Implementing ISO 27001 Annex A 6.3 is a strategic directive requiring role-based security awareness training and regular phishing simulations to mitigate human risk factors. This control ensures personnel are competent in their specific security responsibilities, delivering the business benefit of a resilient, security-first organizational culture that actively detects and reports threats.
ISO 27001 Annex A Information Security Awareness, Education and Training Implementation Checklist
Use this implementation checklist to achieve compliance with ISO 27001 Annex A 6.3. This control requires a shift from passive “tick-box” learning to active, role-specific education that demonstrably changes staff behaviour and reduces human error risks.
1. Define Role-Based Training Tracks
Control Requirement: Ensure training is relevant to the employee’s specific job function. Required Implementation Step: Ditch the “one-size-fits-all” video module. Create distinct training tracks: Developers must receive OWASP/Secure Coding training; Finance needs Invoice Fraud awareness; HR requires deep dives into Privacy/GDPR. Map these tracks in your Learning Management System (LMS) based on Active Directory department attributes.
Minimum Requirement: Documented training matrices showing at least 3 distinct content tracks for different departments.
2. Enforce ‘No Training, No Access’ Onboarding
Control Requirement: Ensure personnel understand their responsibilities before accessing sensitive information. Required Implementation Step: Configure your Identity Provider (Okta/Azure AD) to block access to production systems until the initial security induction is marked as “Complete” in the HR system. The induction must cover the Acceptable Use Policy, Password Standards, and Incident Reporting.
Minimum Requirement: Automated workflow logs proving training completion precedes account provisioning.
3. Execute Monthly Phishing Simulations
Control Requirement: Test the practical application of security awareness. Required Implementation Step: Do not rely on annual multiple-choice quizzes. Run monthly, unannounced phishing simulations using tools like KnowBe4 or Gophish. Vary the templates (e.g., “HR Document”, “Password Reset”, “Urgent CEO Request”) to test resilience against different attack vectors.
Minimum Requirement: Monthly reports showing the ‘Click Rate’ and ‘Reporting Rate’ for phishing tests.
4. Establish Remedial Training Protocols
Control Requirement: Address gaps in knowledge identified during testing. Required Implementation Step: Define an automated trigger for staff who fail phishing tests or violate policy. If a user clicks a phishing link, they should be immediately enrolled in a mandatory “Phishing Refresher” course. Repeat offenders should face formal performance management discussions.
Minimum Requirement: Evidence of targeted re-training assigned to staff who failed practical assessments.
5. Conduct Physical Security Walk-Throughs
Control Requirement: Reinforce awareness of physical protection measures. Required Implementation Step: Security officers must conduct random “Clear Desk” patrols. Leave physical cards on unlocked desks or unattended laptops stating, “This device was compromised.” This visceral feedback is far more effective than reading a PDF about locking screens.
Minimum Requirement: Logs of physical security spot-checks and the disciplinary actions taken for lapses.
6. Deliver ‘Just-in-Time’ Micro-Training
Control Requirement: Provide updates on new and emerging threats. Required Implementation Step: Use instant messaging channels (Slack/Teams) to push “Flash Alerts” regarding immediate threats (e.g., “New Zero-Day in Chrome – Update Now”). Do not wait for the annual cycle to communicate critical vulnerabilities.
Minimum Requirement: A communication log of ad-hoc security advisories sent to staff during the audit period.
7. Educate on Shadow IT Risks
Control Requirement: Minimise the risk of unauthorised software use. Required Implementation Step: Specifically train staff on why they cannot use unauthorised SaaS tools (e.g., converting PDFs online, using personal AI accounts). Explain the data sovereignty and intellectual property risks, providing a clear “SaaS Approval Process” as the alternative.
Minimum Requirement: Dedicated training material explicitly banning unapproved SaaS and AI tools.
8. Verify Contractor Awareness
Control Requirement: Ensure third-party users adhere to the same standards. Required Implementation Step: Mandate that all contractors with system access complete the same security awareness training as permanent staff. Include this requirement in the Statement of Work (SoW) and revoke access for any contractor who fails to complete the modules within 48 hours of starting.
Minimum Requirement: Training completion records for 100% of active contractors.
9. Train on Incident Reporting Procedures
Control Requirement: Ensure staff know how to report security events. Required Implementation Step: Every employee must know exactly where the “Panic Button” is. Whether it’s an email alias (security@company.com) or a Jira Service Desk button, test their knowledge by asking random staff: “If you lost your laptop right now, what is the very first thing you would do?”
Minimum Requirement: Intranet analytics or survey data showing 95%+ staff awareness of the reporting channel.
10. Measure Cultural Effectiveness
Control Requirement: Review the effectiveness of the awareness programme. Required Implementation Step: Move beyond “Completion %”. Track “Mean Time to Report” (MTTR) for phishing simulations. If staff are reporting suspicious emails within minutes, your training is working. If they delete and ignore, your culture is passive and needs overhaul.
Minimum Requirement: Management review reports analysing behavioural metrics, not just attendance records.
ISO 27001 Annex A 6.3 SaaS / GRC Platform Implementation Failure Checklist
| Control Requirement | The ‘Checkbox Compliance’ Trap | The Reality Check |
|---|---|---|
| Role-Based Training | Assigning the same generic “Cyber Security 101” video to the CEO and the Lead Developer. | A developer needs to know about SQL Injection; a CEO needs to know about Whaling. Generic training wastes time and fixes nothing. |
| Phishing Sims | Sending one obvious test email per year to tick a box. | Real attackers don’t send one email a year. If you aren’t simulating attacks monthly, you are training your staff to be complacent. |
| Completion Metrics | Celebrating “100% Completion” of a video course. | Staff likely played the video in the background on mute. Completion proves attendance, not competence. |
| Remedial Action | Ignoring users who fail tests because “they are too busy”. | If a senior manager clicks a phishing link and gets no training, they become your biggest vulnerability. Rank should not grant immunity. |
| Onboarding | Letting new hires do training in their “first month”. | The risk starts at the first login. If they can access data before they know the rules, you have failed the control. |
| Contractors | Assuming the agency trained them. | The agency doesn’t know your policies. If they are on your network, they must take your training. |
| Content Relevance | Using 5-year-old stock content provided by the GRC vendor. | Threats change weekly. If your training doesn’t mention Deepfakes or AI data leakage, it is obsolete. |
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