Insider Risk Policy Checklist: Privacy, HR and Legal Sign-Off

Retrospective: this article looks back at events from November 2019, written in 2026 with the benefit of hindsight.

Insider risk monitoring touches employee privacy. This checklist helps make sure policies have the right sign-off before you enable them.

Purpose and scope

• The business purpose is documented (for example, protecting trade secrets during employee departures).
• Monitored activities and data sources are listed.
• The policy is proportionate — scoped to specific data, groups or scenarios rather than everyone and everything.

Privacy

• Pseudonymization is enabled by default.
• Data retention for alerts and cases is defined.
• A privacy impact assessment has been completed where required.
• Employee notice obligations have been reviewed for each jurisdiction.

HR and legal

• HR agrees on how HR data (resignations, terminations, performance issues) will be used.
• Legal has reviewed monitoring under local employment law.
• Works councils or employee representatives have been consulted where required.

Access

• Investigator access is limited to a small, named group.
• Access is logged and reviewed.
• Escalation from pseudonymized alerts to identified users requires approval.

Process

• Triage and investigation steps are documented.
• Actions after confirmed incidents are defined (HR, legal, technical).
• False positives are reviewed and used to tune policies.

Review

• The program is reviewed at least annually by legal, HR and security together.