BSI C5:2020 HR-05 — Responsibilities in the event of termination or change of employment

What this control requires

Informs employees of ongoing security responsibilities post-termination or role change, specifying duration. Ensures continued compliance with confidentiality and security obligations to prevent unauthorized access or disclosure of cloud customer data after employment ends.

In plain English

Informs employees of ongoing security responsibilities post-termination or role change, specifying duration. In practice, this means you can prove you review cloud customer data-level controls on a defined cadence.

Why it matters

BSI C5 is the default cloud-security baseline German public-sector buyers and many DAX-listed enterprises expect; gaps here directly block procurement in the DACH region and frequently appear as must-have items in EU public-tender documents.

What an auditor looks for

A C5 attesting auditor (under ISAE 3000 / IDW PS 860) tests both the design and — for a Type 2 — the operating effectiveness over the attestation period. For each criterion they look for both the Basic and any in-scope Additional objectives.

Within Human Resources Security, the assessor will trace your implementation back to the catalogue reference (Criterion HR-05) and look for objective evidence on the latest two assessment cycles.

How to implement

1. Write a short policy stating intent, scope and named owner.
2. Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
3. Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
4. Review on a documented cadence and capture the review in the risk register or compliance tracker.

Operational checklist

• Review. Document the trigger, the owner and the cadence.
• Employment. Document the trigger, the owner and the cadence.
• Security. Document the trigger, the owner and the cadence.
• Confidentiality. Document the trigger, the owner and the cadence.
• Data. Document the trigger, the owner and the cadence.
• Scope: cloud customer data, management.

Evidence to collect

• Identity Scan. IAM / IdP exports — Entra ID, Okta, IAM Identity Center, Workspace directory — showing accounts, roles, MFA state and last sign-in.

Identity analytics (Okta, SailPoint, Access Analyzer) demonstrates least-privilege. Focus: Responsibilities in the event of termination or change of employment.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• ISO/IEC 27001:2022 A.8.23 — Web filtering
• SOC 2 (2017 TSC) CC1.5 — Accountability for Internal Control Responsibilities
• NIST SP 800-171 Rev. 3 3.13.4 — Information in Shared System Resources
• CIS Controls v8 6.1 — Establish an Access Granting Process
• ISO/IEC 27701:2025 A.3.8 — Identity management

Related controls in BSI C5:2020

• Criterion HR-01 — Verification of qualification and trustworthiness
• Criterion AM-05 — Commitment to Permissible Use, Safe Handling and Return of Assets
• Criterion IDM-03 — Locking and withdrawal of user accounts in the event of inactivity or multiple failed logins
• Criterion INQ-03 — Conditions for Access to or Disclosure of Data in Investigation Requests
• Criterion INQ-04 — Limiting Access to or Disclosure of Data in Investigation Requests
• Criterion PSS-03 — Online Register of Known Vulnerabilities

References

• Bundesamt für Sicherheit in der Informationstechnik (BSI) — BSI C5:2020
• Catalogue identifier: Criterion HR-05

Topics: identity accessidentity managementaccess reviewprivileged accesschange management