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HR and Personnel Security

Last Reviewed: 2025-02-17:19:44:43-UTC

APS is committed to ensuring all workforce members actively address security and compliance in their roles at APS. We encourage self management and reward the right behaviors. This policy specifies acceptable use of end-user computing devices and technology. Additionally, training is imperative to assuring an understanding of current best practices, the different types and sensitivities of data, and the sanctions associated with non-compliance.

Policy Statements

In addition to the roles and responsibilities stated earlier, APS policy requires all workforce members to comply with the Acceptable Use Policy for End-use Computing and HR Security Policy.

APS policy requires that:

(a) Background verification checks on all candidates for employees and contractors should be carried out in accordance with relevant laws, regulations, and ethics, and proportional to the business requirements, the classification of the information to be accessed, and the perceived risk.

(b) Employees, contractors and third party users must agree and sign the terms and conditions of their employment contract, and comply with acceptable use.

(c) Employees will go through an onboarding process that familiarizes them with the environments, systems, security requirements, and procedures APS has in place. Employees will also have ongoing security awareness training that is audited.

(d) Employee offboarding will include reiterating any duties and responsibilities still valid after terminations, verifying that access to any APS systems has been removed, as well as ensuring that all company owned assets are returned.

(e) APS and its employees will take reasonable measures to ensure no sensitive data is transmitted via digital communications such as email or posted on social media outlets.

(f) APS will maintain a list of prohibited activities that will be part of onboarding procedures and have training available if/when the list of those activities changes.

(g) A fair disciplinary process will be utilized for employees are suspected of committing breaches of security. Multiple factors will be considered when deciding the response such as whether or not this was a first offense, training, business contracts, etc. APS reserves the right to terminate employees in the case of serious cases of misconduct.

Controls and Procedures

HR Management and Reporting

APS uses TriNet to manage its workforce personnel records.

Organization Structure

A reporting structure has been established that aligns with the organization’s business lines and/or individual’s functional roles. The organizational chart is available to all employees via the TriNet and/or posted on the internal web portal.

Job Functions and Descriptions

Position / Job descriptions are documented and updated as needed that define the skills, responsibilities, and knowledge levels required for certain jobs.

Acceptable Use of End-user Computing

APS requires all workforce members to comply with the following acceptable use requirements and procedures, such that:

(a) Per APS security architecture, all workforce members are primarily considered as remote users and therefore must follow all system access controls and procedures for remote access.

(b) Use of APS computing systems is subject to monitoring by APS IT and/or Security team.

(c) Employees may not leave computing devices (including laptops and smart devices) used for business purpose, including company-provided and BYOD devices, unattended in public.

(d) Device encryption must be enabled for all mobile devices accessing company data, such as whole-disk encryption for all laptops.

(e) Use only legal, approved software with a valid license installed through a pre-approved application store. Do not use personal software for business purposes and vice versa.

(f) Encrypt all email messages containing sensitive or confidential data.

(g) Employees may not post any sensitive or confidential data in public forums or chat rooms. If a posting is needed to obtain technical support, data must be sanitized to remove any sensitive or confidential information prior to posting.

(h) Anti-malware or equivalent protection and monitoring must be installed and enabled on all endpoint systems that may be affected by malware, including workstations, laptops and servers.

(i) All data storage devices and media must be managed according to the APS Data Classification specifications and Data Handling procedures.

(j) It is strictly forbidden to download or store any sensitive data on end-user computing devices, including laptops, workstations and mobile devices.

Employee Onboarding Procedures

A master checklist for employee onboarding is maintained by HR/Facilities.
It is published in the HR system or the HR folder on APS’s internal file sharing site.

The HR Representative / Facility Manager is responsible to create an Issue in the Rally via Help Desk to initiate and track the onboarding process. The onboarding process should include the following IT/Security items:

  1. Training.

    • New workforce member is provided training on APS security policy, acceptable use policy, and given access to the Employee Handbook.
    • Records of training and policy acceptance is kept in the HR system.
    • The training and acceptance must be completed within 30 days of employment.

  2. Access.

    • Standard access is provisioned according to the job role and approval as specified in the HR onboarding Rally ticket.
    • Non-standard access requires additional approval following the access request procedures.
    • Request for modifications of access for any APS employee can be made using the procedures outlined in the Access Establishment and Modification policy and procedures.

  3. System configuration.

    • The end-user computing device (e.g. workstation or laptop) may be provisioned by IT to install necessary software, malware protection, security agents, and setting system configurations.
    • Users in a technical role, such as Development, may choose to self configure their system. In this case, the user is given configuration guidelines defined by IT and Security. The system must have the required security configuration and endpoint agents installed for monitoring and to ensure compliance.

Employee Exiting/Termination Procedures

A master checklist for employee existing/termination is maintained by HR/Facilities. It is published in the HR system or the HR folder on APS’s internal file sharing site.

