Procure cloud service that provides feature to generate or
configure entity’s own cryptographic keys to be used for
applications and services in cloud
13. Identify security requirements and ensure implementation of
controls including but not limited to:
a) Secure protocols, industry standard encryption for protection
of data at rest, transit & processing
b) Logical segregation, access control and logging and
monitoring of activities
c) Controls for change management assuring adherence to the
entity’s change management policy
d) Physical security and environmental controls for natural
disasters, malicious attack or accidents
e) Identification of misconfigurations and vulnerabilities on
periodic basis
f) Data Backup, redundancy and recovery, based on business
criticality and impact assessment
g) Ongoing maintenance, patching and upgrades, as required
h) Incident management and Forensics requirements
95
8. Third Party Security
Third Party security is critical to ensure all external stakeholders comply with entity and regulatory demands
on information security, and have implemented and maintaining essential security requirements to aid in
secure delivery of services, and to ensure information stored, processed, and retrieved are secure and
protected always
Entity shall ensure adequate due diligence is applied to all contractual activities and services, as well as
proactive identification and definition of control environment to secure entity’s information assets
A healthcare entity’s management shall be aware of the risk environment related to third party services and
resources, and shall establish a suitable framework for third party management and define a control
environment that shall:
a) Reduce probabilities of information compromise
b) Secure information assets
Objective:
To ensure third party services are controlled through suitable procedural obligations and contractual terms
to ensure privacy and protection of information assets.
Supporting or dependent entity policy references:
i. Information Security Policy
ii. Access Control Policy
96
TP 1 Third Party Security Policy
TP 1.1 The entity shall develop, enforce and maintain a third-party security
policy to facilitate implementation of the associated controls and to
reduce probabilities of risk realization concerning third parties.
The policy shall:
1. Be relevant and appropriate to the relationship of the entity
and the third party
2. Outline roles and responsibilities for managing the third party
3. Establish a process that facilitates:
a) Security due diligence of third-party services before
appointment
b) Secure management of third-party services and their role
Basic
in healthcare and/or related services
c) Defining and including information security objectives in
line with applicable mandates and/or requirements of
entity
d) Third party briefing of security requirements
e) Security requirements for sub-contracting
f) Signing service delivery agreements & non-disclosure
agreements (NDAs) with third parties SLA definition and
Performance monitoring
4. Demonstrate management’s commitment, objectives and
directions
97
TP 2 Third Party Service Delivery and Monitoring
98
9. Identify and include Right-to-Audit terms specific
to the provisions and environment of service
management to manage information security risks
10. Coordinate with entity contract management and
legal teams for third party service requirements
that needs the storing, processing and
transmission of health and/or personally
identifiable information
11. Ensure agreement includes termination clauses
and transition support required from the third-
party during entity decision to exit agreement
and/or use another service/solution
12. These clauses shall cover at minimum below
requirements:
a) Data conversion to a standardized format by
Basic
the third party, based on industry standard
Service Provider
and agreement with healthcare entity
b) Removal of data from all third party’s
environment, after an agreed period of time
c) Migration of data to entity’s environment
d) Handover of all backup copies of data to the
healthcare entity
e) Disconnecting all existing integration on behalf
of the healthcare entity
f) Cooperation with the new onboarded third
party (if any) for the required integration and
data migration
g) Knowledge handover to the new third party or
the healthcare entity’s stakeholders, based on
an agreed approach
99
TP 2.2 The entity shall monitor, and review services provided,
reports and records submitted by third parties
The entity shall;
1. Monitor compliance of security requirements
identified in agreements with third parties
2. Conduct security assessments and audits in
accordance with this standard's applicable
mandates and the entity's information security Advanced
needs
3. Implement controls for authenticating and
monitoring the exchange of information between
various parties to ensure security compliance
4. Assess and manage business, commercial,
financial and legal risk associated with third party
services
100
9. Information Systems Acquisition, Development, and Maintenance
Entity management shall implement appropriate information systems acquisition, development, and
maintenance process to avoid unauthorized alteration or misuse of information/configurations in
applications, to maintain security during the in-house and outsourced development lifecycle and support
procedures, and to assure protection of data used for testing. Based on detailed assessment and entity risk
appetite, the entity’s management shall choose from one of the below options:
a) In-house development, maintenance and support of application and systems
b) Outsource the development, maintenance and support of application and systems
c) Out-of-shelf product deployment, maintained and supported by the vendor
d) Cloud-based application utilization
e) Hybrid approach for the development, maintenance, and support requirements
Objective:
To emphasis the need for adoption of secure system and software development lifecycle management
processes and to ensure that systems and applications in use are securely managed and supported to avoid
misuse of privileges and authority, reduce probabilities of information, system and application
compromises, and to uphold entity and Abu Dhabi government’s reputational value and public trust.
