HR teams handle vast amounts of sensitive information, including identity documents, bank details, medical records, and performance reviews. This data moves across recruitment and payroll systems, managers, and external service providers, with every handover creating a potential security risk.
The scale of India's cybersecurity challenge makes data protection even more critical. According to CERT-In figures cited by the Ministry of Home Affairs in March 2026, India recorded over 29.44 lakh cybersecurity incidents in 2025.
Protecting sensitive employee data cannot be the responsibility of HR alone. HR, legal, and IT departments must work together to establish clear accountability, strengthen security controls, and ensure compliance with applicable data protection regulations.
Defining the Responsibilities of HR, Legal, and IT
Shared accountability means each function must know what it decides and when to involve another function.
HR: Managing Employee Data Responsibly
HR should map the information collected throughout the recruitment, onboarding, employment, and exit processes. This enables them to limit what is collected to what is necessary, explain their privacy practices to employees, and coordinate requests to access or correct their records. A standardized checklist could help prevent recruiters from requesting documents they don't actually need. HR must also flag role changes and departures so IT can update access and retention controls accordingly.
Legal: Interpreting Data Protection Requirements
Legal should identify the grounds for processing the employee data (i.e., where consent is required and where some other lawful basis applies). They should review the privacy notices, vendor agreements, retention policies, and employee rights. This will help them determine the relevant breach-notification obligations and translate regulatory changes into actions for the other teams.
IT: Securing Systems and Managing Access
IT should implement controls via encryption, multi-factor authentication, limited access, and monitoring. Access to payroll or performance data should be on a strictly 'need-to-know' basis and aligned to job role. IT must have secure backup procedures in place, support scheduled deletion, and investigate any anomalous activity. Access reviews can identify accounts that are still active after an employee has left. The findings of these reviews can be valuable to HR and Legal in understanding the potential scale of a data incident.
How HR, Legal, and IT Can Build a Coordinated Compliance Framework
Clear roles need a shared process behind them. You need to document your decisions and approvals so you can trace responsibility during an audit. The following four practices link day-to-day data handling with legal and technical oversight.
1. Create a Shared Data Inventory
HR is responsible for having the employee data and knowing what it’s for. IT should know where it’s stored (including on third-party platforms) and who can access it. Legal should review the justification for the processing and the applicable retention rules. This way, the three of them can assign an owner to each data category.
2. Agree on Access and Vendor Approval Rules
HR should define who needs access to employee records, while IT grants and reviews permissions. Legal checks proposed data sharing and vendor contracts. Before adopting a new payroll or recruitment platform, all three teams should review its data requirements, security measures, and deletion arrangements.
3. Establish a Joint Breach Response Plan
Once an incident is detected and contained, preserve the evidence and identify the affected systems. Legal should look at the reporting obligations and timeframes (including the relevant CERT-In requirements). HR should identify affected staff and help prepare accurate communications where required. Named contacts and an agreed escalation path ensure there is no confusion in the first hours of an incident.
Making Data Protection a Shared Organizational Practice
A vendor contract ends, but the vendor still has access to employee records. An employee changes roles, but their old permissions carry over. These gaps are easiest to catch when teams review access as part of the change itself. HR can agree with IT and procurement on who checks permissions and who removes access when it’s no longer needed. When an employee flags a concern, they should know where to raise it and who will follow up. Employee data may change hands many times. The organization’s responsibility to protect it is assessed after every handover.
Was this resource helpful?
Validate your HR expertise
Earning your SHRM-CP credential makes you a recognized expert and leader in the HR field.
Related Content
Transform HR with mobile technology to streamline workflows, enhance communication, and boost employee engagement across distributed teams.
A new study found that talent development practitioners believe performance-based assessments are more effective at measuring employee learning outcomes than knowledge tests.
As AI makes deeper inroads into organizations, employee concerns about the technology continue to grow. Here's how HR leaders can address the fear of AI among their own staff, as well as in the wider organization.