Scope
Define covered systems, user categories, and data types (PII, PHI, education records). State whether cloud, on-prem, and third-party tools are included.
A written policy reduces legal and operational risk, ensures consistent handling of sensitive employee data, and supports compliance with ESIGN, UETA, HIPAA, and applicable state rules. It also helps IT and HR coordinate access controls, audits, and incident response.
This policy guides multiple internal groups and external stakeholders.
Periodic review and coordinated change control ensure the policy remains aligned with legal obligations and operational needs.
The HR Director typically approves the policy document and is accountable for content, updates, and employee communication. They coordinate with Legal and IT to ensure operational and compliance alignment.
The CISO or equivalent signs off on technical controls, encryption standards, authentication methods, and audit requirements, and confirms that the platform meets organizational security policies.
Define covered systems, user categories, and data types (PII, PHI, education records). State whether cloud, on-prem, and third-party tools are included.
Describe role-based access, least-privilege principles, periodic access reviews, and account termination procedures tied to offboarding.
Specify accepted methods (SSO, MFA, hardware tokens), session timeout requirements, and password complexity rules.
Classify records (public, internal, confidential, restricted) and prescribe encryption, masking, and sharing rules for each category.
Outline permitted eSignature methods, retention, audit trail requirements, and references to ESIGN (15 U.S.C. ch.96) and UETA.
State breach notification procedures, roles, timelines, and documentation requirements for security incidents affecting HR data.
| Field | Configuration |
|---|---|
| Access provisioning | Automate via SSO/SCIM from HRIS |
| MFA enforcement | Require MFA for all privileged accounts |
| Audit logging | Retain logs for 7 years with tamper protection |
| Automated offboarding | Revoke access within 24 hours of termination |
Specify minimum platform capabilities to meet policy controls and legal requirements.
| signNow | DocuSign | Adobe Sign | PandaDoc | HelloSign | |
|---|---|---|---|---|---|
| Starting Price | $8/user/mo | $15/user/mo | $14/user/mo | $19/user/mo | $15/user/mo |
| Free Trial | 7-day free trial | Varies by plan | Varies by plan | Varies by plan | Varies by plan |
| Bulk Send | Yes (Business Premium) | Yes | Yes | Yes | Limited |
| Audit Trail | Yes | Yes | Yes | Yes | Yes |
| HIPAA Compliant | Yes (BAA available) | Yes | Yes | No | No |
| Envelope Cap | No cap | 100 envelopes/user/year | Varies | Varies | Varies |
Annual review cycle with documented sign-off
Quarterly or semi-annual access reviews for privileged accounts
Provision accounts within 24 hours of start date
Revoke access within 24 hours of termination
Report suspected breaches immediately and follow legal notification timelines
A hospital system required BAAs for all vendors handling PHI and added MFA for access to employee health records
A tech company integrated SSO and automatic offboarding with its HRIS to enforce account termination
| Signature Type | Definition | Use Case |
|---|---|---|
| Simple eSignature | image overlay | low-to-medium risk hr forms |
| Click-to-sign | button consent | acknowledgements and policies |
| PKI digital signature | certificate-based | high-assurance needs and non-repudiation |
| Biometric | behavioral data | supplemental authentication |