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HRS-09: Personnel Termination

HRS 9 — Critical Protect

Mechanisms exist to govern the termination of individual employment.

Control Question: Does the organization govern the termination of individual employment?

General (35)
Framework Mapping Values
AICPA TSC 2017:2022 (used for SOC 2) (source) CC1.5 CC6.2-POF3
COSO 2017 Principle 5
CSA CCM 4 HRS-06
GovRAMP Low PS-04
GovRAMP Low+ PS-04
GovRAMP Moderate PS-04
GovRAMP High PS-04
ISO 27002 2022 6.5
ISO 27017 2015 7.3.1
MPA Content Security Program 5.1 OR-3.1
NIST 800-53 R4 PS-4
NIST 800-53 R4 (low) PS-4
NIST 800-53 R4 (moderate) PS-4
NIST 800-53 R4 (high) PS-4
NIST 800-53 R5 (source) PS-4
NIST 800-53B R5 (low) (source) PS-4
NIST 800-53B R5 (moderate) (source) PS-4
NIST 800-53B R5 (high) (source) PS-4
NIST 800-82 R3 LOW OT Overlay PS-4
NIST 800-82 R3 MODERATE OT Overlay PS-4
NIST 800-82 R3 HIGH OT Overlay PS-4
NIST 800-171 R2 (source) 3.9.2
NIST 800-171A (source) 3.9.2[a] 3.9.2[b] 3.9.2[c]
NIST 800-171 R3 (source) 03.01.01.f.03 03.01.01.g.02 03.09.02.a 03.09.02.a.03 03.09.02.b.01
NIST 800-171A R3 (source) A.03.09.02.ODP[01] A.03.09.02.a.01 A.03.09.02.a.02[01] A.03.09.02.a.02[02] A.03.09.02.a.03
PCI DSS 4.0.1 (source) 8.2.5
PCI DSS 4.0.1 SAQ A (source) 8.2.5
PCI DSS 4.0.1 SAQ A-EP (source) 8.2.5
PCI DSS 4.0.1 SAQ C (source) 8.2.5
PCI DSS 4.0.1 SAQ C-VT (source) 8.2.5
PCI DSS 4.0.1 SAQ D Merchant (source) 8.2.5
PCI DSS 4.0.1 SAQ D Service Provider (source) 8.2.5
SCF CORE Mergers, Acquisitions & Divestitures (MA&D) HRS-09
SCF CORE ESP Level 2 Critical Infrastructure HRS-09
SCF CORE ESP Level 3 Advanced Threats HRS-09
US (28)
EMEA (4)
Framework Mapping Values
EMEA EU NIS2 Annex 10.3.1 12.5
EMEA Germany C5 2020 HR-05
EMEA Israel CDMO 1.0 19.9 19.10
EMEA Saudi Arabia SACS-002 TPC-6 TPC-18
APAC (2)
Framework Mapping Values
APAC Australia ISM June 2024 ISM-0430
APAC Japan ISMAP 7.3.1
Americas (1)
Framework Mapping Values
Americas Canada ITSP-10-171 03.01.01.F.03 03.01.01.G.02 03.09.02.A 03.09.02.A.03 03.09.02.B.01

Capability Maturity Model

Level 0 — Not Performed

There is no evidence of a capability to govern the termination of individual employment.

Level 1 — Performed Informally

Human Resources Security (HRS) efforts are ad hoc and inconsistent. CMM Level 1 control maturity would reasonably expect all, or at least most, the following criteria to exist:

  • Personnel management is decentralized, with the responsibility for training users and enforcing policies being assigned to the user’s immediate supervisor(s)/manager(s), including the definition and enforcement of the user’s specific role(s) and responsibilities.
  • The Human Resources (HR) department provides guidance on HR practices for hiring, retaining and terminating employees, contractors and other personnel that work on behalf of the organization.
  • Terms of employment, including acceptable and unacceptable rules of behavior for the use of technologies, including consequences for unacceptable behavior are at the discretion of users’ management.
  • Administrative processes require all employees and contractors to apply cybersecurity and data privacy principles in their daily work.
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.
  • Administrative processes exist to retrieve organization-owned assets up on termination of an individual's employment.
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. o Govern the termination process of individual employment to ensure the confidentiality, integrity, availability and safety of the organizations assets and data are protected. o Adjust logical and physical access authorizations to systems and facilities up on personnel reassignment, transfer or termination, in a timely manner. o Expedite the process of removing a high risk individual’s access to systems and applications up on termination, as determined by management.

  • 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.
  • Administrative processes and technologies:
  • Administrative processes exist to retrieve organization-owned assets up on termination of an individual's employment.
Level 4 — Quantitatively Controlled

See C|P-CMM3. There are no defined C|P-CMM4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to govern the termination of individual employment.

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 govern the termination of individual employment.

Assessment Objectives

  1. HRS-09_A01 criteria and/or process for terminating system access authorization and any credentials coincide with personnel actions is established.
  2. HRS-09_A02 system access and credentials are terminated consistent with personnel actions such as termination or transfer.
  3. HRS-09_A03 the system is protected during and after personnel transfer actions.
  4. HRS-09_A04 the time period within which to disable system access is defined.
  5. HRS-09_A05 cybersecurity topics to be discussed when conducting exit interviews are defined.
  6. HRS-09_A06 upon termination of individual employment, authenticators associated with the individual are terminated or revoked.
  7. HRS-09_A07 upon termination of individual employment, credentials associated with the individual are terminated or revoked.
  8. HRS-09_A08 upon termination of individual employment, exit interviews that include a discussion of cybersecurity topics are conducted.
  9. HRS-09_A09 upon termination of individual employment, security-related system property is retrieved.
  10. HRS-09_A10 upon termination of individual employment, access to organizational information and systems formerly controlled by the terminated individual are retained.
  11. HRS-09_A11 upon termination of individual employment, system access is disabled within an organization-defined time period.
  12. HRS-09_A12 upon termination of individual employment, system access is disabled within <A.03.09.02.ODP[01]: time period>.

Evidence Requirements

E-HRS-19 Deprovisioning Checklist (Offboarding)

Documented evidence of personnel management practices to formally offboard personnel from their assigned roles due to employment termination or role change.

Human Resources
E-HRS-29 Personnel Actions Documentation

Documented evidence of notifications or records of recently transferred, separated, or terminated employees.

Human Resources

Technology Recommendations

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