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CFPB Report: 2018-MO-C-001 January 22, 2018

The CFPB Can Further Strengthen Controls Over Certain Offboarding Processes and Data

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The CFPB's offboarding process for employees and contractors covers, among other things, the return of property, records management, and ethics counseling on conflicts of interest. We determined whether the agency's controls over those aspects of offboarding effectively mitigate reputational and security risks.

The CFPB can strengthen controls related to offboarding, including

  • deactivating personal identity verification and site badges more timely
  • maintaining complete documentation of assigned IT assets
  • communicating records guidance to separating individuals consistently
  • maintaining accurate and complete data on contractors

The agency ensured that executive employees (who are subject to ethics counseling) were briefed on postemployment restrictions and requirements and that nondisclosure agreements were maintained for most contractors in our sample.

This report contains recommendations.