Supporting or dependent entity policy references:
i. Access Control Policy
ii. Communications and Operations Management Policy
101
SA 1 Information Systems Acquisition, Development, and Maintenance Policy
102
SA 2 Security Requirement of Information Systems and Applications
103
SA 2.2 The entity shall ensure developer of information systems, system
components or information system services are provided suitable
training prior to their involvement in development activities
The entity shall:
1. Identify baseline training requirements that are essential
for the developer
2. Acknowledge that developer(s) received relevant baseline Advanced
training prior to their involvement in development activities
3. Identify training requirements based on implemented
security functions and features
4. Design and execute training programs to address additional
and future security requirements
5. Include training requirement in agreements when the
requirements are delivered and managed by third parties
104
Control Demands Control Criteria
Basic/Transitional/Advanced
SA2.4 The entity shall ensure that all distributed and mobile applications
are designed with the ability to tolerate communication failure
Distributed and mobile applications shall: Transitional
Service Provider
1. Include off-line and duplicate or out-of-sequence response
message handling capabilities
105
SA 3 Cryptographic Controls
SA 3.1 The entity shall ensure cryptographic controls are used effectively
to protect health information based on the needs of regulatory
requirements and risk environment.
The entity shall:
1. Use encryption for the protection of information stored and
transmitted within and outside entity.
2. Establish key management process to:
a) Securely generate and use cryptographic keys for
applicable systems and applications.
b) Securely share keys with authorized users
c) Protect keys against modification, loss and destruction Transitional
Service Provider
d) Set date of activation and deactivation for keys
e) Revoke/block keys, as needed
f) Backing up or archiving keys
g) Recover keys that are lost or corrupted
h) Replace keys when they are weakened or compromised
i) Monitoring of key management related activities
3. Define standards for:
a) Key strength for various environments
b) Key storage
106
SA 4 Security of System Files
SA 4.2 The entity shall protect system test data and restrict access to
program source code
The entity shall:
1. Use sample data sets to test application, business and
security functionalities
2. Restrict the use of real data from production systems for
testing,
3. Ensure health information is anonymized before being made
available for testing and training purpose. Transitional
4. Maintain records of copying, using and erasing of Service Provider
operational information in test environment
5. Ensure that personally identifiable information is not used
as test data
6. Erase any data from test applications immediately after
completion of the test
7. Ensure that access to program source code is strictly based
on need and is in compliance with entity access control
policy
107
SA 5 Outsourced Software Development
SA 5.1 The entity shall supervise and have control over outsourced
software development
The entity shall:
1. Ensure that the outsourced development adheres to secure
engineering principles and the entity holds sole custody of
the source code and source code backups.
2. Define acceptance and quality assurance processes
3. Include in the outsourced software development agreement
the requirement to comply with:
a) All relevant entity policies, including information security
and quality related policies, requirements and
functionalities
Transitional
b) Provisions of this Standard Service Provider
c) Regulatory and legal requirements
d) Industry specific secure coding practices
4. Include in the agreement the right to audit clause
5. Conduct source code review, security assessments to identify
potential vulnerabilities, back-door and malicious code
6. Control the number, rotation and termination of staff
involved in outsourced development activities to restrict:
a) Unauthorized access
b) Leakage of information
c) Information compromise
108
SA 6 Supply Chain Management
109
b) Non-disclosure requirements
c) Terms to comply with entity information security
policy and requirements
d) Terms to comply with relevant federal and local
government requirements
UAE IAR Reference: T7.8.1, T7.8.2, T7.8.3, T7.8.4, T7.8.5, T7.8.6, T7.8.7
110
10. Information Security Incident Management
Entity’s management shall be aware that information security incidents may not always be preventable,
the frequency, severity, and impact on an entity's assets, reputation, financial situation, and legal standing
can all be reduced with the implementation of suitable policies, processes, and technology for detection,
reporting, and handling, together with education, awareness, and training.
