In this guide, I will show you exactly how to implement ISO 27001 Annex A 6.4 and ensure you pass your audit. You will get a complete walkthrough of the control, practical implementation examples, and access to the ISO 27001 templates and toolkit that make compliance easy.
I am Stuart Barker, an ISO 27001 Lead Auditor with over 30 years of experience conducting hundreds of audits. I will cut through the jargon to show you exactly what changed in the 2022 update and provide you with plain-English advice to get you certified.
Key Takeaways: ISO 27001 Annex A 6.4 Disciplinary Process
ISO 27001 Annex A 6.4 requires organizations to establish a formal, communicated disciplinary process to take action against personnel who violate information security policies. This control is not just about punishment; it is a “preventive” and “corrective” measure designed to deter negligence and ensure that security rules have real-world consequences. A successful implementation bridges the gap between the IT Security team and Human Resources (HR).
Core requirements for compliance include:
- Formalization: The process must be documented. It cannot be an informal or “case-by-case” decision.
- Communication: Employees must be aware of the process before a breach occurs. This is typically done through the employment contract and security awareness training.
- Proportionality: Actions should be reasoned and fair, considering the severity of the breach, the intent (intentional vs. unintentional), and whether it is a first-time or repeat offense.
- Verification: No disciplinary action should be taken until a formal investigation verifies that a policy violation actually occurred.
- Legal Compliance: The process must adhere to local employment laws and regulations to avoid legal liability for the organization.
Audit Focus: Auditors will look for “The HR Connection”:
- Policy Presence: “Does your staff handbook explicitly mention that violating information security policies can lead to disciplinary action?”
- Evidence of Action: “Show me a record of a recent security event where the disciplinary process was followed. If you have had zero violations, show me the process you would follow.”
- Training Proof: “Can you prove that the employee involved in a breach was actually trained on the policy they violated?”
Security Sanction Matrix (Audit Cheat Sheet):
| Breach Severity | Technical Security Example | Standard Compliance Consequence | ISO 27001:2022 Mapping |
|---|---|---|---|
| Minor | Leaving a workstation unlocked; unauthorised sharing of entry badges. | Verbal Warning + Mandatory Security Retraining. | 6.4 (Disciplinary Process) |
| Moderate | Loss of an unencrypted endpoint; recurrent failure of phishing simulations. | Written Warning + Performance Improvement Plan (PIP). | 6.4 (Disciplinary Process) |
| Severe | Unauthorised password sharing; intentional deactivation of antivirus/EDR. | Final Written Warning + Revocation of Administrative Privileges. | 5.18 (Access Rights) |
| Gross | Data exfiltration; malicious system damage; credential harvesting/sale. | Immediate Termination + Potential Criminal/Legal Action. | 6.4 (Disciplinary Process) |
Table of contents
- What is ISO 27001 Annex A 6.4?
- Watch the ISO 27001 Annex A 6.4 Tutorial
- ISO 27001 Annex A 6.4 Explainer Video
- ISO 27001 Annex A 6.4 Podcast
- ISO 27001 Annex A 6.4 Implementation Guidance
- How to implement ISO 27001 Annex A 6.4
- Security Sanction Matrix
- ISO 27001 Templates
- How to comply
- How to pass the audit of ISO 27001 Annex A 6.4
- What the auditor will check
- Top 3 ISO 27001 Annex A 6.4 mistakes and how to avoid them
- Applicability of ISO 27001 Annex A 6.4 across different business models.
- Fast Track ISO 27001 Annex A 6.4 Compliance with the ISO 27001 Toolkit
- ISO 27001 Annex A 6.4 FAQ
- Related ISO 27001 Controls
- Further Reading
- Matrix of ISO 27001 Controls and Attribute values
What is ISO 27001 Annex A 6.4?
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.
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.
ISO 27001 Annex A 6.4 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.
ISO 27001 Annex A 6.4 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
Watch the ISO 27001 Annex A 6.4 Tutorial
Watch the ISO 27001 disciplinary process tutorial.
ISO 27001 Annex A 6.4 Explainer Video
In this beginner’s guide to ISO 27001 Annex A 6.4 Disciplinary Process, ISO 27001 Lead Auditor Stuart Barker and his team talk you through what it is, how to implement in and how to pass the audit. Free ISO 27001 training.
ISO 27001 Annex A 6.4 Podcast
In this episode: Lead Auditor Stuart Barker and team do a deep dive into the ISO 27001 Annex A 6.4 Disciplinary Process. The podcast explores what it is, why it is important and the path to compliance.
