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Human Resources in ISO 27001

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This curriculum spans the full employee lifecycle and third-party management, comparable in scope to an internal capability-building program that integrates HR processes with an organization’s information security management system, addressing operational workflows, compliance requirements, and cross-functional coordination as would be expected in a multi-phase ISO 27001 implementation.

Module 1: Establishing HR Security Roles and Responsibilities

  • Define and assign information security roles such as Data Owner, Data Custodian, and HR Security Liaison within organizational charts.
  • Integrate security responsibilities into job descriptions for HR personnel handling employee data.
  • Implement role-based access control (RBAC) for HRIS systems based on functional necessity.
  • Conduct joint reviews between HR and Information Security to validate role assignments during organizational restructuring.
  • Document accountability for security incidents involving HR data under the RACI matrix.
  • Establish escalation paths for HR staff to report suspicious access or misuse of personnel records.
  • Align HR security responsibilities with ISO/IEC 27001 Annex A 6.1.2 and A 6.1.3 controls.
  • Review and update role definitions annually or after significant process changes.

Module 2: Secure Onboarding Processes

  • Implement standardized pre-employment screening procedures, including background checks and reference validation, based on role sensitivity.
  • Enforce mandatory information security awareness training completion before system access is granted.
  • Automate provisioning of user accounts and access rights through integrated HR and IT systems using predefined access templates.
  • Require signed confidentiality agreements (NDAs) and acceptable use policies as part of new hire documentation.
  • Verify identity documents during onboarding using secure, tamper-evident methods.
  • Restrict temporary contractor access to HR systems based on time-bound access policies.
  • Ensure dual approval (HR and department manager) for onboarding high-risk roles with elevated privileges.
  • Log and audit all onboarding-related access provisioning activities for compliance reporting.

Module 3: Managing Employee Changes and Transfers

  • Trigger access review workflows in IAM systems when an employee changes roles or departments.
  • Re-evaluate data access rights for transferred employees based on the principle of least privilege.
  • Update HR records to reflect new reporting lines and security clearances after transfers.
  • Conduct security briefings for employees moving into roles with access to sensitive data.
  • Revoke access to previous department systems within 24 hours of role change.
  • Coordinate with IT to reissue or reconfigure endpoint devices when employees relocate.
  • Document justification for any exceptions to standard access provisioning during transfers.
  • Integrate transfer notifications into the organization’s change management system.

Module 4: Offboarding and Access Revocation

  • Initiate automated deprovisioning of user accounts upon receipt of formal resignation or termination notice.
  • Enforce a standardized checklist for returning company assets, including badges, laptops, and tokens.
  • Conduct exit interviews that include confirmation of data return and confidentiality obligations.
  • Validate revocation of access across all systems, including cloud applications and physical access controls.
  • Retain terminated employee access logs for a minimum of six months for forensic readiness.
  • Coordinate with IT to disable multi-factor authentication tokens and revoke VPN certificates.
  • Apply temporary account suspension instead of immediate deletion for roles with ongoing legal or audit obligations.
  • Monitor for post-termination access attempts and trigger alerts for investigation.

Module 5: Third-Party and Contractor Management

  • Require security clauses in contractor agreements specifying data handling and breach notification obligations.
  • Classify contractors based on data access level to determine screening and monitoring requirements.
  • Limit contractor access to HR systems through segregated environments or read-only views.
  • Enforce time-bound access tokens for external consultants working on HR projects.
  • Conduct annual security assessments of third-party HR service providers.
  • Map contractor access rights to ISO 27001 Annex A 8.1.4 and A 13.2.3 controls.
  • Require contractors to complete the same security training as internal staff when accessing sensitive data.
  • Review and audit contractor activity logs quarterly for anomalies or policy violations.

Module 6: Security Awareness and Role-Specific Training

  • Develop role-based training modules for HR staff covering data classification, phishing, and incident reporting.
  • Deliver annual refresher training with updated content reflecting current threats and policy changes.
  • Measure training effectiveness through post-session assessments and simulated phishing tests.
  • Customize content for HR leaders on regulatory compliance, data privacy laws, and breach response.
  • Integrate security topics into HR leadership development programs.
  • Track completion rates and escalate non-compliance to HR management for disciplinary action.
  • Use real incident examples from HR operations to illustrate risks during training sessions.
  • Update training materials following internal audits or regulatory findings.

Module 7: Handling Sensitive HR Data and Privacy Compliance

  • Classify HR data (e.g., payroll, performance reviews, medical records) according to organizational data classification policy.
  • Apply encryption to sensitive HR data at rest and in transit using organization-approved standards.
  • Implement access logging and monitoring for databases containing personal employee information.
  • Align HR data handling practices with GDPR, CCPA, or other applicable privacy regulations.
  • Establish data retention schedules for HR records and enforce secure deletion procedures.
  • Restrict printing and downloading of sensitive HR data through DLP policy enforcement.
  • Conduct DPIAs (Data Protection Impact Assessments) for new HR systems processing personal data.
  • Respond to employee data subject access requests (DSARs) within regulatory timeframes.

Module 8: Incident Response and HR Involvement

  • Define HR’s role in the incident response plan for breaches involving employee data.
  • Coordinate with legal and communications teams when incidents involve staff misconduct.
  • Support forensic investigations by providing employee status, access history, and organizational context.
  • Manage employee notifications in the event of a personal data breach per regulatory requirements.
  • Participate in post-incident reviews to identify HR-related root causes or process gaps.
  • Enforce disciplinary actions for policy violations identified during incident investigations.
  • Update HR policies based on lessons learned from security incidents.
  • Preserve HR records related to incidents for potential legal or regulatory proceedings.

Module 9: Auditing and Continuous Monitoring of HR Security

  • Conduct quarterly access reviews for HR system users, including managers and administrators.
  • Generate and analyze audit logs from HRIS platforms to detect unauthorized access attempts.
  • Perform internal audits of HR security controls aligned with ISO 27001 Annex A requirements.
  • Validate compliance with background check policies during audit cycles.
  • Report findings to the Information Security Committee with remediation timelines.
  • Use SIEM tools to correlate HR-related events with broader security alerts.
  • Track and trend HR security metrics such as onboarding/offboarding delays and access violations.
  • Integrate HR audit results into the organization’s risk register and treatment plans.

Module 10: Aligning HR Policies with ISMS Objectives

  • Map HR policies (e.g., disciplinary, remote work, BYOD) to relevant ISO 27001 controls.
  • Ensure HR policy review cycles are synchronized with ISMS management review meetings.
  • Incorporate information security performance indicators into HR leadership KPIs.
  • Update HR policies following changes to the organization’s risk treatment plan.
  • Require security impact assessments before launching new HR initiatives or systems.
  • Collaborate with the CISO to align HR security initiatives with overall risk appetite.
  • Document policy exceptions with risk acceptance from senior management.
  • Maintain version-controlled records of all HR security policies for audit purposes.