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“68% of breaches involved a non-malicious human element, like a person falling victim to a social engineering attack or making an error.”

— Verizon, 2024 Data Breach Investigations Report | Source

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In an era of digital transformation and growing demand for IT professionals, body leasing has become a common collaboration model in the technology industry. However, along with flexibility and access to qualified person

el, this model brings with it significant challenges in terms of data security. How do you effectively protect a company’s confidential information when outside specialists have access to it? What controls should be implemented to minimize the risk of data leakage?

In this comprehensive guide, we examine the key aspects of data security in the context of body leasing. We present practical solutions to the most common challenges faced by organizations using this collaboration model. From legal and regulatory aspects to operational processes to best practices for long-term collaboration, we provide the comprehensive knowledge necessary for IT managers, security professionals and business decision makers.

We pay special attention to the practical aspects of implementing security policies, presenting proven methods for managing access, monitoring user activity and responding to security incidents. Based on real-world experience and current industry standards, our guide is a comprehensive resource for organizations seeking to effectively secure their assets under a body leasing model.

What is body leasing and what are its key aspects in terms of data security?

Body leasing, also known as employee leasing, is a model of cooperation in which a third-party company makes its specialists available for the implementation of client projects. In the context of the IT industry, where data is a critical business asset, information security takes on particular importance. A specialist working in the body leasing model is given access to the client’s sensitive data, systems and infrastructure, which creates a complex web of dependencies in terms of information protection responsibilities.

The key aspect here is the tripartite relationship between the company using the service (the customer), the body leasing service provider and the specialist himself. Each party has specific duties and responsibilities with regard to data protection. The customer, as the data controller, must provide appropriate technical and organizational measures. The service provider is responsible for the proper preparation and verification of the specialist, while the employee himself is required to follow security procedures.

The body leasing model requires special attention in the area of data access control. The specialist often works in a hybrid environment, using both the client’s resources and his own tools. This requires a precise definition of responsibility boundaries and the implementation of mechanisms for monitoring and controlling the flow of information.

What are the risks and threats to data security posed by body leasing?

Collaboration in the body leasing model generates a number of specific data security risks. The primary risk is the potential leakage of confidential information, which can occur both inadvertently and intentionally. The leasing specialist often has access to critical company resources, which increases the potential attack surface and requires the implementation of additional controls.

The problem of so-called “shadow IT,” i.e. the use of unapproved tools and applications by employees, is also a significant risk. In the case of body leasing, this phenomenon can be particularly dangerous, as a specialist may try to use proprietary solutions that have not been analyzed for security, which can be a gateway for cyber threats.

Another challenge is the turnover of leased employees. Every change in persoel involves granting and revoking privileges, which, if not properly managed, can lead to active accounts and accesses being left for people who no longer work with the organization. This, in turn, poses a serious risk to data security.

What laws govern data security in body leasing?

The basic legal act governing the protection of personal data in the context of body leasing is the Regulation on the Protection of Personal Data (RODO). It defines the fundamental principles of data processing and the roles of various entities in the data protection process. Particularly relevant to body leasing are the provisions on entrustment of data processing and the responsibility of the data controller.

In addition to the RODO, sector-specific regulations are also relevant, especially for projects implemented for entities in regulated industries, such as finance or healthcare. For example, in the banking sector, financial supervision regulations that impose specific information security requirements are additionally applicable.

In the context of international cooperation, regulations on data transfer outside the European Economic Area are crucial. This is especially true when the body leasing company or its employees are located in third countries. This requires the use of appropriate legal mechanisms, such as standard contractual clauses or binding corporate rules.

What are the roles and responsibilities of each entity with respect to data protection?

In the body leasing ecosystem, each entity has a specific role in the data protection system. The company using the service (the customer) most often acts as the data controller, which means that it is the one who determines the purposes and means of data processing and bears the ultimate responsibility for data security. Its responsibilities include ensuring appropriate technical and organizational measures and supervising the correctness of data processing.

A body leasing service provider can act as a processor (processor) or sub-processor, depending on the structure of the cooperation. Its main task is to ensure that the professionals provided are qualified and aware of their data protection responsibilities. The provider is also responsible for the proper training of employees and verification of their reliability.

A specialist working in the body leasing model is directly responsible for adhering to the client’s security policies and procedures. His role includes not only the technical aspects of data protection, but also the reporting of potential security incidents and active participation in information confidentiality processes.

What documents and RODO clauses are necessary when implementing body leasing?

