In this guide you will learn how to implement ISO 27001 Annex A 6.4 and pass your audit from ISO 27001 Lead Auditor Stuart Barker – author of the ultimate ISO 27001 Toolkit.
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.
Table of contents
- Purpose & Definition
- FREE ISO 27001 Annex A 6.4 Training Video
- Implementation Guide
- General Guidance
- When to take disciplinary action
- Disciplinary action considerations
- Reward positive behaviour
- The different types of disciplinary actions
- Disciplinary Process Responsibility
- Disciplinary Process Steps
- Employee Rights
- Employer Responsibilities
- Consequences of Getting it Wrong
- Process Challenges
- How to implement ISO 27001 Annex A 6.4
- ISO 27001 Templates
- How to comply
- How to pass the audit
- What the auditor will check
- Top 3 mistakes and how to avoid them
- ISO 27001 Annex A 6.4 FAQ
- Related ISO 27001 Controls
- Matrix of ISO 27001 Controls and Attribute values
Purpose & Definition
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 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
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FREE ISO 27001 Annex A 6.4 Training Video
In this free training video you will learn How to implement ISO 27001 Annex A 6.4 Disciplinary Process and Pass Your Audit.
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.
Disciplinary action considerations
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.
The different types of disciplinary actions
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.
Disciplinary Process Responsibility
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.
Disciplinary Process Steps
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
Employee Rights
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
Employer Responsibilities
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
Consequences of Getting it Wrong
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
Process Challenges
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 6.4 requires a structured approach to ensure that security policies are enforceable and that personnel are held accountable for breaches.
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.
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.
Top 3 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.
ISO 27001 Annex A 6.4 FAQ
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.
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.
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.
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.
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
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 |
Stuart Barker
I am the ISO 27001 Ninja.
I help tech companies, start-ups, and small businesses implement information security management systems without the corporate bloat or massive consultant fees.
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