ISO 27001:2022 Annex A 6.4 – Disciplinary Process Explained

Policies without consequences are suggestions, not controls.

Annex A 6.4 exists to ensure organisations apply a formal, fair, and consistent disciplinary process when information security policies, rules, or standards are breached.

This control reinforces that information security is taken seriously, while ensuring responses are lawful, proportionate, and defensible.

ISO 27001

Quick Guide: Annex A 6.4 at a Glance

Annex A 6.4 of ISO 27001:2022 focuses on the disciplinary process for information security violations.

At a practical level, this means:

  • Defining how information security breaches are handled
  • Communicating consequences clearly to personnel
  • Applying disciplinary action consistently and fairly
  • Considering intent, impact, and circumstances
  • Aligning disciplinary action with legal and contractual obligations

The control does not mandate dismissal or punitive action. It expects a graduated, proportionate approach that acts as both a deterrent and a corrective mechanism.

In-Depth Guide to Annex A 6.4

What Is Annex A 6.4 and Why Does It Matter?

Information security relies on people following agreed rules.

When violations occur and:

  • No action is taken
  • Responses are inconsistent
  • Outcomes appear arbitrary

…confidence in the ISMS erodes quickly.

Annex A 6.4 ensures organisations:

  • Respond to violations deliberately, not emotionally
  • Treat similar breaches in a consistent manner
  • Reinforce expected behaviours
  • Reduce repeat or deliberate violations

This control supports accountability without creating a culture of fear.

How to Implement Annex A 6.4 Effectively

A pragmatic approach to Annex A 6.4 typically includes the following elements.

1. Define a Formal Disciplinary Process

Organisations should document how disciplinary matters relating to information security are handled, including:

  • When disciplinary action may be considered
  • Who is responsible for managing the process
  • How decisions are made and approved

Clarity prevents ad-hoc or inconsistent responses.

2. Communicate the Process Clearly

Personnel should be aware of:

  • What constitutes a breach of information security policy
  • That breaches may result in disciplinary action
  • Where to find disciplinary procedures

Awareness acts as a deterrent and supports fairness.

3. Apply a Proportionate, Graduated Approach

Disciplinary action should consider factors such as:

  • Nature and seriousness of the breach
  • Impact on confidentiality, integrity, or availability
  • Whether the action was deliberate or accidental
  • Whether this is a first or repeat occurrence
  • Whether appropriate training and guidance had been provided

Not all breaches warrant the same response.

4. Ensure Consistency and Fairness

Similar breaches should be handled in a similar way.

Consistency:

  • Reinforces credibility
  • Reduces legal and HR risk
  • Prevents perceptions of bias or unfairness

Decisions should be evidence-based and documented.

5. Align with Legal, HR, and Contractual Obligations

Disciplinary processes must comply with:

  • Employment law
  • Contractual terms
  • Regulatory and organisational requirements

Information security teams should not act in isolation — coordination with HR and legal functions is essential.

6. Act in a Timely Manner

Disciplinary action should be taken without unnecessary delay once facts are established.

Delays:

  • Undermine deterrence
  • Reduce clarity of cause and effect
  • Increase the risk of repeat behaviour

Timeliness supports learning and accountability.

7. Use Disciplinary Outcomes to Support Improvement

Disciplinary action should not be the end of the process.

Organisations may also consider:

  • Additional training or awareness
  • Process or control improvements
  • Clarification of policies or procedures

The goal is to reduce future risk, not simply penalise behaviour.

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 6.4 does not require:

  • Zero-tolerance enforcement
  • Immediate escalation to severe penalties
  • Public or punitive handling of breaches

It does require organisations to:

  • Treat security violations seriously
  • Respond consistently
  • Balance deterrence with fairness

A weak disciplinary process increases insider risk.
An overly aggressive one damages culture and trust.

Common Challenges and How to Overcome Them

  • Ignoring minor breaches
  • Address issues proportionately before they become systemic
  • Inconsistent handling between teams or roles
  • Apply the same process regardless of seniority
  • Disciplinary action without evidence
  • Base decisions on facts and documented investigation
  • Treating discipline as punishment only
  • Use outcomes to reinforce learning and improvement

Most failures stem from inconsistency, not lack of policy.

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 6.4 is about making information security enforceable.

When disciplinary processes are applied effectively:

  • Security policies carry real weight
  • Behaviour aligns more closely with expectations
  • Repeat violations are reduced
  • The ISMS gains credibility and authority

People take security seriously when they see it is managed seriously.

That is exactly what Annex A 6.4 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