Information security incidents shall be reported, and evidence of security incidents shall be collected and
analyzed to ensure that information security events and weaknesses are properly communicated and
security incidents adequately managed.
Objective:
To ensure that entity define and utilize suitable processes and resources to identify and respond to
information security and privacy incidents, that they are not severely impacted by incident outcomes and
that they are able to restore affected operations within an acceptable timeframe.
Supporting or dependent entity policy references:
i. Access Control Policy
ii. Communications and Operations Management Policy
iii. Third Party Security Policy
111
IM 1 Information Security Incident Management Policy
112
IM 2 Incident Management and Improvements
113
IM 2.2 The entity shall establish a Computer Security Incident
Response Team (CSIRT) or equivalent responsible for
incident management and response efforts
The entity shall:
1. Establish CSIRT organization with adequate
authority, essential roles and responsibilities
2. Identify and nominate competent resources for
each identified role of the CSIRT
3. Establish communication and response protocols
4. Allocate adequate funds for CSIRT operations
5. Ensure CSIRT coordinates with its counterparts
and DoH for incidents which have significant
impact on the entity’s assets or operations.
6. Conduct information security forensic analysis, as
required
7. Participate in forensics and the national incident
response effort, as required
Advanced
8. Identify impactful reoccurring incidents and
implement controls to reduce the recurrence
9. Ensure lessons learnt from past information
security incidents are maintained and shared with
relevant stakeholders to aid in:
a) Addressing future information security
incidents
b) Minimizing the recurrence of such
incidents
10. Build knowledge database on information security
incident diagnosis and response.
11. Provide suitable training to members of the CSIRT
to cover:
a) Past incidents and lessons learnt
b) Current threat environment of the entity
c) New threats and attack trends across the
world
114
IM 2.3 The entity shall assess and classify information security
incidents
The entity shall:
1. Establish an incident classification scheme which
captures the requirements of matrix
recommended by DoH. Refer: Guidelines for the Transitional
implementation of the Abu Dhabi Health
information and Cyber security Standard – IM 2 -
Information Security Incident Classification
2. Define workflows to handle incidents of various
classifications/severity
115
IM 2.5 The entity shall document and preserve records on all
information security incidents.
The entity shall:
1. Identify all relevant data and evidence to be
collected during and after realization of an
information security incident.
2. Establish procedures for collecting evidence
considering the:
a) Chain of custody
b) Safety of evidence
c) Safety of personnel
d) Roles and responsibilities of personnel Transitional
involved
e) Competency of the personnel
f) Documentation
g) Briefing
h) Other identified requirements
3. Prepare a damage assessment report
4. Conduct a post incident analysis and implement
controls identified as recommendations
5. Preserve documents, records, reports and
evidences in compliance with the entity’s
retention policy
UAE IAR Reference: T8.2.1, T8.2.2, T8.2.3, T8.2.4, T8.2.5, T8.2.6, T8.2.7, T8.2.8, T8.2.9, T8.3.2, T8.3.3
116
IM 3 Information Security Events and Weakness Reporting
117
11. Information Systems Continuity Management
Entity shall have proactive strategies and plans in place to counteract interruptions to entity operations
and to protect critical business operations and processes from the consequences of significant
information system, medical device and/or equipment failures to enable timely resumption of affected
processes.
Objective:
To ensure systems, applications and resources are available to support service continuity requirements of
identified critical services and processes during adverse situations or environment.
