More noise with a null end result
Yeah,
I have a few observations here. The NHS already has a Marking Your Own Homework standards approach, Cyber Essentials Plus. Yet NHS Suppliers, on the whole - certainly from what I see day in day out - take absolutely no notice of many of the provisions on the whole, particularly the IT Sec ones. Another Marking Your Own Homework farce just means more lying on more forms, where's the enforcement, where are the checks. The lack of a question mark isn't a mistake, because it's a rhetorical point, not a question. They don't exist.
Something else that doesn't exist, at least as far as my CyberSec colleagues and my team have ever been able to identify is, when we identify Cybersecurity and/or governance issues - who do we inform? Because when these are raised with the suppliers themselves, the response if - 90% of the time - "Well, no-one else has complained". You can point out that you know for a fact that xyz organization has done as well, not a flying one given "Well, we're not changing it". At this point, we're out of escalation levels.
In other Government areas, a negative Cyber assessment gets the system closed down, until fixed, and this is raised with the Department to instruct all other users accordingly. Because in THOSE areas, it's taken seriously.
This proposal is dross, pointless, pretending to do something, while making damn sure that nothing ACTUALLY changes off the back of it.
No enforcement.
No effective third party assessment
No requirement to take part in order to foist your garbage off on NHS Trusts
No escalation and reporting mechanism
No central vulnerability database and dissemination path
No penalty or recovery model for breeches of the Homework You Marked Yourself
No point whatsoever.