HR and Personnel Security
| Title | HR and Personnel Security |
| Doc# | POL-HUMA-017 |
| Version | 1.0 |
| Date | 21-09-2023 |
| Owner | Head of People (A. Desai) |
| Approved By | CISO (I. Ferreira) / COO (G. Sullivan) |
| ISO/IEC 27001:2022 | A.6.1–A.6.5 — HR security (screening, terms, awareness, disciplinary, termination) |
This policy governs the personnel-security lifecycle at Tessera: how we screen, onboard, train, manage and offboard the people who touch our systems and tenant data. It implements the human-resource security controls in Annex A.6 of ISO/IEC 27001:2022 and our obligations under the Privacy Act 1988 (Cth), particularly APP 11 (security of personal information). The Head of People owns this policy; line managers and the Security team operate it.
Policy Statements
In addition to the roles and responsibilities set out in Roles and Responsibilities, Tessera requires that:
Screening (A.6.1). Background verification checks are carried out on all prospective employees and contractors before they start, proportional to the role, the classification of information they will access, and the perceived risk. Checks are conducted in accordance with Australian law and the candidate’s informed consent.
Terms and conditions (A.6.2). Every employee, contractor and third-party user signs a written agreement that binds them to this policy, the Acceptable Use Policy (POL-SEC-022) and Tessera’s confidentiality obligations before they are granted access.
Awareness and training (A.6.3). All workforce members complete security and privacy awareness training during onboarding and at least annually thereafter. Training covers the Privacy Act 1988 and the Australian Privacy Principles, the Notifiable Data Breaches scheme, and Tessera’s incident and breach-reporting expectations.
Disciplinary process (A.6.4). A fair, documented disciplinary process applies to breaches of this and related policies, up to and including termination and referral to authorities.
Termination and offboarding (A.6.5). Offboarding removes access to all Tessera systems, returns company assets, and restates obligations that survive termination.
Workforce members must not transmit sensitive information through unmanaged channels or post it to public forums. Where technical support requires sharing diagnostic detail, the data must be sanitised first.
Controls and Procedures
HR Management and Reporting
Tessera maintains workforce personnel records in Employment Hero. The Head of People is the system owner. Personal information is retained no longer than necessary for the purpose for which it was collected (APP 11.2), in line with the retention schedule.
Organisation Structure
A reporting structure aligned to Tessera’s business lines is maintained and published in the org chart on the intranet. Reporting lines are reviewed when a team is restructured.
Job Functions and Descriptions
Position descriptions document the skills, responsibilities, access profile and knowledge levels required for each role, and are updated when a role changes.
Performance Reviews and Feedback
Employees receive ongoing feedback from their manager and peers. Formal performance reviews are conducted annually using the performance module in Employment Hero. Performance measures and incentives reflect the responsibilities of the role and the expected standards of conduct.
Acceptable Use of End-user Computing
Detailed acceptable-use obligations are set out in the standalone Acceptable Use Policy (POL-SEC-022). The points below highlight the HR-relevant obligations and apply to all workforce members:
Per the security architecture, all workforce members are treated as remote users and must follow remote-access controls (MFA, managed device, encrypted storage).
Use of Tessera systems is monitored by the IT and Security teams in accordance with the Privacy Act and applicable workplace-surveillance law.
Computing devices (company-issued or BYOD) must not be left unattended in public.
Whole-disk encryption must be enabled on every device that stores or accesses company data.
Use only approved software with a valid licence, installed from an approved source. Personal software must not be used for business purposes, and vice versa.
Sensitive or confidential email must be encrypted.
Sensitive or confidential data must not be posted to public forums or chat rooms. Sanitise data before posting for technical support.
Anti-malware protection and monitoring must be installed and active on all endpoints that could be affected by malware.
All storage media must be handled per the Data Classification and Data Handling procedures.
Sensitive data must not be downloaded or stored on end-user devices.
Mobile devices must not connect directly to Tessera production environments.
Employee Screening Procedures
Tessera advertises roles, assesses technical skills and cultural fit through structured interviews, and performs background checks — identity, right-to-work in Australia, referees, and, where the role warrants, criminal-history and qualification checks — before the start date. Checks are run by the People team and a third-party screening provider engaged through Procurement.
(I. Ferreira, note to self: confirm the screening list still lines up with ISMS-PR-014 before the Stage 1 audit — the right-to-work wording changed when we updated the joiner-mover-leaver procedure.)
Employee Onboarding Procedures
A joiner checklist is maintained by the People team and published in the HR system. The People Coordinator raises a joiner ticket in the People & IT project in Jira to track provisioning and training.
The onboarding process covers:
- Training.
- Security and privacy awareness training covering this policy, the Acceptable Use Policy, and the Employee Handbook.
- Privacy Act / APP / NDB awareness is the default baseline for all new starters.
- Staff who support tenants that are US healthcare providers also complete HIPAA awareness training, and a Business Associate Addendum is reflected in the tenant’s contract.
- Records of training and policy acceptance are kept in Employment Hero and must be completed within 30 days of the start date.
- Access.
- Standard access is provisioned to the role profile recorded on the Jira joiner ticket.
- Non-standard access follows the Access Establishment and Modification procedures.
- Joiners, movers and leavers are run through the joiner-mover-leaver procedure (ISMS-PR-014).
- System configuration.
- IT provisions the end-user device with the standard image, endpoint agent, encryption and required software.