Supporting or dependent entity policy references
i. Incident Management Policy
ii. Business Continuity Policy
v. Compliance Policy
118
SC 1 Information Systems Continuity Management Policy
119
SC 2 Information Systems Continuity Planning
SC 2.1 The entity shall conduct Business Impact Analysis (BIA) to capture
information necessary to predict the impact of a critical information
systems medical devices, equipment and application failure and
gather information to define the strategies to mitigate or minimize
the risk
The entity shall:
1. Perform Risk Assessment to identify points of failure and
understand likelihood, impact in time for identification and
Advanced
prioritization of critical Information systems
Service Provider
2. Determine the criticality of information systems and their
need for recovery
3. Establish Recovery Time Objective (RTO) and Recovery Point
Objective (RPO) to resume activities timely and effectively
4. Identify dependencies between services and supporting
resources (facilities, personnel, equipment, software, data
files, system components, and vital records)
120
SC 2.2 The entity shall develop Information Systems Continuity and
Recovery plans that shall prevent or minimize interruptions and
support in recovery of critical information assets and services
during adverse situations
The plan shall:
1. Enlist information systems, medical devices, equipment and
applications in scope of continuity plan
2. Identify continuity requirements for recovering from events
that affect availability of critical information assets and
services Have recovery strategies for critical information
assets to minimize the period and impact of disruption
3. Be harmonized and support organizational business
continuity planning and/or disaster recovery demands
Advanced
4. Identify individuals with assigned roles and responsibilities,
Service Provider
along with necessary contact information
5. Define call tree matrix and escalation matrix
6. Defined criteria and conditions for plan activation
7. Have provisions to address information security incident-
based scenarios and provide guidance to operate and
support critical business services during such scenarios
8. Ensure required level of continuity for information security
during disruption
9. Consider redundant system, components or architectures
for critical business services, processes and technology,
wherever availability cannot be guaranteed using the existing
systems architecture
121
SC 2.3 The entity shall test, reassess, and maintain its information systems’
continuity plans at planned intervals or in case of any significant
change, to ensure that they are up to date and effective.
The entity shall:
1. Define schedules and test information system, medical
devices, equipment’s and application continuity plans to
ensure:
a) Adequacy and effectiveness of the plans
b) Entity and resource readiness to execute the plans Advanced
2. Conduct fail over testing to check the efficiency of redundant
information systems
3. Document test outcomes and lessons learned
4. Assess plan adequacy during changes to business services,
systems and applications
5. Update and maintain information system and application
continuity plans based on lessons learned and assessment
outcome
122
4.Key stakeholder Roles and Responsibilities
The entity shall be committed and responsible to address all information and cyber security risks to its
environment. The entity shall invest time, efforts, and resources to remediate and reduce the impact of
risks to maintain a secure and trusted environment and practices.
Based on their job assignment or association, everyone associated (including any external stakeholders,
third parties/ contractors/vendors) with the entity has certain responsibilities to maintain day-to-day
security of the Entity’s environment, services, systems, and information. Main responsibilities of the
involved stakeholders/parties concerning Abu Dhabi Healthcare sector are listed below:
Stakeholder Responsibility
a) Establish ADHICS.
b) Enforce ADHICS Standard for Abu Dhabi Healthcare sector, covering all in
scope entities, healthcare professional(s) and support staff who have access
to patients’ health/diagnostic/personal information.
c) Maintain ADHICS Standard, based on learning and industry evolution.
d) Review entity’s mandatory self-assessment reports (shared by entity) and
recommend improvements towards achieving compliance, and escalations
where relevant Conduct review meetings with entities to enhance
Department of
cybersecurity and maintain compliance.
Health
e) Develop the sector risk profiles and sector level improvement plans derived
from the risk mitigation/treatment actions and report to relevant Local and
Federal authorities.
f) Conduct information security audits of entities periodically in line with
requirements of this standard.
g) Provide sector specific inputs to the National cyber threat intelligence
initiatives and work in collaboration with National Authorities.
h) Establish and maintain sector HIIP.
123
progress to entity management and Abu Dhabi Healthcare sector – HIIP
Chairperson.
d) Educate business users and conduct periodic Information Security and data
privacy awareness trainings/sessions.
e) Ensure security requirements are adequately addressed during the design,
development, implementation, and maintenance of any existing or new
information systems.
f) Maintain system accreditation and compliance as per policy.
a) Adhere to and comply with ADHICS Standard, and Entity policies and
demands.
Entity Business /
b) Align business processes as per information security demands of the entity.
End User
c) Participate in all applicable information security training and other awareness
programs organized by the entity.
124
5.Monitoring and Evaluation
The entity shall establish robust monitoring to track and evaluate compliance with the standard. Reliable
metrics and measurements to be utilized to assess the effectiveness of compliance with required controls.
The entity will periodically report compliance status, deviations, and risks to DoH. Risk(s) related to non-
compliance shall be recorded and managed appropriately. Regular internal audits and assessments shall be
conducted to validate and verify compliance with the requirements of standard. Based on the outcomes of
monitoring and evaluation activities, the entity shall establish a continuous improvement process, adapting
to emerging threats, technology changes and evolving compliance requirements.