  1. The Human Resources Department (or other designated department), users, and their supervisors (HR) are required to notify Security upon completion and/or termination of access needs and facilitating completion of the “Termination Checklist”.

  2. HR are required to notify Security to terminate a user’s access rights if there is evidence or reason to believe the following (these incidents are also reported on an incident report and is filed with the Security Officer):

    • The user has been using their access rights inappropriately;
    • A user’s password has been compromised (a new password may be provided to the user if the user is not identified as the individual compromising the original password);
    • An unauthorized individual is utilizing a user’s User Login ID and password (a new password may be provided to the user if the user is not identified as providing the unauthorized individual with the User Login ID and password).

  3. Security will terminate users’ access rights immediately upon notification, and will coordinate with the appropriate APS employees to terminate access to any non-production systems managed by those employees.

  4. Security audits and may terminate access of users that have not logged into organization’s information systems/applications for an extended period of time.

Employee Issue Escalation

APS workforce members are to escalate issues using the procedures outlined in the Employee Quick Reference. Issues that are brought to the Escalation Team are assigned an owner. The membership of the Escalation Team is maintained by the Chief Executive Officer or a delegate.

Security incidents, particularly those involving sensitive data, are handled using the process described in Incident Response. If the incident involves a breach of sensitive data, the Security Officer will manage the incident using the process described in Breach Notification. Refer to Incident Response for a list of sample items that can trigger APS’s incident response procedures; if you are unsure whether the issue is a security incident, contact the Security team immediately.

It is the duty of the incident owner to follow the process outlined below:

  1. Create an Issue in the Rally Security Project.
  2. The Issue is investigated, documented, and, when a conclusion or remediation is reached, it is moved to Review.
  3. The Issue is reviewed by another member of the Escalation Team. If the Issue is rejected, it goes back for further evaluation and review.
  4. If the Issue is approved, it is marked as Done, adding any pertinent notes required.
  5. The workforce member that initiated the process is notified of the outcome via email.

Continuous Education and Skills Development

APS provides employees the opportunity to attend conferences, trade shows, and/or ongoing training/studies relevant to their job function and business objectives.

Non-Compliance Investigation and Sanctions

All APS officers, employees, and associates are expected to review the complete set of policies at least annually, and to read and understand individual new policies or policy changes as they are communicated by company management.

Compliance Measurement

The APS management team will verify compliance with policies through various methods, including but not limited to, periodic walk-thrus, video monitoring, business tool reports, internal and external audits, and feedback to the policy owner.

Procedures

Workforce members shall report non-compliance of APS’s policies and procedures to the Security Officer or other individual as assigned by the Security Officer. Individuals that report violations in good faith may not be subjected to intimidation, threats, coercion, discrimination against, or any other retaliatory action as a consequence.

  1. The Security Officer promptly facilitates a thorough investigation of all reported violations of APS’s security policies and procedures. The Security Officer may request the assistance from others.

    • Complete an audit trail/log to identify and verify the violation and sequence of events.
    • Interview any individual that may be aware of or involved in the incident.
    • All individuals are required to cooperate with the investigation process and provide factual information to those conducting the investigation.
    • Provide individuals suspected of non-compliance of the Security rule and/or APS’s policies and procedures the opportunity to explain their actions.
    • The investigator thoroughly documents the investigation as the investigation occurs. This documentation must include a list of all employees involved in the violation.

  2. Violation of any security policy or procedure by workforce members may result in corrective disciplinary action, up to and including termination of employment. Violation of this policy and procedures by others, including business associates, customers, and partners may result in termination of the relationship and/or associated privileges. Violation may also result in civil and criminal penalties as determined by federal and state laws and regulations.

    • A fair disciplinary process will be utilized for employees are suspected of committing breaches of security. Multiple factors will be considered when deciding the response such as whether or not this was a first offense, training, business contracts, etc.
    • APS reserves the right to terminate employees in the case of serious cases of misconduct.
    • A violation resulting in a breach of confidentiality (i.e. release of sensitive data to an unauthorized individual), change of the data integrity, or inability to access data by other users, requires immediate termination of the workforce member from APS.

  3. The Security Officer facilitates taking appropriate steps to prevent recurrence of the violation (when possible and feasible).

  4. In the case of an insider threat, the Security Officer is to set up a team to investigate and mitigate the risk of insider malicious activity. APS workforce members are encouraged to come forward with information about insider threats, and can do so anonymously.

  5. The Security Officer maintains all documentation of the investigation, sanctions provided, and actions taken to prevent reoccurrence for a minimum of seven years after the conclusion of the investigation.

  6. When the Security Officer identifies a violation and begins a formal sanction process, they will notify the appropriate management or supervisors within 24 hours. That notification will include 1) identifying the individual sanctioned, 2) the reason for the sanction, and 3) specific procedures for service or account restriction / revocation or other disciplinary actions as required.

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