ISO 27001 Annex A 6.4 Implementation Guidance
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 behaviours 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:
- Investigation of the incident
- Review of the employee’s file
- Meeting with the employee to discuss the incident
- Issuance of a written warning or other disciplinary action
- 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
How to implement ISO 27001 Annex A 6.4
Implementing ISO 27001 Annex A 6.5 (formerly A.7.2.3) requires a structured approach to ensure that security policies are enforceable and that personnel are held accountable for breaches. By following this technical workflow, organisations can establish a transparent framework that acts as a deterrent against negligence and intentional misconduct while providing verifiable audit evidence for certification.
1. Formalise the Security Disciplinary Policy
Develop a documented disciplinary framework that explicitly defines the consequences of violating information security policies and procedures.
- Categorise security breaches into specific severity levels: minor, major, and gross misconduct.
- Establish a graduated scale of sanctions, ranging from informal warnings to immediate termination of employment or contract.
- Ensure the policy is reviewed by legal and HR departments to guarantee compliance with UK employment law and statutory regulations.
- Integrate these clauses into standard employment contracts and third-party service level agreements.
2. Socialise the Process through Mandatory Inductions
Communicate the disciplinary process to all personnel to ensure that the consequences of security failures are understood and acknowledged.
- Include a dedicated module on the “Consequences of Breach” within the initial security induction for all new starters.
- Utilise digital signature platforms to obtain formal policy acknowledgements from all employees and contractors.
- Regularise awareness through periodic training sessions that highlight real-world examples of policy violations.
- Maintain a centralised record of training attendance as primary evidence for ISO 27001 auditors.
3. Align Security Incident Reporting with HR Workflows
Create a technical link between the Information Security Management System (ISMS) and Human Resources to ensure seamless escalation of breaches.
- Configure the Incident Management System (IMS) to trigger a notification to HR when a security event involves human negligence or intent.
- Define specific IAM roles for HR personnel to allow them limited access to security investigation logs while maintaining data privacy.
- Establish a formal hand over process between the IT security team and the disciplinary hearing panel.
- Ensure that any disciplinary action taken is recorded against the individual’s personnel file in the HR Management System.
4. Institutionalise Fair and Evidence Based Investigations
Establish a rigorous investigation process that relies on objective data and maintains the integrity of evidence for potential legal proceedings.
- Utilise forensic logs and system audit trails to substantiate claims of policy violations.
- Document a clear “Chain of Custody” for any digital evidence extracted from company laptops or mobile devices.
- Ensure the disciplinary panel remains impartial by including members from departments not involved in the original incident.
- Apply sanctions consistently across all levels of the organisation, regardless of the individual’s seniority or role.
5. Audit the Process for Continual Improvement
Perform regular reviews of the disciplinary process to ensure it remains effective and aligned with the evolving risk landscape of the organisation.
- Analyse trends in disciplinary actions to identify systemic security weaknesses or areas where awareness training is failing.
- Conduct an annual review of the policy to incorporate updates from new regulations such as GDPR or the Data Protection Act 2018.
- Validate that the “Deterrent Effect” is working by monitoring for a reduction in recurring minor security breaches.
- Update the ISMS Risk Register based on findings from the disciplinary review cycle.
Security Sanction Matrix
| Severity | Breach Example | Consequence |
| Minor | Leaving PC unlocked; Sharing badge. | Verbal Warning + Retraining. |
| Moderate | Losing unencrypted laptop; Phishing click (repeated). | Written Warning + PIP. |
| Severe | Sharing passwords; Disabling antivirus. | Final Warning + Access Removal. |
| Gross | Stealing data; Malicious damage. | Immediate Termination + Legal Action. |
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 of ISO 27001 Annex A 6.4
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.
Top 3 ISO 27001 Annex A 6.4 mistakes and how to avoid them
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.
Applicability of ISO 27001 Annex A 6.4 across different business models.
| Business Type | Applicability | Examples of Control Implementation |
|---|---|---|
| Small Businesses | Focuses on integrating basic security rules into the existing staff handbook. The goal is to ensure that even in a small team, employees understand that security negligence (like leaving a laptop in a car) has formal consequences. |
|
| Tech Startups | Critical for managing remote and high-trust environments. Compliance involves clear communication that high-impact mistakes, such as intentionally bypassing security controls on a production server, will lead to serious action. |
|
| AI Companies | Vital for protecting unique model IP and massive training datasets. Focus is on preventing internal data theft or malicious model tampering through the deterrent of gross misconduct penalties. |
|
Fast Track ISO 27001 Annex A 6.4 Compliance with the ISO 27001 Toolkit
For ISO 27001 Annex A 6.4 (Disciplinary process), the requirement is to formalize and communicate a process to take action against personnel who violate information security policies. This is a human resources governance control designed to ensure accountability and deter misconduct.