DoH shall conduct periodic audits and technical assessments on all regulated entities, as relevant and
applicable, to validate compliance with the requirements of standard.
In the event of non-compliance with the application of the terms of the standard, DoH can impose sanctions
in relation to any breach of requirements under this standard in accordance with the Audit Outcomes,
Complaints, Investigations, Regulatory Action and Specified Sanctions shall be applied as per the disciplinary
regulation for the healthcare sector of the Emirate of Abu Dhabi.
125
7. Relevant Reference Documents
GP Program_National IoT
4 2023 Policies (csc.gov.ae)
Security Policy
GP Program_National Cloud
5 2023 Security Policy Policies (csc.gov.ae)
Department of Health
Publications: Data Privacy & AAMEN | Department of Health Abu Dhabi
6 2020
Internet Of Medical Things (doh.gov.ae)
Standard, Circulars
https://u.ae/en/information-and-
UAE Information Assurance services/justice-safety-and-the-law/cyber-safety-
7 2020
Regulation and-digital-security/uae-information-assurance-
regulation
https://data.abudhabi/opendata/sites/default/fil
Abu Dhabi Government Data
8 2017 es/AD-Gov-Data-Management-Standards-EN-
Management Standards V2.0
v1.0.pdf
DOH Standard on
9 Draft Yet to be released
Telemedicine
126
11 2015 ISO/IEC 27017:2015 https://www.iso.org/standard/43757.html
Information Security
Governance – A Practical
[PDF] Information Security Governance by Krag
13 2009 Development and
Brotby eBook | Perlego
Implementation Approach, by
Krag Brotby
127
8. Appendices
HR 2 - Prior to Employment
HR 3 - During Employment
Service
HR 3.5 Disciplinary Process 2 Transitional M4.3.2
Provider
Service
HR 4.3 Removal of Access Rights 2 Basic M4.4.3
Provider
128
Number of Service
Control
Control Number & Control Name Sub- Provider UAE IAR Reference
Criteria
Control Controls
HR 4.4 Internal Transfers and Change of
3 Basic M4.4.3
Role
Service
AM 1.2 Allocation of Medical Assets 6 Basic
Provider
AM 2 Management of Asset
Service
AM 2.1 Asset Inventory 3 Basic T1.2.1
Provider
Service
AM 2.4 Acceptable Use of Assets 2 Basic T1.2.3
Provider
AM 2.5 Acceptable Bring Your Own Service
5 Basic T1.2.4
Device Arrangements Provider
Service
AM 3.1 Information Classification 4 Basic T1.3.1, T1.3.2
Provider
AM 3.2 Interpretation of External Entities
NA Transitional T1.3.1
Classification Scheme
AM 4 Asset Handling
AM 5 Asset Disposal
129
Number of Service
Control
Control Number & Control Name Sub- Provider UAE IAR Reference
Criteria
Control Controls
AM 5.1 Information Asset Secure Service
6 Basic T2.3.6
Disposal Provider
PE 2 Secure Areas
Service
PE 2.1 Physical Security Perimeter 5 Basic T2.2.1
Provider
PE 3 Equipment Security
Service
PE 3.1 Equipment Siting and Protection 3 Basic T2.3.1, T2.3.8
Provider
PE 3.2 Standard operating procedure for Service
2 Advanced
equipment’s Provider
Service
PE 3.4 Security of Equipment Off Site 4 Transitional T2.3.5, T2.3.7
Provider
130
Number of Service
Control
Control Number & Control Name Sub- Provider UAE IAR Reference
Criteria
Control Controls
AC 2.3 Use and Management of Security Service
10 Basic T5.2.3, T5.3.1, T5.5.3
Credential Provider
AC 4 Access Reviews
Service
Ac 4.1 Review of User Access Rights 4 Basic T5.2.4
Provider
Service
AC 6.1 Secure Log-On Procedures 4 Basic T5.5.1
Provider
AC 6.2 User Identification and Service
2 Basic T5.5.2
Authentication Provider
Service
CO 2.1 Baseline Configuration 2 Transitional T3.2.1
Provider
131
Number of Service
