Exclusions of the ISMS scope
If a unit in the organization (let us say HR) is excluded from the scope, there is a dependency between HR and other units (for example, HR is responsible for recruitment and training). Although HR is excluded from the scope, it still provides training for employees of other departments that are included in the scope. In this case, HR should be considered an external third-party provider to the other organizational units that are included in the scope, which means that HR should be controlled as a supplier.
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You are basically right - if the HR department is outside of the ISMS scope, from the ISMS point of view it will have the same status as a third-party provider; of course, legally speaking, your HR department is not a third-party provider, but a organizational unit of your company.
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Oct 21, 2023