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HRS-03: Position Categorization

HRS 8 — High Identify

Mechanisms exist to manage personnel security risk by assigning a risk designation to all positions and establishing screening criteria for individuals filling those positions.

Renumbered: Formerly HRS-02 in SCF 2025.4.

Code reused: In SCF 2025.4 and earlier, HRS-03 was Defined Roles & Responsibilities. That control is now HRS-04.

Control Question: Does the organization manage personnel security risk by assigning a risk designation to all positions and establishing screening criteria for individuals filling those positions?

General (28)
Framework Mapping Values
AICPA TSC 2017:2022 (used for SOC 2) (source) CC1.2 CC1.2-POF1 CC1.2-POF2 CC1.2-POF3 CC1.2-POF4
BSI Standard 200-1 6.0
COSO 2013 2.0
GovRAMP PS-02
GovRAMP Moderate PS-02
GovRAMP High PS-02
ISO 27001 2022 (source) 7.2(a)
ISO 27017 2015 6.1
ISO 42001 2023 7.2
MPA Content Security Program 5.3.1 OR-3.1
NIST 800-53 R4 PS-2
NIST 800-53 R5.2 PS-02
NIST 800-53B R5 (low) (source) PS-02
NIST 800-53B R5 (moderate) (source) PS-02
NIST 800-53B R5 (high) (source) PS-02
NIST SP 800-66 R2 164.308(a)(3) 164.312(a)
NIST 800-82 R3 PS-02
NIST 800-82 R3 LOW OT Overlay PS-02
NIST 800-82 R3 MODERATE OT Overlay PS-02
NIST 800-82 R3 HIGH OT Overlay PS-02
NIST 800-171 R3 (source) 03.01.01.c.01 03.01.01.c.02 03.01.01.d.01 03.01.01.d.02 03.01.02 03.09.01.a 03.09.01.b 03.15.03.b
NIST 800-171A R3 (source) A.03.01.01.c.01 A.03.01.01.c.02 A.03.01.01.d.01 A.03.01.01.d.02 A.03.01.02[01] A.03.01.02[02] A.03.09.01.a A.03.09.01.b A.03.15.03.b
NIST CSF 2.0 (source) GV.RR-02 PR.AA-05
PCI DSS 4.0.1 (source) 12.7 12.7.1
PCI DSS 4.0.1 SAQ D Merchant (source) 12.7.1
PCI DSS 4.0.1 SAQ D Service Provider (source) 12.7.1
SWIFT CSF 2025 5.1
TISAX ISA 6.0.3 1.2.2 2.1.1
US (21)
EMEA (7)
Framework Mapping Values
EMEA Germany C5 2026 OIS-04.01B.3 HR-01.01B HR-01.04B HR-01.06B
EMEA Spain Royal Decree 311 2022 Article 16(3)
EMEA EU GDPR 2016 Article 32.4
EMEA EU NIS2 Annex 2024 10.1.2(b) 10.1.3
EMEA Saudi Arabia IoT CGIoT-1 2024 1-8-1
EMEA Saudi Arabia CSCC-1 2019 1-5-1-2
EMEA Saudi Arabia OTCC-1 2022 1-2-1-2
APAC (5)
Framework Mapping Values
APAC Australia CCM 2026 GOV-04
APAC India SEBI CSCRF 2024 DE.DP.S1 GV.RR.S2 PR.AT.S4 RS.CO.S1
APAC Japan ISMAP 4.5.2.2
APAC New Zealand NZISM 3.9 9.2.10.C.01 9.2.11.C.01 9.2.11.C.02
APAC Singapore MAS TRM 2021 3.5.1
Americas (1)
Framework Mapping Values
Americas Canada ITSP-10-171 2025 03.01.01.C.01 03.01.01.C.02 03.01.01.D.01 03.01.01.D.02 03.01.02 03.09.01.A 03.09.01.B 03.15.03.B

Capability Maturity Model

Level 0 — Not Performed

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Level 1 — Performed Informally

Human Resources Security (HRS) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with HRS domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Personnel management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ The Human Resources (HR) department provides guidance on secure HR practices for hiring, retaining and terminating employees, contractors and other personnel that work on behalf of the organization. ▪ HR, in conjunction with IT and/or cybersecurity personnel, evaluates the business-critical cybersecurity and data protection skills needed to support the organization's mission.

Level 2 — Planned & Tracked

Human Resources Security (HRS) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with HRS domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with HRS domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with HRS domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Personnel management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Personnel management is decentralized at a localized/regionalized function, where there are non-standardized methods to govern personnel matters across the organization. ▪ Localized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization. ▪ The HR department, in conjunction with IT and/or cybersecurity personnel, evaluates the business-critical cybersecurity and data protection skills needed to support the organization's mission and identify gaps that exist.

Level 3 — Well Defined

Human Resources Security (HRS) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with HRS domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with HRS domain capabilities are well-documented and kept current by process owners. ▪ A Human Resources (HR) team, or similar function, is appropriately staffed and supported to implement and maintain HRS domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of human resources security operations (e.g., personnel management software solution). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with HRS domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to manage personnel security risk by assigning a risk designation to all positions and establishing screening criteria for individuals filling those positions.

Level 4 — Quantitatively Controlled

Human Resources Security (HRS) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational. ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

Level 5 — Continuously Improving

Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.

Assessment Objectives

  1. HRS-03_A01 the frequency at which to review / update position risk designations is defined.
  2. HRS-03_A02 a risk designation is assigned to all organizational positions.
  3. HRS-03_A03 screening criteria are established for individuals filling organizational positions.
  4. HRS-03_A04 position risk designations are reviewed / updated per an organization-defined frequency.

Evidence Requirements

E-HRS-01 Position Categorization

Documented evidence of a discrete roles for cybersecurity & data privacy functions (e.g., position categorization).

Human Resources

Technology Recommendations

Micro/Small

  • Employee security policy acknowledgment
  • Background check for sensitive roles

Small

  • Security awareness policy
  • Background checks
  • Security onboarding checklist

Medium

  • HR security program
  • Background checks for all staff
  • Security onboarding training

Large

  • Enterprise HR security program
  • Background screening service
  • Automated offboarding workflows

Enterprise

  • Enterprise HR security framework
  • Background screening platform
  • Integrated HR/IAM offboarding
  • Continuous monitoring

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