HRS-08.2: Policy Familiarization & Acknowledgement
Mechanisms exist to ensure personnel receive recurring familiarization with the organization's security, compliance and resilience policies and provide acknowledgement.
Renumbered: Formerly HRS-05.7 in SCF 2025.4.
Control Question: Does the organization ensure personnel receive recurring familiarization with its security, compliance and resilience policies and provide acknowledgement?
General (9)
| Framework | Mapping Values |
|---|---|
| ISO 27001 2022 (source) | 7.3 7.3(c) |
| ISO 42001 2023 | 7.3 |
| MPA Content Security Program 5.3.1 | OR-3.1 |
| NIST 800-171 R3 (source) | 03.15.03.c 03.15.03.d |
| NIST 800-171A R3 (source) | A.03.15.03.c A.03.15.03.d[02] |
| NIST CSF 2.0 (source) | GV.PO GV.PO-01 GV.PO-02 |
| PCI DSS 4.0.1 (source) | 12.6.3 |
| PCI DSS 4.0.1 SAQ D Merchant (source) | 12.6.3 |
| PCI DSS 4.0.1 SAQ D Service Provider (source) | 12.6.3 |
US (5)
| Framework | Mapping Values |
|---|---|
| USA Federal C2M2 2.1 | WORKFORCE-1e |
| USA Federal FFIEC ITEH 2016 | II.C.1 II.C.7.e |
| USA Federal HIPAA Administrative Simplification 2013 | § 164.530(b)(1) |
| USA Federal FCA CRM 2023 | 609.930(c)(4) |
| USA Texas DIR SCSC 2.2 2025 | PL-04-SID |
EMEA (8)
| Framework | Mapping Values |
|---|---|
| EMEA Austria FAPPD 2000 | § 6(3) |
| EMEA Germany C5 2026 | HR-02.04B HR-02.05B AM-08.01B |
| EMEA Spain Royal Decree 311 2022 | Article 13(2) |
| EMEA EU DORA RTS 2024 | Article 19.1(b)(i) |
| EMEA EU NIS2 Annex 2024 | 1.1.1(f) |
| EMEA LUX CCSF 20/750 2020 | 3.4.1-29 |
| 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 (1)
| Framework | Mapping Values |
|---|---|
| APAC Japan ISMAP | 4.5.2.6 4.5.2.8 7.2 7.2.1.3 8.1.3.1 |
Americas (2)
| Framework | Mapping Values |
|---|---|
| Americas Canada ITSP-10-171 2025 | 03.15.03.C 03.15.03.D |
| 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.
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 ensure personnel receive recurring familiarization with the organization's security, compliance and resilience policies and provide acknowledgement.
Level 4 — Quantitatively Controlled
Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.
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
- HRS-08.2_A01 personnel receive familiarization with the organization's cybersecurity / data privacy policies per an organization-defined frequency.
- HRS-08.2_A02 a documented acknowledgement from individuals indicating that they have read, understand, and agree to abide by the rules of behavior is received before authorizing access to sensitive / regulated data and the system.
- HRS-08.2_A03 a documented acknowledgement from individuals indicating that they have read, understand, and agree to abide by the rules of behavior is received before authorizing access to CUI and 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 - E-SAT-04 Recurring User Training
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Documented evidence of recurring (e.g., annual) user training for security, compliance and/or resilience topics.
Education
Technology Recommendations
Micro/Small
- Formal onboarding training
- Written policy acknowledgement
Small
- Formal onboarding training
- Written policy acknowledgement
Medium
- Formal onboarding training
- Written policy acknowledgement
Large
- Formal onboarding training
- Written policy acknowledgement
Enterprise
- Formal onboarding training
- Written policy acknowledgement