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Insider risks: Why critical positions require special protection

In the industry and energy sector, safety and continuity are often approached through systems, installations and processes. Technical safeguards receive significant attention. Increasingly, however, organisations recognise that risk is not limited to technology or external threats. Individuals with legitimate access to critical infrastructure, data and operational environments are a central focus of Security, Compliance and Data Protection Officers.

Insider risk is frequently associated with deliberate misconduct. In reality, organisations in critical infrastructure environments are primarily concerned with managing exposure responsibly and transparently. In business areas where permanent staff, contractors and supply-chain partners work alongside one another, certain functions are inherently more vulnerable than commonly assumed. 

For organisations subject to the Industry and Energy sector, the key question is no longer whether insider risk exists, but whether roles with elevated access are clearly identified, proportionately protected and demonstrably controlled. This includes being able to demonstrate to auditors and regulators how insider risks are minimised and how access decisions are justified.

employees finishing up screening
employees finishing up screening

Why insider risk is moving up the German Industry and Energy agenda


Rising regulatory requirements and audit expectations extend across all industrial and critical infrastructure sectors in Germany. In addition, evidence is expected regarding who has access to sensitive environments, on what basis such access is granted, and how reliability is ensured over the long term.

Industry and Energy facilities environments are complex by design. Physical locations, operational technology and IT systems are closely interconnected. Individuals with authorised access to these facilities environments can, intentionally or unintentionally, affect safety, operational continuity and public interest.

Security, Compliance and Data Protection Officers are therefore continuously assessing how to minimise the insider risks on the company assets, infrastructure and sensitive information.

 

 

What we mean by insider risk and what is often overlooked

Insider risk is commonly linked to sabotage or fraud, but this perspective is incomplete. Insider risk is understood more broadly as the risk that individuals with legitimate access could intentionally or unintentionally cause harm, disruption or data breaches.

Insider risk refers to vulnerabilities that arise because individuals have legitimate access to systems, locations or processes. That access creates exposure, even in the absence of malicious intent.

Human error, negligence, external pressure or conflicts of interest can all contribute. Precisely because these factors are less visible, they are often identified only after an incident has occurred.

Organisations therefore seek objective and fact-based ways to verify reliability before granting access, without creating unnecessary burden for candidates. They can easily do this by using an automated pre-employment screening software.

 

Access, not intent, defines the risk profile

Trust in people remains essential, but it cannot function as the sole control measure. Particularly in Germany, organisations emphasise that pre-employment screening is not about mistrust of individuals but about minimising risk and protecting critical operations and employees.

The level and nature of access determine the risk associated with a role. The broader the access and the greater the influence, the higher the potential impact of misuse, error or external influence.

 

 

Critical roles: why job titles provide a false sense of security

Critical roles are often associated with senior or highly specialised positions. In practice, job titles are a poor indicator of actual exposure.

Within Industry and Energy, risk is defined by access to production systems, energy networks, operational technology environments, physical installations or escalation authorities within operations.

Temporary staff, contractors and suppliers increasingly hold such access, without always being recognised as occupying critical roles.

 

Why temporary and external roles require particular attention

Labour shortages and project-based delivery models have increased reliance on external employees. Access is frequently granted quickly to prevent operational delays. HR and contractor managers therefore need screening processes that support fast and seamless onboarding while remaining legally compliant.

Reassessment, monitoring and structured documentation do not always keep pace. This creates blind spots: individuals with sustained or extensive access whose risk profile is not periodically reviewed.

Organisations want to avoid using too many (and unnecessary) platforms or fragmented processes and instead require automated, integrated and seamless pre-employment screening workflows.

Michelle Piergoelam VALIDATASEPT24 110

 

 

Influence: the least visible driver of insider risk

In addition to access, influence is a significant but often underestimated factor in insider risk.

Influence may arise from financial pressure, dependency on external interests, prolonged engagement with a single organisation or conflicting loyalties within complex supply chains. Such dynamics are difficult to detect, particularly in fragmented operating models.

Traditional screening approaches are rarely designed to address these forms of risk. Pre-employment screening nowadays helps organisations to verify relevant facts objectively and document decisions to support compliance and audit requirements. 

It’s not about mistrust, it’s about minimising insider risks.
 

 

Regulatory expectations are increasing without prescribing detailed solutions

Legislation and regulatory frameworks do not always explicitly define how insider risk should be managed. However, there is a clear and growing expectation that organisations can demonstrate control over who has access to critical functions and infrastructure.

German laws such as the KRITIS Umbrella Act, the BSI Act together with the IT Security Act, and the Energy Industry Act place full responsibility for protecting critical infrastructures and essential services on the organisations themselves. 

The focus is shifting from isolated technical measures to organisation-wide risk management, requiring operators to implement robust resilience measures and demonstrate continuous, risk-based governance.

Auditors and contracting authorities increasingly focus on the rationale behind access decisions. Why was access granted? On what basis? And how is this assessment reviewed over time?

Insider risk therefore extends beyond security and becomes a matter of governance and accountability.

Compliance failures in this area can lead to incidents, fines, audit findings and reputational damage.

 

 

The question organisations are increasingly expected to answer

Which roles within your organisation have access to critical infrastructure, and what level of protection is proportionate to that access?

Could you explain and substantiate this today, including for contractors and other external parties?

Can you demonstrate with documented evidence that reliability has been verified in a GDPR-compliant way before access was granted?

 

 

Looking ahead

In the following pieces of content, we will explore how organisations can address insider risk in a structured and sustainable manner. Not through isolated controls, but through a coherent approach that connects roles, access and reliability, without disrupting operational continuity.