ISO 27001:2022 Annex A 6.5 – Responsibilities After Termination or Change of Employment Explained

The risk does not end when someone leaves.
In many cases, it increases.

Annex A 6.5 exists to ensure organisations define, communicate, and enforce information security responsibilities that continue after employment or contractual relationships end or change.

This control protects the organisation during one of the highest-risk transition points in the people lifecycle.

Quick Guide: Annex A 6.5 at a Glance

Annex A 6.5 of ISO 27001:2022 focuses on information security responsibilities that remain in force after termination or change of employment.

At a practical level, this means:

Defining which security responsibilities continue after exit or role change
Making those responsibilities explicit in contracts or agreements
Protecting confidential information, intellectual property, and knowledge
Ensuring access rights are removed or adjusted promptly
Preventing misuse of information after departure

The control does not assume bad intent. It assumes risk exists unless responsibilities and access are managed deliberately.

In-Depth Guide to Annex A 6.5

What Is Annex A 6.5 and Why Does It Matter?

When people leave or change roles, they often retain:

Knowledge of systems and processes
Access to information
Copies of data, documents, or credentials
Ongoing relationships with customers or suppliers

If responsibilities are unclear or unenforced:

Confidential information may be disclosed
Intellectual property may be misused
Former access may be exploited
Legal and contractual protections may be weakened

Annex A 6.5 ensures organisations retain control beyond the employment relationship, not just during it.

This control applies to:

Employees
Contractors and temporary staff
Third parties with access to information

How to Implement Annex A 6.5 Effectively

A pragmatic approach to Annex A 6.5 typically includes the following elements.

1. Define Ongoing Information Security Responsibilities

Organisations should identify which responsibilities continue after:

Employment ends
Contracts expire
Roles or responsibilities change

These responsibilities commonly relate to:

Confidentiality of information
Protection of intellectual property
Use of knowledge gained during employment

Clarity prevents dispute later.

2. Embed Responsibilities in Terms and Conditions

Responsibilities that extend beyond employment should be:

Included in employment contracts
Referenced in contractor or supplier agreements
Aligned with confidentiality or non-disclosure agreements

Relying on policy alone weakens enforceability.

3. Communicate Responsibilities Clearly at Exit or Change

Responsibilities should not remain implicit.

Organisations typically:

Remind individuals of ongoing obligations
Reinforce confidentiality and non-disclosure expectations
Confirm understanding during exit or role change

Clear communication reduces “I didn’t realise” risk.

4. Remove or Adjust Access Promptly

Responsibilities alone are not sufficient.

Organisations should ensure:

Access rights are revoked or modified without delay
Credentials are disabled or replaced
Physical and logical access is addressed

Responsibility without access control is ineffective.

5. Transfer Security Responsibilities Where Roles Change

When individuals move roles internally:

Security responsibilities should be reviewed
Knowledge transfer should be managed
Access aligned with new duties

Role change is a common source of excessive or inappropriate access.

6. Address Third-Party and Contractual Scenarios

Where contractors or third parties depart, organisations should consider:

Contractual obligations that continue
Return or deletion of information
Ongoing confidentiality commitments

Third-party exits are often less controlled than employee exits — and therefore higher risk.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

Annex A 5.1 is a foundational governance control. It sets the tone for the entire Information Security Management System (ISMS).

Policies define:

What the organisation values
How security decisions are approached
Where accountability sits

Without clear policies, security becomes inconsistent. Teams improvise. Decisions vary depending on who’s involved. Risk acceptance becomes informal and undocumented.

From a security perspective, that inconsistency is often where incidents start.

From a business perspective, unclear policies lead to friction — security teams blocking work, delivery teams bypassing controls, and leadership stepping in only when something breaks.

A well-designed policy framework:

Aligns security with business objectives
Supports proportionate, risk-based decisions
Provides a reference point during incidents and disputes
Creates consistency without bureaucracy

A common real-world scenario we see is organisations with technically strong controls but weak policy direction. When an exception arises — a supplier request, a new platform, a rushed delivery — there’s no agreed framework to guide the decision. That’s when risk is introduced quietly and unintentionally.

How to Implement Annex A 5.1 Effectively

A practical, security-first approach usually includes the following steps.

