As a small startup heavily reliant on contractors and lacking a complete board setup, should we be concerned about the absence of an employee handbook? How might the typical controls over employees, their workstations, and the board apply to our unique situation? Are there strategies to establish these controls even if we don’t have anything, or should we explore potential exclusions given our startup’s specific structure and dynamics?
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Good question
While the absence of an employee handbook might be more common in small startups, it’s still important to establish clear policies and controls to ensure a structured and compliant work environment.
HR and Leadership controls –
Since your startup relies heavily on contractors, developing a contractor-specific policy is crucial. This policy should outline security awareness expectations, data protection guidelines, and the contractor’s responsibilities in maintaining the company’s security posture.
There is a decision to be made.
Do you as the organization takes the responsibility to provide HR security related controls (I.e security awareness training, policy acknowledgment etc..) or do you delegate these responsibilities to the contractors themselves?
Regardless of the decision, formalizing it through a contractor policy or an extension of the existing employee handbook policy is essential.
In scenarios where the contractors bear the responsibility, their acknowledgment becomes pivotal as substantiating evidence during the audits.
Workstations –
Even without a traditional office setup, workstation security remains important. Contractors should be educated about secure practices for remote work.
Start with the decision – is this your responsibility or your contractor? Document this within the contractor policy or existing handbook or other appropriate policy and have it acknowledged by the contractors.
Board of Directors –
While you might lack a traditional board, having oversight mechanisms is still vital. Is there an executive management team, even if comprised of a solitary individual, who can assumes the ‘oversight’ role?
That oversight responsibility is what will need to be provided to your auditor.
At the end of the day, the auditor wants to see that you have thought through these controls. Therefore a well documented policy that explains your practices and unique set up for potential controls non-applicability is essential.