The fundamental document in the context of the RODO at body leasing is the data processing entrustment agreement. It defines the scope and purpose of data processing, the obligations of the parties and the required security measures. The document should be precise and tailored to the specifics of the cooperation, taking into account, among other things, the issues of subcontracting the processing or the principles of auditing.

Appropriate confidentiality clauses are also necessary and should be included both in the body leasing framework agreement and in individual contracts with specialists. These clauses must clearly define the scope of information covered by confidentiality and the consequences of violating obligations.

In the case of international body leasing, it is also necessary to implement appropriate legal mechanisms to regulate the transfer of personal data. These can be standard contractual clauses approved by the European Commission or binding corporate rules if the cooperation is within a corporate group.

When is a data processing entrustment agreement required?

A data entrustment agreement becomes necessary when access to personal data is transferred between organizations under body leasing. The key factor determining the need for such an agreement is the actual scope of access to data that the leased employee receives. If, as part of his duties, he will be processing personal data on behalf of the client, an entrustment agreement is absolutely required.

It is particularly important to define precisely the circumstances under which such an agreement should be concluded. This is especially true if the specialist has access to production systems containing personal data, customer databases or employee records. Even if access to personal data is not the main purpose of the cooperation, but is a necessary element for the implementation of the entrusted tasks, the entrustment agreement must be concluded.

In business practice, it is recommended to conclude an entrustment agreement even in borderline cases, when the scope of access to personal data is not fully defined at the beginning of the cooperation. This approach ensures compliance with the provisions of the RODO and minimizes the legal risks associated with improper processing of personal data.

How to properly onboard a leased employee for safety?

The process of onboarding a leased employee requires special attention in the area of information security. The first step should be to conduct comprehensive training on the security policies in place at the client organization. Such training must cover not only the theoretical aspects of data protection, but also practical security scenarios and procedures specific to the work environment.

A key element of onboarding is to precisely define the scope of access to systems and data. The process should be based on the principle of minimum privileges, where an employee is given only those privileges necessary to perform his or her assigned tasks. This requires close cooperation between the IT department, the security department and project managers.

Documentation of the onboarding process is also an important aspect. Each assignment of privileges should be properly documented, and the employee should confirm that he or she is familiar with security policies and data protection commitments. It is also worth introducing a system of regular reviews of authorizations to ensure they are up-to-date and relevant to the tasks at hand.

How do you manage data access and permissions for leased employees?

Access management for leased employees requires the implementation of a multi-level control system. The foundation is the implementation of Zero Trust, where every access must be explicitly authorized and regularly verified. Organizations should use advanced identity and access management (IAM) systems that enable precise control of authorizations and their automatic termination upon termination.

In the context of daily operations, monitoring user activity is crucial. SIEM (Security Information and Event Management) systems allow you to keep track of access to sensitive data and quickly detect potential security breaches. It is also worth considering the implementation of DLP (Data Loss Prevention) solutions, which help prevent unauthorized data transfer outside the organization.

Effective access management also requires regular entitlement audits. For long-term projects, it is particularly important to implement an access recertification process, during which the legitimacy of the privileges held is verified. This process should be automated and supported by appropriate tools, allowing for rapid response to changes in organizational structure or responsibilities.

How to ensure security when leasing professionals work remotely?

Remote work by leased professionals introduces additional data security challenges. A basic requirement is to ensure secure connection to the client’s infrastructure through encrypted communication channels, most often using a VPN. Such connections should be further secured through multi-level authentication (MFA) and monitored for unusual activity.

Adequate security of endpoints, or terminal devices used by leased employees, is also important. Organizations should clearly define minimum security requirements for such devices, including up-to-date antivirus software, disk encryption and automatic screen locking, among others. For particularly sensitive projects, consider providing leased employees with dedicated, properly configured workstations.

How do you protect your company’s intellectual property and confidential information?

Protection of intellectual property in the context of body leasing requires a comprehensive approach, combining legal, organizational and technical solutions. The foundation is the precise definition in contracts of the scope of intellectual property rights and the rules for the use of works created in the course of cooperation. It is also crucial to clearly define which elements of know-how and technological solutions constitute the client’s business secrets.

Effective protection of confidential information requires the implementation of a data classification system that makes it possible to clearly define the level of confidentiality of individual information and the associated security requirements. In practice, a multi-level classification model works well, where each level is associated with specific restrictions on access, storage and transmission of information.

It is also important to control the flow of information between the client environment and external systems. Organizations should implement Data Loss Prevention (DLP) mechanisms and file transfer monitoring systems to detect and block unauthorized data outflows. Special attention should be paid to the use of private mobile devices and cloud services, which can be a potential channel for information leakage.

