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HRS-03.2: Competency Requirements for Security-Related Positions

HRS 9 — Critical Identify

Mechanisms exist to ensure that all security-related positions are staffed by qualified individuals who have the necessary skill set.

Control Question: Does the organization ensure that all security-related positions are staffed by qualified individuals who have the necessary skill set?

General (35)
Framework Mapping Values
AICPA TSC 2017:2022 (used for SOC 2) (source) CC1.2 CC1.2-POF2 CC1.2-POF4 CC1.3 CC1.4-POF2 CC1.4-POF6 CC1.5 CC5.3 CC5.3-POF5
COBIT 2019 APO01.08
COSO 2017 Principle 2 Principle 3 Principle 5 Principle 12
ENISA 2.0 SO6
GovRAMP Moderate PS-02
GovRAMP High PS-02
IMO Maritime Cyber Risk Management 3.5.1.2
ISO/SAE 21434 2021 RQ-05-07
ISO 22301 2019 7.2
ISO 27001 2022 (source) 7.2 7.2(a) 7.2(b) 7.2(c) 7.2(d)
ISO 27701 2025 7.2
ISO 42001 2023 7.2
NIST AI 100-1 (AI RMF) 1.0 GOVERN 4.1 MAP 1.2 MAP 3.4
NIST 800-53 R4 PS-2
NIST 800-53 R4 (low) PS-2
NIST 800-53 R4 (moderate) PS-2
NIST 800-53 R4 (high) PS-2
NIST 800-53 R5 (source) PS-2
NIST 800-53B R5 (low) (source) PS-2
NIST 800-53B R5 (moderate) (source) PS-2
NIST 800-53B R5 (high) (source) PS-2
NIST 800-82 R3 LOW OT Overlay PS-2
NIST 800-82 R3 MODERATE OT Overlay PS-2
NIST 800-82 R3 HIGH OT Overlay PS-2
NIST 800-171 R3 (source) 03.07.06.d
NIST 800-218 PO.2
PCI DSS 4.0.1 (source) 6.2.2
PCI DSS 4.0.1 SAQ A-EP (source) 6.2.2
PCI DSS 4.0.1 SAQ C (source) 6.2.2
PCI DSS 4.0.1 SAQ D Merchant (source) 6.2.2
PCI DSS 4.0.1 SAQ D Service Provider (source) 6.2.2
TISAX ISA 6 1.2.2 2.1.1
SCF CORE Mergers, Acquisitions & Divestitures (MA&D) HRS-03.2
SCF CORE ESP Level 2 Critical Infrastructure HRS-03.2
SCF CORE ESP Level 3 Advanced Threats HRS-03.2
US (25)
Framework Mapping Values
US C2M2 2.1 ASSET-5.E.MIL3 THREAT-3.E.MIL3 RISK-5.E.MIL3 ACCESS-4.E.MIL3 SITUATION-4.E.MIL3 RESPONSE-5.E.MIL3 THIRD-PARTIES-3.E.MIL3 WORKFORCE-4.E.MIL3
US CERT RMM 1.2 HRM:SG1.SP1
US CMS MARS-E 2.0 PS-2
US DHS ZTCF SEC-03
US FCA CRM 609.930(b)(3)
US FDA 21 CFR Part 11 11.10 11.10(i)
US FedRAMP R4 PS-2
US FedRAMP R4 (low) PS-2
US FedRAMP R4 (moderate) PS-2
US FedRAMP R4 (high) PS-2
US FedRAMP R4 (LI-SaaS) PS-2
US FedRAMP R5 (source) PS-2
US FedRAMP R5 (low) (source) PS-2
US FedRAMP R5 (moderate) (source) PS-2
US FedRAMP R5 (high) (source) PS-2
US FedRAMP R5 (LI-SaaS) (source) PS-2
US GLBA CFR 314 2023 (source) 314.4(e)(2)
US ITAR Part 120 120.15 120.16 120.39 120.40 120.41
US NISPOM 2020 8-307
US NNPI (unclass) 2.3
US SEC Cybersecurity Rule 17 CFR 229.106(b)(1)(ii)
US - NY DFS 23 NYCRR500 2023 Amd 2 500.10(a)(1)
US - TX DIR Control Standards 2.0 PS-2
US - TX TX-RAMP Level 1 PS-2
US - TX TX-RAMP Level 2 PS-2
EMEA (5)
Framework Mapping Values
EMEA Saudi Arabia ECC-1 2018 1-9-2
EMEA Saudi Arabia SACS-002 TPC-26
EMEA Spain BOE-A-2022-7191 15.1 16.1 16.2 16.3
EMEA Spain 311/2022 15.1 16.1 16.2 16.3
EMEA UK CAF 4.0 C1.e
APAC (3)
Framework Mapping Values
APAC Japan ISMAP 4.5.2 4.5.2.1 4.5.2.2 4.5.2.3 4.5.2.4 4.5.2.5 4.5.2.6
APAC New Zealand NZISM 3.6 5.1.14.C.01
APAC Singapore MAS TRM 2021 3.5.1 6.1.5
Americas (2)
Framework Mapping Values
Americas Canada CSAG 1.5 1.7
Americas Canada ITSP-10-171 03.07.06.D