| Compliance Factor | SaaS Compliance Platforms | High Table ISO 27001 Toolkit | Audit Evidence Example |
|---|---|---|---|
| Policy Ownership | Rents access to your HR standards; if you cancel the subscription, your documented security sanctions and history vanish. | Permanent Assets: Fully editable Word/Excel HR Policies and Sanction Matrices that you own forever. | A localized “Security Sanction Matrix” defining consequences for specific policy violations like password sharing. |
| HR Governance | Attempts to “automate” enforcement via dashboards that cannot conduct fair investigations or issue legal warnings. | Governance-First: Formalizes your existing HR workflows and labor law requirements into an auditor-ready framework. | An employee handbook update proving that security violations are integrated into the formal disciplinary process. |
| Cost Efficiency | Charges a “Per-Employee Tax” that scales aggressively as your headcount and organizational complexity grow. | One-Off Fee: A single payment covers your disciplinary governance for 5 employees or 5,000. | Allocating budget to security awareness training rather than monthly software fees for a “compliance dashboard.” |
| Strategic Freedom | Mandates rigid workflows that may conflict with local labor laws, union agreements, or unique company cultures. | 100% Agnostic: Procedures adapt to any jurisdiction or culture—ensuring legal compliance without technical limits. | The ability to evolve your HR strategy and disciplinary steps without reconfiguring a rigid SaaS compliance module. |
Summary: For Annex A 6.4, the auditor wants to see that you have a formal disciplinary process that includes security violations and proof that employees are aware of it. The High Table ISO 27001 Toolkit provides the governance framework to satisfy this requirement immediately. It is the most direct, cost-effective way to achieve compliance using permanent documentation that you own and control.
ISO 27001 Annex A 6.4 FAQ
What is ISO 27001 Annex A 6.4?
ISO 27001 Annex A 6.4 (formerly A.7.2.3) is an information security control that requires organisations to establish and communicate a formal disciplinary process for personnel who commit security breaches.
- It ensures that security policies are enforceable rather than just guidelines.
- It acts as a deterrent against intentional and negligent security violations.
- It requires the process to be documented, fair, and applied consistently across the workforce.
- It bridges the gap between Information Security (ISMS) and Human Resources (HR).
Is a formal disciplinary policy mandatory for ISO 27001?
Yes, a formal disciplinary process is a mandatory requirement under Annex A 6.4 of the ISO 27001:2022 standard to ensure accountability for security policy violations.
- The process must be officially documented within your ISMS or HR handbook.
- Employees must be made aware of the consequences of security breaches during onboarding.
- Auditors will look for evidence that the policy has been communicated to all staff.
- Lack of a formal process is often cited as a minor non-conformity during certification audits.
What should be included in a security disciplinary policy?
A robust security disciplinary policy must define the types of breaches, the severity of violations, and the specific graduated actions that will be taken.
- Clear definitions of what constitutes a “minor” versus “gross” security breach.
- A graduated scale of consequences (e.g., verbal warning, formal warning, suspension, dismissal).
- The legal and regulatory implications of specific breaches (e.g., GDPR violations).
- Instructions on how to appeal a disciplinary decision related to security.
Does the disciplinary process apply to contractors and third parties?
Yes, while contractors may not be subject to internal HR procedures, ISO 27001 requires that equivalent disciplinary measures are enforced via service level agreements (SLAs) or contracts.
- Contractual clauses should allow for immediate termination of access in the event of a breach.
- Third-party agreements should specify the right to seek damages for security failures.
- Sanctions should be clear in the Non-Disclosure Agreement (NDA) or main service contract.
How do you ensure a disciplinary process is fair and consistent?
Fairness is achieved by applying the same rules and consequences to all personnel, regardless of their role, seniority, or tenure within the organisation.
- Ensure HR leads the disciplinary investigation to maintain objectivity.
- Document all evidence of the breach before initiating the disciplinary workflow.
- Provide regular security awareness training so staff cannot claim ignorance of the rules.
- Review the process annually to ensure it aligns with current employment law.
What evidence do auditors look for regarding Annex A 6.4?
Auditors seek verifiable proof that the disciplinary process is documented, communicated to staff, and has been utilised if breaches have occurred.
- Signed employee handbooks or policy acknowledgement records.
- Training logs showing that the “Consequences of Breach” were covered in inductions.
- Redacted records of past disciplinary actions (if any exist) to prove the process is active.
- The Information Security Policy (ISP) containing the specific disciplinary clauses.
Related ISO 27001 Controls
ISO 27001 Clause 7.5.1 Documented Information
ISO 27001 Clause 7.4 Communication
ISO 27001 Annex A 5.1 Policies for Information Security
ISO 27001 Annex A 6.2 Terms and Conditions of Employment
Further Reading
The complete guide to ISO/IEC 27002:2022
Matrix of ISO 27001 Controls and Attribute values
| Control type | Information security properties | Cybersecurity concepts | Operational capabilities | Security domains |
| Preventive Corrective | Availability Confidentiality Integrity | Protect Respond | Human resource security | Governance and ecosystem |