1. Define a Comprehensive Information Security Policy

Policies exist to set direction, not to document every control.Start by being clear about what your policies are there to achieve:

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

Leadership support is critical. Without it, policies remain words on paper without real enforcement. Senior executives should:

Review and approve policies.
Ensure resources are allocated for implementation.
Lead by example in enforcing security policies.

3. Communicate and Train Employees

A policy is useless if no one reads or understands it.

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

Information security threats evolve, and so should your policies.

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

Your information security policy should be the backbone of your ISMS (Information Security Management System).

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

Aspect	ISO 27001:2013	ISO 27001:2022
Control Structure	Two separate controls: 5.1.1 & 5.1.2	Merged into one control (5.1)
Implementation Guidance	Less prescriptive	More detailed guidance for policy creation and alignment
Awareness & Training	Not explicitly mentioned	Explicitly requires policies to be part of training programmes
Attributes Table	Not included	ew attributes table for mapping policies to industry terms

The new approach in ISO 27001:2022 ensures that policies are not just created but actively integrated into business operations, improving security culture across organisations.

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.

By embedding strong security policies into your business operations, you don’t just tick a compliance box—you build a robust security posture that protects your organisation from real-world threats.

Practical Considerations

Annex A 6.5 does not require:

Suspicion-driven exit processes
Overly restrictive post-employment controls
Identical handling for all roles

It does require organisations to:

Recognise exit and change as risk points
Define responsibilities deliberately
Combine contractual clarity with access control

Most failures occur not through malice, but through assumption and omission.

Common Challenges and How to Overcome Them

Assuming obligations end with employment
Define and enforce post-employment responsibilities

Poorly managed exits for contractors
Apply consistent controls based on access and risk

Access removed but responsibilities not communicated
Reinforce obligations during exit processes

Role changes treated as low risk
Review responsibilities and access during internal moves

Transitions expose gaps quickly.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

Annex A 5.1 is a foundational governance control. It sets the tone for the entire Information Security Management System (ISMS).

Policies define:

What the organisation values
How security decisions are approached
Where accountability sits

Without clear policies, security becomes inconsistent. Teams improvise. Decisions vary depending on who’s involved. Risk acceptance becomes informal and undocumented.

From a security perspective, that inconsistency is often where incidents start.

From a business perspective, unclear policies lead to friction — security teams blocking work, delivery teams bypassing controls, and leadership stepping in only when something breaks.

A well-designed policy framework:

Aligns security with business objectives
Supports proportionate, risk-based decisions
Provides a reference point during incidents and disputes
Creates consistency without bureaucracy

A common real-world scenario we see is organisations with technically strong controls but weak policy direction. When an exception arises — a supplier request, a new platform, a rushed delivery — there’s no agreed framework to guide the decision. That’s when risk is introduced quietly and unintentionally.

How to Implement Annex A 5.1 Effectively

A practical, security-first approach usually includes the following steps.

1. Define a Comprehensive Information Security Policy

Policies exist to set direction, not to document every control.Start by being clear about what your policies are there to achieve:

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

Leadership support is critical. Without it, policies remain words on paper without real enforcement. Senior executives should:

Review and approve policies.
Ensure resources are allocated for implementation.
Lead by example in enforcing security policies.

3. Communicate and Train Employees

A policy is useless if no one reads or understands it.

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

Information security threats evolve, and so should your policies.

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

Your information security policy should be the backbone of your ISMS (Information Security Management System).

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

Aspect	ISO 27001:2013	ISO 27001:2022
Control Structure	Two separate controls: 5.1.1 & 5.1.2	Merged into one control (5.1)
Implementation Guidance	Less prescriptive	More detailed guidance for policy creation and alignment
Awareness & Training	Not explicitly mentioned	Explicitly requires policies to be part of training programmes
Attributes Table	Not included	ew attributes table for mapping policies to industry terms

The new approach in ISO 27001:2022 ensures that policies are not just created but actively integrated into business operations, improving security culture across organisations.

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.

By embedding strong security policies into your business operations, you don’t just tick a compliance box—you build a robust security posture that protects your organisation from real-world threats.

Final Recommendations

Annex A 6.5 is about protecting information beyond the employment relationship.

When responsibilities after termination or change are managed effectively:

Confidentiality is preserved
Insider and post-employment risk is reduced
Legal and contractual protections are strengthened
Trust is supported by structure, not assumption

People move on.
Information should not move with them unintentionally.