Capability Maturity Model

Level 0 — Not Performed

There is no evidence of a capability to ensure that all security-related positions are staffed by qualified individuals who have the necessary skill set.

Level 1 — Performed Informally

C|P-CMM1 is N/A, since a structured process is required to ensure that all security-related positions are staffed by qualified individuals who have the necessary skill set.

Level 2 — Planned & Tracked

Human Resources Security (HRS) efforts are requirements-driven and governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist: o Ensures industry-recognized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization. o Defines terms of employment, including acceptable and unacceptable rules of behavior for the use of technologies, including consequences for unacceptable behavior.

  • Personnel management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
  • IT/cybersecurity personnel identify cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements for personnel management.
  • The Human Resources (HR) department:
  • The responsibility for training users and enforcing policies being assigned to user’s immediate supervisor(s)/manager(s), including the definition and enforcement of the user’s specific role(s) and responsibilities.
  • Personnel managers ensure personnel are routinely made aware of the organization's cybersecurity / data privacy policies and provide acknowledgement.
  • Administrative processes require all employees and contractors to apply cybersecurity and data privacy principles in their daily work.
Level 3 — Well Defined

Human Resources Security (HRS) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: o Ensures industry-recognized HR practices are implemented for hiring, managing, training, investigating and terminating employees, contractors and other personnel that work on behalf of the organization. o Ensures that every user accessing a system that processes, stores, or transmits sensitive/regulated data is cleared and regularly trained in proper data handling practices. o Identifies and implements industry-recognized HR practices related to cybersecurity and data privacy training and awareness to help ensure secure practices are implemented in personnel operations to help manage risk to both technology assets and data. o Manages personnel security risk by assigning a risk designation to all positions and establishing screening criteria for individuals filling those positions.

  • The Human Resources (HR) department:
  • Administrative processes require Non-Disclosure Agreements (NDAs) or similar confidentiality agreements that reflect the needs to protect data and operational details, for both employees and third-parties.
Level 4 — Quantitatively Controlled

Human Resources Security (HRS) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist:

  • 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.
  • Both business and technical stakeholders are involved in reviewing and approving proposed changes.
Level 5 — Continuously Improving

See C|P-CMM4. There are no defined C|P-CMM5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to ensure that all security-related positions are staffed by qualified individuals who have the necessary skill set.

Assessment Objectives

  1. HRS-03.2_A01 defined competency requirements ensure that all cybersecurity / data privacy-related positions are staffed by qualified individuals who have the necessary skill set.
  2. HRS-03.2_A02 a risk designation is assigned to all organizational positions.
  3. HRS-03.2_A03 the frequency at which to review / update position risk designations is defined.
  4. HRS-03.2_A04 screening criteria are established for individuals filling organizational positions.
  5. HRS-03.2_A05 position risk designations are reviewed / updated per an organization-defined frequency.

Evidence Requirements

E-HRS-21 Position Competency Requirements

Documented evidence of personnel management practices to define minimum competency requirements for cybersecurity & data privacy-related roles.

Human Resources
E-HRS-23 Critical Cybersecurity & Data Privacy Skills

Documented evidence of personnel management practices to formally identify critical cybersecurity skills needed to support business operations.

Human Resources

Technology Recommendations

Micro/Small

  • Demonstrated Subject Matter Expert (SME) experience
  • Professional references
  • Education / certification transcripts

Small

  • Demonstrated Subject Matter Expert (SME) experience
  • Professional references
  • Education / certification transcripts

Medium

  • Demonstrated Subject Matter Expert (SME) experience
  • Professional references
  • Education / certification transcripts

Large

  • Demonstrated Subject Matter Expert (SME) experience
  • Professional references
  • Education / certification transcripts

Enterprise

  • Demonstrated Subject Matter Expert (SME) experience
  • Professional references
  • Education / certification transcripts

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