ISO 27001:2022 Annex A 6.1 – Screening Explained

People are often the first control an organisation relies on — and the first risk if trust is assumed rather than verified.

Annex A 6.1 exists to ensure organisations screen individuals and selected suppliers appropriately before granting access to information and systems, so that access is based on suitability, trustworthiness, and risk, not urgency or convenience.

This control is preventative. It reduces insider risk before it materialises.

ISO 27001

Quick Guide: Annex A 6.1 at a Glance

Annex A 6.1 of ISO 27001:2022 focuses on screening of personnel and relevant third parties.

At a practical level, this means:

  • Performing background checks before access is granted
  • Applying screening proportionate to role and risk
  • Verifying identity, qualifications, and employment history where appropriate
  • Respecting legal, regulatory, and ethical requirements
  • Managing situations where screening is incomplete

The control does not mandate specific checks or vetting methods. It expects organisations to apply risk-based, lawful, and transparent screening aligned to the information individuals will access.

In-Depth Guide to Annex A 6.1

What Is Annex A 6.1 and Why Does It Matter?

Many information security incidents involve:

  • Misuse of legitimate access
  • Insider threat, whether malicious or negligent
  • Over-trusting individuals in sensitive roles

Annex A 6.1 addresses this risk by ensuring organisations:

  • Assess suitability before access is granted
  • Avoid placing individuals in roles they are not appropriate for
  • Reduce exposure created by urgency-driven hiring

Screening supports trust — it does not replace it.

This control applies to:

  • Employees (permanent, temporary, or casual)
  • Contractors and agency staff
  • Selected suppliers where their role affects information security

How to Implement Annex A 6.1 Effectively

A pragmatic approach to Annex A 6.1 typically includes the following elements.

1. Define a Screening Approach

Organisations should define what screening looks like in their context, including:

  • Which roles are subject to screening
  • What checks are appropriate for different risk levels
  • When screening is performed

Screening should occur before access to information or systems is granted wherever possible.

2. Apply Screening Proportionate to Risk

Not all roles carry the same level of risk.

Screening may consider:

  • Sensitivity of information accessed
  • Level of system or privileged access
  • Financial or decision-making authority
  • Regulatory or contractual obligations

Higher-risk roles typically justify enhanced screening.

3. Verify Identity and Background Where Appropriate

Common screening activities may include:

  • Verification of identity
  • Confirmation of employment history
  • Validation of qualifications or professional standing
  • Reference checks

The specific checks used should be justified by role and risk, not applied uniformly without reason.

4. Address Legal, Regulatory, and Ethical Requirements

Screening frequently involves processing personally identifiable information.

Organisations should ensure:

  • Screening complies with applicable employment and privacy law
  • Individuals are informed about screening activities
  • Data is handled securely and lawfully

Compliance with local law is fundamental to this control.

5. Include Suppliers Where Relevant

Where suppliers or contractors will access information or systems, organisations should consider:

  • Whether screening is appropriate
  • How screening requirements are communicated
  • How responsibilities are addressed contractually

Supplier screening should be aligned with supplier risk, not treated as a default requirement.

6. Manage Incomplete or Delayed Screening

Sometimes screening cannot be completed before onboarding.

Annex A 6.1 expects organisations to manage this risk deliberately, which may include:

  • Delaying access until screening is complete
  • Restricting system or information access
  • Applying increased supervision
  • Reconsidering engagement if screening cannot be completed

Access should not be granted by default simply because screening is incomplete.

7. Consider Ongoing Suitability Where Risk Justifies It

For some critical roles, organisations may consider:

  • Periodic review of suitability
  • Re-screening after role change or promotion

This is particularly relevant where responsibilities increase significantly.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

Practical Considerations

Annex A 6.1 does not require:

  • Identical screening for all roles
  • Continuous vetting of all personnel
  • Screening that exceeds legal or ethical boundaries

It does require organisations to:

  • Think deliberately about trust and access
  • Apply screening consistently and lawfully
  • Avoid unmanaged exceptions

Poorly designed screening creates legal risk.
Poorly applied screening creates security risk.

Common Challenges and How to Overcome Them

  • Treating screening as a tick-box HR task
  • Align screening with information security risk
  • Applying the same checks to every role
  • Use a proportionate, role-based approach
  • Granting access before screening is complete
  • Apply temporary restrictions or supervision
  • Ignoring supplier access risk
  • Extend screening considerations to relevant third parties

Screening fails most often when urgency overrides judgement.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

Final Recommendations

Annex A 6.1 is about placing trust deliberately.

When screening is applied effectively:

  • Insider risk is reduced
  • Access decisions are more defensible
  • Legal and regulatory exposure is controlled
  • Confidence in personnel suitability increases

Screening is not about mistrust.
It is about ensuring the right people have the right access, for the right reasons.

That is exactly what Annex A 6.1 is designed to achieve.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

  • What the organisation values
  • How security decisions are approached
  • Where accountability sits
  • Aligns security with business objectives
  • Supports proportionate, risk-based decisions
  • Provides a reference point during incidents and disputes
  • Creates consistency without bureaucracy

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy
  • Scope: What the policy applies to (systems, data, people).
  • Objectives: Why security is important for the business.
  • Roles & Responsibilities: Who is accountable for security.
  • Key Principles: Risk management, access control, and data protection.
2. Secure Senior Management Approval
  • Review and approve policies.
  • Ensure resources are allocated for implementation.
  • Lead by example in enforcing security policies.
3. Communicate and Train Employees
  • Include security policies in onboarding and ongoing training.
  • Ensure policies are easily accessible to all employees.
  • Encourage acknowledgment and acceptance of security responsibilities.
4. Regular Review & Continuous Improvement
  • Set a schedule for periodic policy reviews (at least annually).
  • Update policies based on business changes, new threats, or regulatory updates.
  • Conduct audits to ensure compliance and effectiveness.
5. Integrate Policies into the ISMS
  • Use it to develop more detailed security procedures.
  • Ensure policies align with other Annex A controls and broader risk management practices.
Key Differences: ISO 27001:2013 vs ISO 27001:2022
AspectISO 27001:2013ISO 27001:2022
Control StructureTwo separate controls: 5.1.1 & 5.1.2Merged into one control (5.1)
Implementation GuidanceLess prescriptiveMore detailed guidance for policy creation and alignment
Awareness & TrainingNot explicitly mentionedExplicitly requires policies to be part of training programmes
Attributes TableNot includedew attributes table for mapping policies to industry terms
Common Challenges & How to Overcome Them
  • Challenge: Employees don’t follow security policies.
  • Solution: Make policies practical and relevant to daily work. Use real-world examples in training.
  • Challenge: Policies are outdated or too generic.
  • Solution: Schedule annual reviews and update policies based on real threats and business changes.
  • Challenge: Policies are written in technical jargon.
  • Solution: Use plain language that all employees can understand.
  • Challenge: Lack of leadership buy-in.
  • Solution: Show how weak security affects business objectives—costs of breaches, loss of client trust, and legal penalties.
Final Recommendations
  • Make security policies living documents—review, refine, and update regularly.
  • Use policy training and awareness to create a security-conscious workforce.
  • Ensure policies are accessible, relevant, and easy to understand.
  • Keep policies aligned with business strategy and regulatory requirements.
  • Engage leadership in driving security culture from the top down.

The Annex Control Table

ISO 27001:2022 Organisational Controls
ISO 27001:2022 Technological Controls