That is exactly what Annex A 6.5 is designed to prevent.

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

Annex A 5.1 is a foundational governance control. It sets the tone for the entire Information Security Management System (ISMS).

Policies define:

What the organisation values
How security decisions are approached
Where accountability sits

Without clear policies, security becomes inconsistent. Teams improvise. Decisions vary depending on who’s involved. Risk acceptance becomes informal and undocumented.

From a security perspective, that inconsistency is often where incidents start.

From a business perspective, unclear policies lead to friction — security teams blocking work, delivery teams bypassing controls, and leadership stepping in only when something breaks.

A well-designed policy framework:

Aligns security with business objectives
Supports proportionate, risk-based decisions
Provides a reference point during incidents and disputes
Creates consistency without bureaucracy

A common real-world scenario we see is organisations with technically strong controls but weak policy direction. When an exception arises — a supplier request, a new platform, a rushed delivery — there’s no agreed framework to guide the decision. That’s when risk is introduced quietly and unintentionally.

How to Implement Annex A 5.1 Effectively

A practical, security-first approach usually includes the following steps.

1. Define a Comprehensive Information Security Policy

Policies exist to set direction, not to document every control.Start by being clear about what your policies are there to achieve:

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

Leadership support is critical. Without it, policies remain words on paper without real enforcement. Senior executives should:

Review and approve policies.
Ensure resources are allocated for implementation.
Lead by example in enforcing security policies.

3. Communicate and Train Employees

A policy is useless if no one reads or understands it.

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

Information security threats evolve, and so should your policies.

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

Your information security policy should be the backbone of your ISMS (Information Security Management System).

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

Aspect	ISO 27001:2013	ISO 27001:2022
Control Structure	Two separate controls: 5.1.1 & 5.1.2	Merged into one control (5.1)
Implementation Guidance	Less prescriptive	More detailed guidance for policy creation and alignment
Awareness & Training	Not explicitly mentioned	Explicitly requires policies to be part of training programmes
Attributes Table	Not included	ew attributes table for mapping policies to industry terms

The new approach in ISO 27001:2022 ensures that policies are not just created but actively integrated into business operations, improving security culture across organisations.

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.

By embedding strong security policies into your business operations, you don’t just tick a compliance box—you build a robust security posture that protects your organisation from real-world threats.

ISO 27001:2022 Annex A 6.5 – Responsibilities After Termination or Change of Employment Explained

Quick Guide: Annex A 6.5 at a Glance

In-Depth Guide to Annex A 6.5

What Is Annex A 6.5 and Why Does It Matter?

How to Implement Annex A 6.5 Effectively

1. Define Ongoing Information Security Responsibilities

2. Embed Responsibilities in Terms and Conditions

3. Communicate Responsibilities Clearly at Exit or Change

4. Remove or Adjust Access Promptly

5. Transfer Security Responsibilities Where Roles Change

6. Address Third-Party and Contractual Scenarios

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy

2. Secure Senior Management Approval

3. Communicate and Train Employees

4. Regular Review & Continuous Improvement

5. Integrate Policies into the ISMS

Key Differences: ISO 27001:2013 vs ISO 27001:2022

Common Challenges & How to Overcome Them

Final Recommendations

Practical Considerations

Common Challenges and How to Overcome Them

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy

2. Secure Senior Management Approval

3. Communicate and Train Employees

4. Regular Review & Continuous Improvement

5. Integrate Policies into the ISMS

Key Differences: ISO 27001:2013 vs ISO 27001:2022

Common Challenges & How to Overcome Them

Final Recommendations

Final Recommendations

In-Depth Guide to Annex A 5.1

What is Annex A 5.1 and Why Does It Matter?

How to Implement Annex A 5.1 Effectively

1. Define a Comprehensive Information Security Policy

2. Secure Senior Management Approval

3. Communicate and Train Employees

4. Regular Review & Continuous Improvement

5. Integrate Policies into the ISMS

Key Differences: ISO 27001:2013 vs ISO 27001:2022

Common Challenges & How to Overcome Them

Final Recommendations

The Annex Control Table

ISO 27001:2022 Organisational Controls

ISO 27001:2022 People Controls

ISO 27001:2022 Physical Controls

ISO 27001:2022 Technological Controls

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