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DATE \l 8/24/95 Human Resource Process Controls PAGE 4 The New York Times Company Process Controls for Human Resources Introduction: This document details the internal control environment which will be created during the design of the HR Base processes. Several control objectives appear below. The risks each objective is designed to mitigate and the controls that will be implemented to achieve the objectives appear on subsequent pages. Each control description ends with the implementation vehicle it affects (i.e., system, process, policy, or change management). Overview of Objectives: The Integrity Of Employee Records Is Maintained. Human Resource Policies Comply With Applicable Laws And Regulations. Adequate Records Of Compliance Are Maintained. Employee Record Changes Are Properly Authorized And Accurately Recorded. Objective 1: The Integrity Of Employee Records Is Maintained. Risks: The company will incur legal or trade union action if confidential employee information is disclosed. Disclosure of confidential information will lower employee morale and loyalty. Business Process Controls: Restrict physical or electronic access to personnel records to authorized employees and managers with a genuine need for such information. Require that all access to personnel files be logged by the system if possible. (SYSTEM) Install adequate physical and logical security controls to restrict access to personnel information stored on the computer. (SYSTEM) Train human resource personnel and management in ethical standards and privacy issues. Discipline individuals who disclose confidential information. (CHANGE MANAGEMENT) Objective 2: Human Resource Policies Comply With Applicable Laws And Regulations. Risks: The company will incur fines or other penalties. The company will incur bad publicity and loss of reputation. The company will have difficulty attracting quality people. Business Proces