Human Resources Security Policy (OP-POL-004)

1. Objective

The objective of this policy is to define the security requirements and procedures that govern the lifecycle of all [Company Name] workforce members. This policy ensures that individuals with access to sensitive company information, including electronic Protected Health Information (ePHI), are trustworthy, properly trained, and managed in a way that minimizes insider risk and upholds the company’s commitment to security and compliance.

2. Scope

This policy applies to all prospective, current, and former workforce members of [Company Name], including full-time and part-time employees, contractors, and temporary staff. It covers all stages of the employment lifecycle, from pre-employment screening through termination and separation.

3. Policy

[Company Name] shall implement and maintain procedures to ensure that the workforce is managed securely and in accordance with all applicable legal and regulatory requirements.

3.1 Screening and Background Checks

To ensure a trusted workforce, all candidates for employment or engagement shall undergo a formal screening process before being granted access to company information assets.

  • Contingent Offers: All offers of employment or contract are contingent upon the successful completion of a background check, conducted by a company-approved third-party provider.

  • Scope of Checks: The standard background check includes, at a minimum, identity verification, a criminal history check, and employment history verification, in accordance with applicable local, state, and federal laws. For roles with elevated access to financial or sensitive data, additional checks (e.g., credit history) may be required.

  • Adverse Findings: Any adverse findings from a background check will be reviewed by the Human Resources Department and the Security Officer to determine eligibility for employment based on the nature of the finding and the requirements of the role.

3.2 Onboarding and Security Training

Upon joining the company, all new workforce members must complete a formal onboarding process to ensure they understand their security responsibilities.

  • Confidentiality Agreements: All new workforce members must sign a Confidentiality and Non-Disclosure Agreement as a condition of their employment or engagement.

  • Security Awareness Training: New workforce members must complete the mandatory security and privacy awareness training within [Number, e.g., 30] days of their start date.

  • Access Provisioning: Access to systems and data will be provisioned in accordance with the Access Control Policy (SEC-POL-001), based on the principle of least privilege.

3.3 Termination and Separation

A formal process must be followed to ensure a secure and orderly separation when a workforce member leaves the company, regardless of the reason.

  • Notification: Managers must immediately notify the Human Resources and IT Departments of any voluntary or involuntary termination.

  • Revocation of Access: All logical and physical access rights must be promptly revoked upon termination, as defined in the Access Control Policy (SEC-POL-001).

  • Return of Assets: The departing workforce member is required to return all company-owned property, including laptops, mobile devices, access badges, and any documents containing sensitive information. The Human Resources Department is responsible for tracking and confirming the return of all assets.

  • Exit Interview: Where appropriate, the Human Resources Department will conduct an exit interview to remind the departing workforce member of their ongoing confidentiality obligations.

3.4 Sanction Policy

Failure to comply with [Company Name]’s information security policies may result in disciplinary action.

  • Framework: A formal sanction policy shall be maintained to address violations of the ISMS policies. This framework ensures that disciplinary actions are fair, consistent, and commensurate with the severity of the violation.

  • Disciplinary Actions: Sanctions may range from verbal or written warnings and mandatory retraining to suspension, termination of employment, and, where applicable, civil or criminal legal action.

  • Documentation: All policy violations and the resulting sanctions must be formally documented by the Human Resources Department in consultation with the workforce member’s manager and the Security Officer.

4. Standards Compliance

This policy is designed to comply with and support the following industry standards and regulations.

Policy Section Standard/Framework Control Reference
All HIPAA Security Rule 45 CFR § 164.308(a)(3)(i) - Workforce Security
3.3 HIPAA Security Rule 45 CFR § 164.308(a)(3)(ii)(C) - Termination Procedures
3.4 HIPAA Security Rule 45 CFR § 164.308(a)(1)(ii)(C) - Sanction Policy
3.1, 3.2 SOC 2 Trust Services Criteria CC2.1 - The entity establishes and communicates the importance of integrity and ethical values…
3.1, 3.2 SOC 2 Trust Services Criteria CC2.2 - The board of directors and management establish a commitment to competence…

5. Definitions

  • Workforce Member: Employees, volunteers, trainees, and other persons whose conduct, in the performance of work for [Company Name], is under the direct control of the company, whether or not they are paid by the company.

  • Background Check: A process of verifying the identity and credentials of a candidate for employment, which may include criminal history, employment verification, and other checks as permitted by law.

  • Sanction: A penalty or disciplinary action imposed for violating a rule or policy.

6. Responsibilities

Role Responsibility
Human Resources Department Own, review, and update this policy annually. Manage the screening, onboarding, and termination processes. Administer the sanction policy in consultation with management.
Security Officer / Team Advise on the security aspects of HR processes, including background checks and termination procedures. Participate in the investigation of security policy violations.
Managers Ensure their direct reports complete all required security training. Promptly notify HR of all terminations. Participate in the enforcement of the sanction policy.
All Workforce Members Comply with all information security policies. Report any suspected policy violations to their manager or the Security Officer.