Control
Control Number & Control Name Sub- Provider UAE IAR Reference
Criteria
Control Controls
CO 2.4 Separation of Test, Development Service
6 Transitional T3.2.5
and Operational Environment Provider
Service
CO 3.2 System Acceptance and Testing 6 Transitional T3.3.2
Provider
CO 4 Malware Protection
Service
CO 4.1 Controls Against Malware 11 Transitional T3.4.1
Provider
CO 4.2 Gateway Level Protection for
2 Advanced T3.4.1
Malware
Service
CO 5.1 Backup Management 6 Basic T3.5.1
Provider
Service
CO 5.2 Archival Requirements 6 Advanced T3.5.1
Provider
Service
CO 6.4 Information Leakage 1 Transitional T7.6.4
Provider
CO 8 Patch Management
Service
CO 8.1 Patch Management Procedure 9 Basic
Provider
CO 9 Information Exchange
132
Number of Service
Control
Control Number & Control Name Sub- Provider UAE IAR Reference
Criteria
Control Controls
Service
CO 9.3 Information Exchange Agreements 6 Basic T4.2.2
Provider
Service
CO 9.4 Physical Media in Transit 6 Basic T4.2.3
Provider
CO 9.5 Restrict usage of Public Domain Service
NA Basic
Email Provider
CO 10 Electronic Commerce
Service
CO `12.1 Network Controls 7 Basic T4.5.1
Provider
Service
DP 1.1 Data Privacy Policy 4 Basic NA
Provider
Service
DP 1.2 Consent Collection 4 Basic NA
Provider
DP 1.3 Lawful, Fair and Transparent Service
6 Transitional NA
Processing Procedures Provider
DP 1.4 Technical and organizational Service
6 Basic M5.2.4
measures Provider
DP 1.5 Data Processing Inventory and
3 Advanced NA
Data Privacy Impact Assessment (DPIA)
Service
DP 1.6 Data Processors security 5 Basic NA
Provider
Service
DP 1.7 Data Breach Management 6 Basic NA
Provider
133
Number of Service
Control
Control Number & Control Name Sub- Provider UAE IAR Reference
Criteria
Control Controls
Service
DP 3.1 Protection of data subject rights 4 Transitional
Provider
Service
CS 1.2 Cloud Security Controls 13 Transitional T6.3.2
Provider
Service
TP 1.1 Third Party Security Policy 4 Basic T6.1.1
Provider
TP 2 Third Party Service Delivery and
Monitoring
TP 2.1 Third-Party Service Delivery Service
12 Basic T6.2.1
Agreements Provider
TP 2.2 Monitoring and Review of Third-
4 Advanced T6.2.2
Party Services
TP 2.3 Managing Changes to Third Party
3 Transitional T6.2.3
Services
SA 3 Cryptographic Controls
134
Number of Service
Control
Control Number & Control Name Sub- Provider UAE IAR Reference
Criteria
Control Controls
SA 3.1 Cryptography and Key Service
3 Transitional T7.4.1, T7.4.2
Management Provider
Service
SA 4.1 Control of Operational Software 5 Transitional T7.5.1
Provider
SA 4.2 Protection of System Test Data Service
7 Transitional T7.5.3
and Source Code Provider
Service
SA 6.1 Secure Acquisition NA Basic
Provider
Service T7.8.1, T7.8.2, T7.8.3,
SA 6.2 Supply Chain Protection Strategy 8 Advanced
Provider T7.8.4, T7.8.5
SA 6.3 Process to Address Weakness or Service
3 Advanced T7.8.6
deficiency Provider
SA 6.4 Supply of Critical Information
3 Advanced T7.8.7
System Component
Service
IM 2.1 Incident Response Procedure 8 Basic T8.2.1, T8.3.3
Provider
IM 2.2 Computer Security Incident
11 Advanced T8.2.2
Response Team
135
Number of Service
Control
Control Number & Control Name Sub- Provider UAE IAR Reference
Criteria
Control Controls
SC 1.1 Information Systems Continuity
4 Advanced T9.1.1
Management Policy
Service
SC 2.1 Business Impact Analysis 4 Advanced
Provider
SC 2.2 Developing Information Systems Service
9 Advanced T9.2.1
Continuity Plans Provider
SC 2.3 Testing, Maintaining and
5 Advanced T9.3.1
Reassessing Plans
136