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HRS-11: Personnel Transfer

HRS 9 — Critical Identify

Mechanisms exist to adjust logical and physical access authorizations to Technology Assets, Applications and/or Services (TAAS) and facilities upon personnel reassignment or transfer, in a timely manner.

Renumbered: Formerly HRS-08 in SCF 2025.4.

Code reused: In SCF 2025.4 and earlier, HRS-11 was Separation of Duties (SoD). That control is now HRS-14.

Control Question: Does the organization adjust logical and physical access authorizations to Technology Assets, Applications and/or Services (TAAS) and facilities upon personnel reassignment or transfer, in a timely manner?

General (25)
Framework Mapping Values
AICPA TSC 2017:2022 (used for SOC 2) (source) CC1.5 CC6.2-POF3
CSA CCM 4.1.0 IAM-07
GovRAMP PS-05
GovRAMP Low PS-05
GovRAMP Low+ PS-05
GovRAMP Moderate PS-05
GovRAMP High PS-05
ISO 27002 2022 6.5
ISO 27017 2015 7.3.1
ISO 27018 2025 6.5
MPA Content Security Program 5.3.1 OR-3.2
NIST 800-53 R4 PS-5
NIST 800-53 R5.2 PS-05
NIST 800-53B R5 (low) (source) PS-05
NIST 800-53B R5 (moderate) (source) PS-05
NIST 800-53B R5 (high) (source) PS-05
NIST SP 800-66 R2 164.308(a)(3)
NIST 800-82 R3 PS-05
NIST 800-82 R3 LOW OT Overlay PS-05
NIST 800-82 R3 MODERATE OT Overlay PS-05
NIST 800-82 R3 HIGH OT Overlay PS-05
NIST 800-171 R2 (source) 3.9.2
NIST 800-171 R3 (source) 03.01.01.g.02 03.09.02.a 03.09.02.b.01 03.09.02.b.02
NIST 800-171A (source) 3.9.2[a] 3.9.2[b] 3.9.2[c]
NIST 800-171A R3 (source) A.03.01.01.g.02 A.03.09.02.ODP[01] A.03.09.02.a.01 A.03.09.02.b.01[01] A.03.09.02.b.01[02] A.03.09.02.b.02
US (16)
EMEA (2)
Framework Mapping Values
EMEA Germany C5 2026 HR-01.03B HR-01.05B
EMEA Israel CDMO 2.0 Appendix A, 9.2
APAC (1)
Framework Mapping Values
APAC Australia ISM June 2026 ISM-0430
Americas (1)
Framework Mapping Values
Americas Canada ITSP-10-171 2025 03.01.01.G.02 03.09.02.A 03.09.02.B.01 03.09.02.B.02

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.

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 adjust logical and physical access authorizations to Technology Assets, Applications and/or Services (TAAS) and facilities upon personnel reassignment or transfer, in a timely manner.

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

  1. HRS-11_A01 criteria and/or process for terminating system access authorization and any credentials coincide with personnel actions is established.
  2. HRS-11_A02 system access and credentials are terminated consistent with personnel actions such as termination or transfer.
  3. HRS-11_A03 the system is protected during and after personnel transfer actions.
  4. HRS-11_A04 transfer or reassignment actions to be initiated following transfer or reassignment are defined.
  5. HRS-11_A05 the time period within which transfer or reassignment actions must occur following transfer or reassignment is defined.
  6. HRS-11_A06 personnel or roles to be notified when individuals are reassigned or transferred to other positions within the organization is/are defined.
  7. HRS-11_A07 time period within which to notify organization-defined personnel or roles when individuals are reassigned or transferred to other positions within the organization is defined.
  8. HRS-11_A08 the ongoing operational need for current logical and physical access authorizations to systems and facilities are reviewed and confirmed when individuals are reassigned or transferred to other positions within the organization.
  9. HRS-11_A09 transfer or reassignment actions are initiated within an organization-defined time period following the formal transfer action.
  10. HRS-11_A10 access authorization is modified as needed to correspond with any changes in operational need due to reassignment or transfer.
  11. HRS-11_A11 personnel or roles are notified within an organization-defined time period.
  12. HRS-11_A12 the time period within which to disable system access is defined.
  13. HRS-11_A13 upon individual reassignment or transfer to other positions in the organization, the ongoing operational need for current logical and physical access authorizations to the system and facility is reviewed.
  14. HRS-11_A14 upon individual reassignment or transfer to other positions in the organization, the ongoing operational need for current logical and physical access authorizations to the system and facility is confirmed.
  15. HRS-11_A15 upon individual reassignment or transfer to other positions in the organization, access authorization is modified to correspond with any changes in operational need.

Evidence Requirements

E-HRS-29 Personnel Actions Documentation

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

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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