HRS-12: Personnel Termination
Mechanisms exist to govern the termination of individual employment.
Renumbered: Formerly HRS-09 in SCF 2025.4.
Code reused: In SCF 2025.4 and earlier, HRS-12 was Incompatible Roles. That control is now HRS-15.
Control Question: Does the organization govern the termination of individual employment?
General (32)
US (17)
| Framework | Mapping Values |
|---|---|
| USA Federal CMS MARS-E 2.0 | PS-4 PS-4.a PS-4.b PS-4.c PS-4.d PS-4.e PS-4.f PS-4.g PS-4-IS.1 PS-4-IS.2 |
| USA Federal CISA CPG 2022 | 2.D |
| USA Federal C2M2 2.1 | WORKFORCE-1d WORKFORCE-1g |
| USA Federal CMMC 2.0 Level 2 | PSL2.-3.9.2 |
| USA Federal CJIS Security Policy 6.0 | PS-4 |
| USA Federal FedRAMP R5 (low) | PS-04 |
| USA Federal FedRAMP R5 (moderate) | PS-04 |
| USA Federal FedRAMP R5 (high) | PS-04 |
| USA Federal FedRAMP R5 (LI-SaaS) | PS-04 |
| USA Federal IRS 1075 2021 | 2.C.4.3 PS-4 |
| USA Federal HIPAA Security Rule NIST SP 800-66 R2 | § 164.308(a)(3)(ii)(C) |
| USA Federal HIPAA Administrative Simplification 2013 | § 164.308(a)(3)(ii)(C) |
| USA Massachusetts 201 CMR 17.00 2008 | 17.03(2)(e) |
| USA New York DFS 23 NYCRR500 2023 Amd 2 | 500.7(a)(6) |
| USA Texas DIR SCSC 2.2 2025 | PS-04 |
| USA Texas TX-RAMP Level 1 | PS-04 |
| USA Texas TX-RAMP Level 2 | PS-04 |
EMEA (3)
| Framework | Mapping Values |
|---|---|
| EMEA Germany C5 2026 | AM-08.03B |
| EMEA EU NIS2 Annex 2024 | 10.3.1 12.5 |
| EMEA Israel CDMO 2.0 | Appendix A, 9.2 |
APAC (2)
| Framework | Mapping Values |
|---|---|
| APAC Australia ISM June 2026 | ISM-0430 |
| APAC Japan ISMAP | 7.3 7.3.1 7.3.1.1 7.3.1.2 7.3.1.3 |
Americas (1)
| Framework | Mapping Values |
|---|---|
| Americas Canada ITSP-10-171 2025 | 03.01.01.F.03 03.01.01.G.02 03.09.02.A 03.09.02.A.02 03.09.02.A.03 03.09.02.B.01 |
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. ▪ HR, in conjunction with an individual's manager/supervisor, collects assets and return those assets to IT and/or cybersecurity personnel, upon termination of employment.
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 govern the termination of individual employment.
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-12_A01 criteria and/or process for terminating system access authorization and any credentials coincide with personnel actions is established.
- HRS-12_A02 system access and credentials are terminated consistent with personnel actions such as termination or transfer.
- HRS-12_A03 the system is protected during and after personnel transfer actions.
- HRS-12_A04 the time period within which to disable system access is defined.
- HRS-12_A05 cybersecurity topics to be discussed when conducting exit interviews are defined.
- HRS-12_A06 upon termination of individual employment, authenticators associated with the individual are terminated or revoked.
- HRS-12_A07 upon termination of individual employment, credentials associated with the individual are terminated or revoked.
- HRS-12_A08 upon termination of individual employment, exit interviews that include a discussion of cybersecurity topics are conducted.
- HRS-12_A09 upon termination of individual employment, security-related system property is retrieved.
- HRS-12_A10 upon termination of individual employment, access to organizational information and systems formerly controlled by the terminated individual are retained.
- HRS-12_A11 upon termination of individual employment, system access is disabled within an organization-defined time period.
- HRS-12_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
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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