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How SOCI Is Reshaping Hiring and Workforce Risk in Australia

When Australia’s critical infrastructure risk management obligations came into force, many organisations treated SOCI (the Security of Critical Infrastructure Act) as a regulatory milestone. Something to implement, document, and move on from.

Seven years on, that assumption doesn’t quite hold up. SOCI hasn’t faded into the background. Instead, it’s more visible and impacts how organisations think about workforce risk. SOCI has quietly changed the hiring conversation.

For organisations operating in critical infrastructure, workforce risk is no longer limited to whether someone can do the job. It now includes whether that person should have access to systems, assets, data, and environments that are essential to national resilience.

From cyber risk to human risk

The SOCI framework takes an “all hazards” approach, bringing cyber, supply chain, physical, and personnel risks all in the same frame, as part of its Critical Infrastructure Risk Management Program.

What’s become clearer over time is this: some of the most significant vulnerabilities may not sit in technology alone, but in the people trusted to access it.

A critical worker is not always the most senior person in the organisation. It may be an IT administrator, control room operator, contractor, supplier, or employee with privileged access to sensitive systems, that changes how hiring needs to be viewed.

Hiring is no longer just hiring. It’s about risk management

Under SOCI, personnel risk is not just an onboarding issue. It is a lifecycle issue.

In practice, this shows up in ways many organisations will recognize:

  • A contractor is brought in quickly to meet demand, but given system access before full checks are completed.
  • A role evolves over time, but access levels aren’t reassessed.

Organisations need to know:

  1. Who their critical workers are
  2. Why are they classified as critical
  3. What access they hold
  4. How their suitability is assessed over time

This pushes hiring and HR teams into closer alignment with risk, compliance, cyber, legal, and operations.

Background checks such as identity verification, right-to-work checks, criminal history assessments, and role-based screening are more than HR processes. They are part of the organisation’s risk management strategy

Speak with First Advantage Australia to strengthen your hiring and workforce screening strategy in line with SOCI requirements.

From one-off checks to ongoing assurance

The conversation is also shifting from one-time checks to ongoing assurance.

As regulatory expectations mature, organisations are being asked to demonstrate not just that checks were completed, but that personnel risk is being actively managed across the lift cycle:

  • Reviewing access when roles change;
  • Revoking access when employees leave;
  • Monitoring whether critical workers remain suitable for the responsibilities they hold.

Not just “Was a check done?”

But “How do you know that person is still suitable today?”

An ongoing tension for HR leaders

The pressure to hire quickly hasn’t gone away. Instead, it increased, particularly across technical and critical roles. At the same time, the consequences of getting it wrong is higher.

That creates a pressure on CHROs for HR leaders to get it right:

Moving at speed vs getting the right level of assurance;

Enabling access vs maintaining control;

Delivering a good candidate experience vs doing the necessary checks.

What this means for HR leaders

Defining critical roles properly:
Organisations must define which roles are truly critical.

Matching screening to access:
Depth of checks need to reflect the level of access and risk attached to the role.

Cross-functional governance:
HR can no longer manage hiring risk in isolation and must share accountability with security, legal, and operations.

Maintaining ongoing trust:
Suitability should be reviewed across the employee lifecycle, not just at the offer stage.

Trust in a changing world

Every hire is ultimately a decision about trust. But in today’s environment, trust isn’t something you can take at face value. Trust must be verified, documented, and revisited.

You should be able to give a clear answer to these questions:

  • Who has access to your critical systems?
  • Why do they have that access?
  • Does that still make sense today?

Every workforce management decision can have consequences far beyond the workplace. In a changing world, workforce resilience begins with knowing your people and taking steps to preserve that trust.

If you are reviewing your approach, we’d be happy to share what’s working across industries. Connect with us today.

Key Takeaways

  • SOCI has shifted hiring from a recruitment activity to a workforce risk management function.
  • Personnel risk is now a critical component of infrastructure security, not just HR responsibility.
  • Background screening and identity verification play a key role in controlling access to sensitive systems.
  • Organisations are moving from one-time checks to ongoing workforce assurance.
  • Effective hiring now requires alignment between HR, risk, compliance, and security teams.

This content is offered for informational purposes only. First Advantage is not a law firm, and this content does not, and is not intended to, constitute legal advice.  Information in this may not constitute the most up-to-date legal or other information.

Readers of this content should contact their own legal advisors concerning for their particular circumstance.  No reader, or user of this content, should act or refrain from acting on the basis of information in this content.  Only your individual attorney or legal advisor can provide assurances that the information contained herein – and your interpretation of it – is applicable or appropriate to your particular situation.  Use of, and access to, this content does not create an attorney-client relationship between the reader, or user of this presentation and First Advantage.