How do you effectively monitor compliance with safety rules?

Effective monitoring of security compliance requires a multi-layered control system. The primary tool is SIEM (Security Information and Event Management) systems, which collect and analyze logs from a variety of sources to detect potential security violations. These systems should be configured for specific behavior patterns specific to leased employees.

Regular compliance audits are another key component of the monitoring system. Audits should cover both technical and organizational aspects, verifying, among other things, the timeliness of authorizations, adherence to security procedures or the correctness of documentation. It is particularly important to put in place automatic compliance verification mechanisms that allow for quick detection of deviations from accepted standards.

Building security awareness among leased employees through regular training and testing is also an important aspect. The training program should be dynamically adapted to changing risks and take into account feedback from the monitoring system. It is also worth introducing an incentive system to promote compliance with safety rules, for example, by including this aspect in periodic employee evaluations.

How to respond to security incidents in a body leasing model?

Effective response to security incidents in a body leasing environment requires precisely defined procedures and a clear division of responsibilities. The incident response plan should take into account the specifics of working with external specialists and define the roles of each entity in the incident handling process. Speed of response and effective communication between all parties involved is crucial.

When a security incident is detected, the first step is to properly classify it and assess the impact on the organization. The incident response team should have clear guidelines for escalating incidents and involving relevant stakeholders, including representatives of the body leasing company. It is also important to secure digital evidence that may be needed in the event of an investigation or legal action.

The incident handling process should also include a post-mortem analysis phase, during which the root causes of the incident are identified and recommendations for changes to security processes are developed. Particular attention should be paid to aspects specific to the body leasing model, such as potential gaps in the onboarding process or insufficient control over access to systems.

Security breaches in the context of body leasing can lead to serious legal and financial consequences for all parties involved. Under the RODO, a data controller can face a financial penalty of up to 4% of a

ual global turnover or €20 million, whichever is higher. In addition, the organization may be required to compensate individuals whose data has been breached.

In addition to direct financial penalties, security breaches can lead to significant image damage and loss of customer confidence. For companies providing body leasing services, security incidents can result in loss of contracts and difficulty in attracting new customers. Indirect costs can also include expenses related to legal services, crisis communications or the need for additional security audits.

How to safely offboard a leased employee?

The process of offboarding a leased employee is a critical moment from an information security perspective. It requires special care, as if conducted incorrectly it can lead to serious data security breaches. A systematic approach is crucial to ensure that the organization’s interests are comprehensively safeguarded while maintaining professional business relationships.

The first step in the offboarding process is to immediately extinguish all employee access privileges. This includes not only the deactivation of accounts in IT systems, but also the revocation of physical accesses, such as access cards or room keys. This process should be automated and integrated with identity management systems, minimizing the risk of any of the privileges being overlooked.

It is particularly important to secure business data located on employee devices. If private equipment is used (BYOD), there should be a controlled migration of business data and its secure removal from personal devices. This process should be properly documented, and the employee should confirm in writing the return or removal of all confidential information.

Last, but not least, offboarding involves conducting an exit interview with an emphasis on security aspects. During such an interview, the employee should be reminded of his or her confidentiality obligations, which often extend beyond the period of cooperation. It is also useful to gather feedback on potential areas for improvement in security procedures.

What are the best practices for data security in a long-term partnership?

Long-term cooperation in the body leasing model requires the implementation of a comprehensive information security management system that will evolve as the business relationship develops. The foundation of such a system is the regular updating of risk assessments, taking into account changing technological and business conditions. This allows proactive adaptation of controls to emerging risks.

A key component of a long-term safety strategy is building a safety culture among leased employees. A program of continuous security awareness development should include regular training, hands-on workshops and knowledge-sharing sessions. It is particularly important to involve leased employees in the process of identifying potential threats and developing security solutions.

In the context of a long-term relationship, it is also worth investing in advanced security monitoring and analysis tools. Systems such as UEBA (User and Entity Behavior Analytics) allow detection of anomalies in user behavior and early warning of potential threats. Integrating such solutions with existing security systems creates a multi-layered protection, effectively safeguarding against a variety of threats.

Regular review and updating of security documentation is also an important aspect. This applies to both operating procedures and agreements defining the rules of cooperation. In the case of long-term projects, it is particularly important to keep records of data security responsibilities and control and audit mechanisms up to date.

The success of long-term cooperation in the body leasing model depends largely on the ability to build lasting relationships based on trust and mutual understanding of security needs. Regular review meetings, joint improvement workshops, and open communication about incidents and threats allow for continuous improvement of the security system and build value for all parties involved.