The Ultimate Guide to ISO 27001 Annex A 6.4: Disciplinary Process

ISO 27001 Disciplinary Process

ISO 27001 Annex A 6.4 Disciplinary Process is an ISO 27001 control that wants you to have a process to take action against people who violate your information security policy, topic specific policies and processes.

The ISO 27001 disciplinary process is a structured procedure that employers use to address employee misconduct or performance issues. It typically involves a series of steps to investigate, document, and resolve the issue.

Purpose

The purpose of the ISO 27001 disciplinary process is to ensure that people understand what will happen, and the consequences, of a violation of information security policy. The intent is to deter people from not following and adhering to policies and appropriately deal with those that do.

Definition

ISO 27001 defines the ISO 27001 Annex A 6.4 disciplinary process as:

A disciplinary process should be formalised and communicated to take actions against personnel and other relevant interested parties who have committed an information security policy violation.

ISO 27001:2022 Annex A 6.4 Disciplinary Process

Ownership

In close collaboration with HR Management and Legal Teams, the Information Security Officer is responsible for establishing and maintaining effective disciplinary controls and procedures.

Watch the Tutorial

Watch the ISO 27001 disciplinary process tutorial.

Implementation Guide

General Guidance

You are going to

• engage with a HR professional
• implement a HR disciplinary process
• include information security violations in the disciplinary process
• communicate the disciplinary process to relevant and interested parties
• act on the process as required and maintain evidence

When to take disciplinary action

You are going to confirm and verify that an information security policy violation has actually occurred before you take any action.

What should the disciplinary action consider?

Under the guidance of a HR professional you are going to consider a reasoned and proportionate response that take into account all legal and regulatory requirements and obligations. Consider:

• The nature of the event
• The intent – was it intentional or unintentional
• The frequency – was it a first time or a repeat offence
• Was the person aware of what was required and can you prove that
• Was the person trained and can you prove that

Reward positive behaviour

It isn’t just a negative approach. It can be a great way to enhance the culture and adherence to policy by rewarding, in what ever form is appropriate to you, positive behviours in relation to information security. From monetary rewards to formal recognition in meetings to ‘information security star of the month’ are all examples of what we have seen work well.

What are the different types of disciplinary actions that can be taken?

The types of disciplinary actions that can be taken vary depending on the severity of the offense. Some common disciplinary actions include

• verbal warnings,
• written warnings
• suspension,
• and termination.

Who is responsible for administering the disciplinary process?

The disciplinary process is usually administered by the organisation’s human resources department. However, in some cases, the disciplinary process may be administered by the employee’s manager or supervisor.

What are the steps involved in the disciplinary process?

The steps involved in the disciplinary process vary depending on the organisation. However, some common steps include:

1. Investigation of the incident
2. Review of the employee’s file
3. Meeting with the employee to discuss the incident
4. Issuance of a written warning or other disciplinary action
5. Follow-up to ensure that the employee has corrected the behaviour

What are the rights of the employee during the disciplinary process?

The employee has the right to:

• Be informed of the allegations against them
• Be present at any disciplinary meeting
• Respond to the allegations
• Be represented by a union representative or other advocate
• Appeal the disciplinary decision

What are the responsibilities of the employer during the disciplinary process?

The employer has the responsibility to:

• Investigate the incident thoroughly
• Review the employee’s file
• Meet with the employee to discuss the incident
• Issue a written warning or other disciplinary action that is fair and consistent with the organisation’s policies and procedures
• Follow up to ensure that the employee has corrected the behaviour

What are the consequences of not following the disciplinary process?

The consequences of not following the disciplinary process can vary depending on the organisation. However, some common consequences include:

• Increased employee turnover
• Decreased employee morale
• Decreased productivity
• Increased legal liability

What are the challenges of implementing a disciplinary process?

Some of the challenges of implementing a disciplinary process include:

• Dealing with employee emotions
• Avoiding bias
• Ensuring that the process is fair and consistent
• Documenting the process

ISO 27001 Templates

Having a topic specific policy for information security awareness training template and an ISO 27001 communication plan template can really help if you don’t want the entire ISO 27001 toolkit.

How to comply

To comply with ISO 27001 Annex A 6.4 Disciplinary Process you are going to implement the ‘how’ to the ‘what’ the control is expecting. In short measure you are going to:

• Write, sign off, implement and communicate your topic specific policies for HR
• Write, sign off, implement and communicate your disciplinary procedures
• Implement your training and awareness that includes the consequences of violating policies and procedures
• Implement your communication plan to communicate to relevant and interested parties
• Ensure that the disciplinary process meets all laws as well as local laws and regulations
• Implement a process of internal audit that checks that the appropriate controls are in place and effective and where they are not follow the continual improvement process to address the risks

How to pass the audit

To pass an audit of ISO 27001 Annex A 6.4 you are going to make sure that you have followed the steps above in how to comply.

What the auditor will check

The audit is going to check a number of areas for compliance with Annex A 6.4 Disciplinary Process. Lets go through them

1. That you have a documented disciplinary process

The auditor will meet with the HR team and look for a documented disciplinary process that includes violations of information security policies and procedures.

2. That you have communicated the disciplinary process

The process needs to be communicate to relevant and interested parties. The audit will check that the training and awareness plan and the communication plan and look for past evidence that this has happened.

3. That people are aware of their responsibilities

The audit is going to check for documented processes, documented topic specific policy and these have been communicated and people have been trained on what is required of them.

Common Mistakes

In my experience, the top 3 mistakes people make for ISO 27001 Annex A 6.4 Disciplinary Process are

1. You have no evidence that anything actually happened

You need to keep records and minutes of everything. You need a paper trail to show it was done. Make sure you have updated communication plans and training plans on the disciplinary process. If it isn’t written down it didn’t happen.

2. One or more members of your team haven’t done what they should have done

Prior to the audit check that all members of the team have done what they should have. Do they know where the process documents are in relation to the disciplinary process? Do a pre audit as close to the audit as you can that checks the disciplinary process and the HR team that will be involved. Assuming they are doing the right thing is a recipe for disaster. Check!

3. Your document and version control is wrong

Keeping your document version control up to date, making sure that version numbers match where used, having a review evidenced in the last 12 months, having documents that have no comments in are all good practices.

FAQ

Related ISO 27001 Controls

ISO 27001 Documented Information: Clause 7.5.1

ISO 27001 Communication: Clause 7.4

ISO 27001 Policies for Information Security: Annex A 5.1

ISO 27001 Terms and Conditions of Employment: Annex A 6.2

Further Reading

The complete guide to ISO/IEC 27002:2022

Matrix of ISO 27001 Controls and Attribute values