- Engineers and other technical roles may self-configure within published IT and Security baselines, provided the endpoint agent and required security configuration remain in place.
[Reviewer, A. Desai, 2025-03-04: the joiner checklist still references the old “new starter pack” PDF that was retired with the 2024 HRIS migration — replace with the Employment Hero onboarding workflow before the next review.]
Employee Exiting / Termination Procedures
A leaver checklist is maintained by the People team and published in the HR system. When a termination or resignation is confirmed, the People team raises a leaver ticket in the People & IT Jira project; IT and Security action the access and asset steps.
- The People team notifies IT and Security of a confirmed termination or resignation, and the effective date and time.
- All system access must be revoked within 2 hours of termination, in line with the offboarding procedure (ISMS-PR-014). This covers SSO / identity provider accounts, cloud console access, source-code repositories, SaaS applications and VPN.
- Company assets (laptop, phone, keys, access card) are returned and recorded against the leaver ticket. (Asset return was previously tracked in a separate Return-of-Assets register that has since been folded into the Jira leaver ticket — some older runbooks still reference the old register.)
- Surviving obligations — confidentiality, IP assignment, return of company information — are restated in writing.
- Where there is evidence of misuse, a user’s access may be suspended immediately and before the formal termination date; such cases are recorded as a security incident (see Incident Response).
- Security periodically audits for accounts that have not been used for an extended period and disables them.
Employee Issue Escalation
Workforce members escalate concerns through their manager or the People team. The membership of the Escalation Team is maintained by the CEO or their delegate.
Security incidents, particularly those involving personal or tenant data, follow the Incident Response process. Suspected privacy breaches follow the NDB Playbook (SOP-PRIV-001). The incident owner:
- Raises an issue in the Security project in Jira.
- Investigates and documents it, then moves it to Review.
- Has a second reviewer check the conclusion; rejected items return for further work.
- Marks approved items Done, with notes.
- Notifies the reporter of the outcome.
Whistleblower Policy and Process
Tessera requires high standards of conduct from all workforce members. This section aligns with the whistleblower protections in Part 9.4AAA of the Corporations Act 2001 (Cth), which protects eligible whistleblowers who disclose reportable conduct about Tessera or a related body corporate.
- Reportable conduct. Workforce members are encouraged to report:
- dishonest, fraudulent or corrupt conduct;
- illegal conduct or a breach of any law enforced by the ACCC, ASIC or another regulator;
- conduct that endangers the public or the financial system; and
- conduct that otherwise poses a serious risk to Tessera’s reputation or viability.
Eligible whistleblowers. Officers, employees, contractors and their relatives, dependants and spouses can qualify for protection under Pt 9.4AAA.
How to report. Reports can be made to the Head of People, the CEO, the CFO, or the external Whistleblower Officer engaged by Tessera. Reports may be made anonymously and still qualify for protection.
Confidentiality. The identity of a whistleblower, and information likely to identify them, is kept confidential to the fullest extent permitted by law, and is disclosed only with consent or where the law requires or permits.
No detriment. Tessera prohibits any act that causes detriment, or threatens detriment, to a person because they made, or may make, a protected disclosure. Workforce members who breach this prohibition are subject to disciplinary action up to and including termination. A whistleblower who suffers detriment may seek compensation and other remedies through the courts.
Investigations. Reports are handled by the Whistleblower Officer and reported to the Audit and Risk Committee. Frivolous or knowingly false reports made maliciously are a disciplinary matter; a report made honestly but ultimately unsubstantiated is not.
Employee Performance Review Process
Formal performance reviews are conducted annually using the performance module in Employment Hero.
- 360° feedback is gathered from colleagues who work closely with the employee.
- The employee completes a self-assessment covering outcomes and behaviours.
- The manager reviews the self-assessment and peer feedback and documents the rating.
- The final review is signed by the employee and the manager.
Employee Incentives and Rewards
Tessera recognises contribution through peer recognition, manager acknowledgement and the rewards available through the Employment Hero perks module. Recognition is intended to reinforce behaviours that support security, service and teamwork.
Continuous Education and Skills Development
Employees may attend conferences, training and study relevant to their role, subject to manager approval and the training budget.
Non-Compliance Investigation and Sanctions
Workforce members must report suspected non-compliance with this or any related policy to the Head of People or the Security team. Good-faith reporters are protected from retaliation.
The Head of People, with the Security team, investigates reported violations. An investigation may include:
- collecting and reviewing logs and audit trails;
- interviewing those who may be aware of or involved;
- requiring cooperation from all individuals; and
- giving the individual an opportunity to respond.
The investigator documents the investigation as it proceeds, including the individuals involved.
Violations may result in corrective action up to and including termination. Violations by contractors, customers or partners may result in termination of the relationship and may be referred to law enforcement.
- A fair process weighs factors such as whether this is a first offence, the individual’s training, and the seriousness of the conduct.
- Serious misconduct may warrant summary termination.
- A violation that causes a breach of confidentiality, a change to data integrity, or denial of access for others may warrant immediate termination.
The investigator recommends steps to prevent recurrence.
Suspected insider threats are handled by a small, privileged team convened by the CISO and the Head of People; reports may be made anonymously.
Investigation records are retained for a minimum of seven years.
When a formal sanction is commenced, the Head of People notifies the individual’s manager within 24 hours, setting out the individual, the reason, and the access restrictions or other actions to be applied.