Workforce Verification and Privacy: A Guide For InfoSec

For many security teams, the 2023 MGM Resorts cyberattack was a wake-up call. A single vishing attack exploited weak identity assurance in help desk workflows and disrupted casino and hotel operations for days, causing hundreds of millions in losses and reputational damage.

The breach revealed a disconcerting new reality: Just one compromised employee account can enable attackers to bypass the entire security perimeter, regardless of an organization’s size or security budget.

To prevent account takeover and social engineering attacks, many security teams are turning to workforce identity verification. It’s the process of ensuring every member of your workforce is who they claim to be. Verification works by binding a user's claimed identity to their real-world identity using methods like government ID verification, selfie liveness checks, and passive signals.

Workforce identity verification is a critical part of mitigating insider threats and catching fake candidates before they're hired. But getting it right requires addressing serious privacy questions. In this article, we’ll discuss a few of the major privacy best practices to consider before implementing workforce verification.

Practice Zero Trust and least privilege access

When you collect employee verification data, there’s a real risk that threat actors could get to it. In the context of workforce verification, Zero Trust addresses this by continuously validating that the right person is accessing the right data at the right time for the right reason.

The combination of Zero Trust and the principle of least privilege access policies ensures that only individuals who have a strict need to review employee identity data, such as security or HR teams, can access data when necessary.

Here’s what Zero Trust can look like in practice:

Role-based access controls (RBAC): Start by segmenting access to employee verification data using RBAC. For example, your IT help desk and talent teams might see only verification status (pass/fail), while your compliance team can access audit logs.
Time-based access: Session monitoring and time-bound credentials can help ensure access doesn't persist longer than necessary.

Limit access to employee personally identifiable information (PII)

Verifying employee identities often means collecting sensitive PII. For example, most government IDs include a full name, date of birth, address, and other personal information.

Restricting access to PII is consistent with requirements under GDPR, CCPA, and similar privacy frameworks, which generally mandate purpose-limited data access. (However, obligations vary by jurisdiction and organizational context.)

It's also essential for security. Every additional person with access to sensitive data increases the risk of insider threats, credential compromise, and accidental exposure.

To limit exposure:

Implement RBAC with field-level restrictions to layer on contextual restrictions
Enable automatic PII censoring so sensitive fields like addresses or birthdates are redacted by default
Audit access logs regularly to ensure permissions stay aligned with roles as people change jobs or leave the organization

Practice data minimization: Keep employee and customer data separate

If you're already using identity verification for customers, you've likely built up a repository of consumer PII. When you implement workforce verification, you must keep workforce data separate from customer data.

GDPR's data minimization principle (Article 5) requires that you collect and retain only what's necessary for a specific purpose. Mixing employee and customer data is inconsistent with this principle because the two datasets serve entirely different purposes with different legal bases, retention requirements, and access justifications.

Beyond legal requirements, keeping employee and customer data separate is good data hygiene. Here are a few ways to keep your data separate:

Keep workforce data in a completely separate tenant. Employee verification should exist in a different system or at minimum, a fully segregated tenant, with independent access controls, retention policies, user permissions, and audit logs.
Implement this separation at the vendor level. If you use a third-party verification provider, insist on a mandatory separate tenant structure.
Audit the separation regularly. Periodically, confirm that your access policies, data residency settings, and retention schedules remain aligned with each dataset's purpose.

Decide how long you’ll retain data and why

Once you've verified an employee, how long should you keep their data? The decision depends on your organization's risk tolerance, regulatory obligations, and operational needs. Some security teams opt for minimal retention, while others keep it for months or years to support fraud investigations, compliance audits, or reverification needs.

Here’s what to consider. (Note that some regulated industries or jurisdictions impose specific mandatory retention periods that may override general best-practice guidance.)

Short retention (immediate to 90 days)

Short retention aligns with data minimization principles, reduces your privacy exposure, and limits the risk of that data being breached.

The downside is that you lose the ability to investigate fraud after the fact. If you suspect an employee was verified using a stolen identity or deepfake, and the verification data has already been deleted, you have no evidence to review. You also won’t be able to reverify the same employee against the original verification data if they need to prove their identity again later.

Longer retention (six months to 2+ years)

Longer retention supports fraud detection, compliance audits, and operational continuity. For example, say that an employee onboarded and authenticated for sensitive data access with an iPhone. Months later, the employee unexpectedly tries to reset their password with an Android device. With longer data retention, you’d be able to flag the difference using passive signal analysis.

The trade-off is increased privacy risk: The longer you retain data, the more exposure you carry. Longer retention can also entail more data subject access requests to process, more records to audit, and a larger volume of sensitive data to secure.

Determine your data residency policies

Data residency refers to where you’ll physically store and process employee data. It can be one of the most complex privacy decisions you’ll navigate: Some jurisdictions require that personal data collected from residents be stored within their borders, while others impose strict conditions on cross-border data transfers.

Consider these best practices for data residency:

Identify your employees’ locations. You’ll need to understand which jurisdictions' laws apply to them.
Review your vendor's Data Processing Agreement (DPA). Clarify controller/processor roles, understand where data may be transferred, and confirm what safeguards are in place for cross-border transfers.
Audit your data flows regularly. As you hire employees in new countries or change verification workflows, your residency requirements may shift accordingly.

Learn more about how data residency laws work.

What to look for in a vendor's compliance posture

If you decide to work with a third-party vendor, it will likely handle sensitive employee data as well. That makes its security and compliance posture as important as yours.

During vendor evaluation, consider each vendor’s certifications, security practices, and privacy frameworks. Here's what to look for:

Independent security audits: SOC 2 Type II and ISO 27001. These indicate that the vendor's security posture has been independently validated and meets both US and international standards.
Identity verification standards: Kantara IAL2. This certification validates that the vendor's verification process meets NIST SP 800-63-3 standards for identity proofing.
Industry-specific compliance: HIPAA. If you operate in healthcare or handle Protected Health Information (PHI), confirm the vendor is HIPAA-compliant and willing to sign a Business Associate Agreement (BAA). Even if you're not in healthcare, HIPAA compliance is a strong signal that the vendor can meet rigorous data protection standards.
GDPR and CCPA compliance tools: Look for vendors that can provide configurable data retention and deletion controls, DPAs that clarify controller/processor roles, and data residency options.

How Persona can help

Our company, Persona, helps organizations verify employees at the moments attackers target most. Leading companies like Okta, Twilio, and Figma trust us to solve today’s identity challenges and those still to come.

Trust is built on security and privacy. That’s why Persona adheres to the highest industry standards, maintaining compliance and certifications to safeguard you and your employees’ data:

Certifications and compliance. Our security and privacy frameworks are based on and aligned with global standards that ensure the highest grade of security is met and exceeded.
Security. With multilayered security mechanisms, our in-depth strategy protects against a wide range of threats.
Privacy. Every decision we make begins with the safety and privacy of you and your employees' data in mind.

If you're evaluating how to meet your privacy obligations while verifying employees, we're here to help. Contact our team to discuss your specific compliance requirements and how Persona can support your workforce security strategy.