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HRS-08.1: Formal Indoctrination

HRS 7 — High Identify

Mechanisms exist to formally educate authorized users on proper data handling practices for all the relevant types of data to which they have access.

Renumbered: Formerly HRS-04.2 in SCF 2025.4.

Control Question: Does the organization formally educate authorized users on proper data handling practices for all the relevant types of data to which they have access?

General (16)
Framework Mapping Values
AICPA Privacy Management Framework (PMF) M1.2-POF3
COSO 2013 4.0
CSA CCM 4.1.0 HRS-07 HRS-13
ISO 22301 2019 7.3 7.3(a) 7.3(b) 7.3(c) 7.3(d)
ISO 27001 2022 (source) 7.3 7.3(a) 7.3(b) 7.3(c)
ISO 27002 2022 5.4
ISO 27701 2025 7.3
ISO 31000 2018 6.2
ISO 42001 2023 7.3
MPA Content Security Program 5.3.1 OR-3.1
NIST 800-53 R4 PS-3(2)
NIST 800-53 R5.2 PS-03(02)
NIST 800-82 R3 PS-03(02)
NIST 800-171 R2 (source) 3.2.1 3.2.2
NIST 800-171 R3 (source) 03.01.22.a 03.02.02.a.01 03.06.04.a 03.06.04.a.01 03.15.03.b
NIST 800-171A R3 (source) A.03.01.22.a A.03.02.02.a.01[01] A.03.06.04.ODP[01] A.03.06.04.a.01 A.03.15.03.b
US (6)
Framework Mapping Values
USA Federal C2M2 2.1 WORKFORCE-1e WORKFORCE-2a
USA Federal CMMC 2.0 Level 2 ATL2.-3.2.1 ATL2.-3.2.2
USA Federal 21 CFR Part 11 2025 11.10(i) 11.10(j)
USA Federal 33 CFR Part 101 Subpart F 101.625(d)(8)
USA Federal FIPPS 1973 2.0
USA New York DFS 23 NYCRR500 2023 Amd 2 500.10(a)(2)
EMEA (2)
Framework Mapping Values
EMEA Saudi Arabia ECC-1 2018 1-9-4-1 1-9-4-2
EMEA Saudi Arabia SAMA CSF 1.0 2017 3.3.1.3.b
APAC (3)
Framework Mapping Values
APAC Australia ISM June 2026 ISM-0435
APAC Japan ISMAP 4.5.2.6 7.2 7.2.1.1 8.1.3.1
APAC New Zealand NZISM 3.9 9.1.7.C.01
Americas (3)
Framework Mapping Values
Americas Argentina Reg 132 2018 B.2.2
Americas Canada ITSP-10-171 2025 03.01.22.A 03.02.02.A.01 03.06.04.A 03.06.04.A.01 03.15.03.B
Americas Canada PIPEDA 2000 P1-4.1.4(d)

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

SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.

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 governs personnel management operations and notifies IT and/or cybersecurity personnel of role changes for logical access provisioning and deprovisioning actions. ▪ Personnel managers ensure personnel are responsible for educating new hires on the organization's cybersecurity and data protection policies.

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 formally educate authorized users on proper data handling practices for all the relevant types of data to which they have access.

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-08.1_A01 individuals accessing a system, application or service processing, storing or transmitting types of sensitive / regulated data that require formal indoctrination are formally indoctrinated for all of the relevant types of information to which they have access on the system.

Evidence Requirements

E-HRS-18 Provisioning Checklist (Onboarding)

Documented evidence of personnel management practices to formally onboard personnel into their assigned roles.

Human Resources
E-SAT-02 Initial User Training

Documented evidence of initial user training for security, compliance and/or resilience topics.

Education

Technology Recommendations

Micro/Small

  • Formal onboarding training

Small

  • Formal onboarding training

Medium

  • Formal onboarding training

Large

  • Formal onboarding training

Enterprise

  • Formal onboarding training

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