Monday, 2 November 2015

Deep Dive Inspection

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Some RSLs will now be encountering the HCA IDE (In-depth AKA Deep Dive  Assessments). One of the social landlords I work with was one of the first on the list. They are really good performers and hold top ratings for governance and financials, so didn't really expect any issues. By the looks of things, the assessment went very well, with procedures all documented and visibly in-use.

When a notice is imminent it is prudent to ensure everyone knows where procedures are, even if they are actively in use. I was very interested in what the assessment looked at within the ICT area. If any of my associates from the HCA are reading this, I promise I won't let too many cats of the bag, in this post.

Not surprisingly, key areas were data protection and security. The auditors were pretty sharp on these areas, control of email and system access etc. Anecdotally one thing that was asked was "how was a failure rectified and can you show that procedures are now in place to mitigate" (or similar).

Rather than sometimes 'lightweight young internal auditors', these were very experienced inspection staff, with a good understanding of the sector and what can go wrong.

So, lessons to be learnt for IT and ICT teams possibly facing these Homes & Communities In-Depth assessments, is have your ducks in a row and know where to find them. For ducks read 'procedures' and ensure they are actively and visibly in use, particularly around security and data protection areas. These areas should be watertight anyway for IT, but think carefully about what vulnerabilities you might have.

Being open about vulnerabilities and showing a plan is in place, would score many more brownie points than just trying to hide those. One thing was clear from what I witnessed, if you have a vulnerability, this audit will reveal it. For ICT this is not a mere box ticking exercise. One more reason to run a tight ship, know what your procedures should achieve and coach staff in keeping to them, if you have the assessors in or not 8-)

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Related Post: How well do you look after your data?


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Dio - Holy DiverDio - Holy Diver.
(c) Tony Smith, Acutance Consulting 07854-655009

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