Platt Perspective on Business and Technology

Onboarding new employees 101 – 10: onboarding in a heavily regulated industry and for positions requiring security clearance

Posted in career development, HR and personnel by Timothy Platt on December 23, 2012

This is my tenth posting to a series on the onboarding process and on bringing new employees in and up to speed working at a business (see HR and Personnel, postings 119 and following for Parts 1-9.) I have, up to now at least, been discussing onboarding in general, and as a set of standard and transferrable processes and practices that would apply in most business settings. Some of the details that I have been touching upon in that might not be relevant to the needs of a smaller business or one with a very limited employee headcount, and some might require more elaboration and more nuanced specificity in a larger organization. But I have been writing to this topic area with general new employee and hiring business needs in mind. With this posting I add in a set of specialty complications: meeting outside business regulatory guidelines, and onboarding employees to positions requiring security clearance.

• What positions do you have in your organization that would be directly affected by regulatory compliance and/or or security clearance issues?
• Keep in mind that this might include people who would have access to and use sensitive information as a direct and significant part of their day to day work. But this might also include people in positions within your organization where they should be expected to incidentally come into contact with such information too but where this might not be listed on their basic job descriptions. Consider in this case, maintenance workers who are assigned to work areas for cleaning floors of a company office building. For some this might very well mean their having access to paper waste in the course of their work that would contain client names, addresses and social security numbers – information that could be used for identity theft purposes. And if these maintenance workers are at least periodically moved around to meet current work load needs on different floors, when for example a regularly assigned worker is off sick or on vacation, this source of risk might arise for potentially any of these employees.
• I picked that example as an obvious one where a wider range of employees and would-be employees would need criminal background checks and perhaps other background validation checks (e.g. credit checks) as well – besides simply seeking feedback from their previous employment references provided.
• And I note that an important element of most regulatory laws and security access guidelines seeks to anticipate and codify situations such as this, removing the need for the specific organization to a priori identify all of them. And these externally applied frameworks seek to provide standardized, vetted resolutions to these risk management challenges.

So start out working with Risk Management and services that would hold sensitive information, or that might be directly regulated as to their activity by regulatory or security clearance law, to identify potential sources of risk. Then ask who might either directly or incidentally have to be accounted for by job title and work and responsibility area. And add an awareness of this into their job descriptions as needed, and into their job candidate vetting and onboarding processes too.

Note that this is not a posting where it would be appropriate for me to attempt to outline what a specific financial services analyst or client advisor should or should not do, to meet specific regulatory requirements for their particular business and industry. This is not where I would write about any of that type of detail and even if I was sure that anything I could add would be of lasting significance as laws and guidelines change, and in wording and in court interpretations. My goal here is to look at this strictly from the Human Resources perspective, and for how HR professionals as such, work coordinately with others including the employees who would face those functionally specific guidelines and regulatory requirements.

Human Resources personnel do not need to be functional area experts for those parts of their organization that would fall under the mandate of outside regulatory control. But they need to be able to communicate effectively with them, so they can make sure their processes and procedures mesh with and support the business’ compliance and risk remediation efforts.

I chose to address regulatory and security clearance issues together in this posting. I will separately address the issues of nondisclosure agreements in my next series installment, there considering both

• Prior agreements signed with earlier employers, and
• New ones that might have to be signed by a new hire as part of their onboarding with their new employer.

Meanwhile, you can find this and related postings at HR and Personnel.

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