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TERMINATION OF EMPLOYMENT [DP232]
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        Scope: Enterprise
        Distribution: All employees
        Purpose: To ensure only current employees and contractors are able to access information systems.
        External Regulation or Standard: 45 CFR 164.308(a)(3)(ii)(C) ‐‐ Workforce Security, 45 CFR 164.308(a)(ii)(C) ‐‐ Security Management
        Process

         Who is Responsible    Statement     Policy, Standard, or Procedure Statement
                                Number
         Employees               DP232.1     Violations of the organization's data security policies will be subject to the
                                             organization's Corrective Action policies and procedures.


         Directors, Managers     DP232.2     When an employee or contractor is terminated, the supervisor must complete the IT
         and Supervisors, with               Termination Form indicating the change. In cases where immediate terminations
         Asset Protection, IT                occur, the supervisor must also contact the IT Staff and Asset Protection or the store
         Staff and                           or program manager for off‐site locations immediately prior to, or upon termination,
         Administrators of                   to assist with immediate termination to systems and secure areas. The IT Staff will
         Managed Systems                     terminate access to mobile devices connected to the system, including synched
                                             phones.

                                             The IT Staff and Asset Protection must disable access if requested by a director,
                                             manager or supervisor pending formal completion of the IT Termination Form.

                                             If a termination is anticipated (due to resignation or completion of a contract), the
                                             supervisor must complete the IT Termination Form with the projected termination
                                             date and time and submit it at least one week before the termination date for
                                             scheduling. In all cases, the supervisor must complete all items contained in the
                                             Termination To‐Do‐List prior to or immediately upon termination.

                                             The supervisor must also contact administrators of other managed systems
                                             (GoodTrak, Raiser’s Edge, other), to ensure access is immediately terminated to
                                             those systems.




         Directors, Managers     DP232.3     Access privileges of employees and contractors will be terminated immediately upon
         and Supervisors to                  a job termination. See GESM OFFICE EMPLOYEE TERMINATION CHECKLIST.
         request, with Asset
         Protection and/or off‐
         site Managers and IT
         Staff to do.
         Directors, Managers     DP232.4     When a person leaves employment, that person's supervisor must collect from the
         and Supervisors                     person all assets of the organization such as laptops, phones, electronic media, and
                                             documents. Also see GESM OFFICE EMPLOYEE TERMINATION CHECKLIST.



         Directors, Managers     DP232.5     When an employee or contractor changes roles within the organization, the
         and Supervisors                     supervisor must complete the IT Job Change Form including limiting previous
                                             permissions if needed, or increasing permissions based on new job responsibilities.
                                             Access privileges must also be changed to ensure the employee or contractor has
                                             appropriate access to facilities and secure areas.




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