HRS-06Cloud & AI Related

Employment Termination

Specification

Establish, document, and communicate to all personnel the procedures outlining the roles and responsibilities concerning changes in employment.

Threat coverage

Model manipulation

Data poisoning

Sensitive data disclosure

Model theft

Model/Service Failure

Insecure supply chain

Insecure apps/plugins

Denial of Service

Loss of governance

Architectural relevance

Physical infrastructure

Network

Compute

Storage

Application

Data

Lifecycle

Preparation

Team and expertise

Development

Supply Chain

Evaluation

Not applicable

Deployment

AI Services supply chain

Delivery

Not applicable

Retirement

Not applicable

Ownership / SSRM

Shared Cloud Service Provider-Model Provider (Shared CSP-MP)

The CSP and MP are jointly responsible and accountable for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with Large Language Model (LLM)/GenAI technologies in the context of the services or products they develop and offer.

Model

Owned by the Model Provider (MP)

The model provider (MP) designs, develops, and implements the control as part of their services or products to mitigate security, privacy, or compliance risks associated with the Large Language Model (LLM). Model Providers are entities that develop, train, and distribute foundational and fine-tuned AI models for various applications. They create the underlying AI capabilities that other actors build upon. Model Providers are responsible for model architecture, training methodologies, performance characteristics, and documentation of capabilities and limitations. They operate at the foundation layer of the AI stack and may provide direct API access to their models. Examples: OpenAI (GPT, DALL-E, Whisper), Anthropic(Claude), Google(Gemini), Meta(Llama), as well as any customized model.

Orchestrated

Shared Cloud Service Provider-Model Provider (Shared CSP-MP)

Application

Shared across the supply chain

Shared control ownership refers to responsibilities and activities related to LLM security that are distributed across multiple stakeholders within the AI supply chain, including the Cloud Service Provider (CSP), Model Provider (MP), Orchestrated Service Provider (OSP), Application Provider (AP), and Customer (AIC). These controls require coordinated actions, communication, and governance across all involved parties to ensure their effectiveness.

Implementation guidelines

[All Actors]
1. Role Reassignment and Knowledge Transfer: Define AI-related responsibilities (e.g., data handling, model maintenance) and ensure formal handover of tasks and documentation when individuals change roles or leave the organization.

2. Immediate Access Revocation: Revoke or update all credentials, accounts, and permissions upon termination or role change, including access to shared or provider-hosted AI environments.

3. Contractual and Third-Party Coordination: Incorporate access termination requirements in service-level agreements or contracts with external providers, ensuring offboarding processes align for both internal staff and external consultants.

4. Secure Data Management: Establish clear procedures to remove or anonymize sensitive AI data (including PII) accessed by departing personnel, preventing unauthorized retention.

5. Monitoring and Compliance: Continuously monitor and log AI system access. Use automated alerts to detect suspicious post-termination activity, enabling rapid response to any potential breaches.

Auditing guidelines

1. Verify the CSP's policies for employment changes ensure that all access to the cloud provider's physical and logical infrastructure is immediately and permanently revoked upon termination.

2. Check for integration between the HR system and IAM systems to automate access removal.

Standards mappings

ISO 42001No Gap

42001: A.2.3 Alignment with other organizational policies
27001: A.6.5 Responsibilities after termination or change of employment
27002: 6.5 Responsibilities after termination or change of employment

Addendum

N/A

EU AI ActFull Gap

No Mapping

Addendum

Establish, document, and communicate to all personnel the procedures outlining the roles and responsibilities concerning changes in employment.

NIST AI 600-1No Gap

MP-4.1-003

Addendum

N/A

BSI AIC4No Gap

HR-05

Addendum

N/A

AI-CAIQ questions (1)

HRS-06.1

Are procedures outlining the roles and responsibilities concerning changes in employment established, documented, and communicated to all personnel?