Annex A 6.4: Disciplinary Process

Annex A 6.4 sits in the “people controls” portion of ISO/IEC 27001:2022 and exists for a simple operational reason: policies without consequences do not hold up under pressure. You can have strong access controls, training, and monitoring, but if a repeated security violation gets treated as “a coaching moment” every time, your ISMS loses credibility and risk increases.

For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing Annex A 6.4 is to treat it as a join between HR, Legal, and Information Security. HR owns discipline, Security owns the rule set (policies/standards), Legal manages fairness and labor law considerations, and GRC verifies control operation and evidence.

This page gives requirement-level implementation guidance: what the control expects, who it applies to, how to build the workflow, what evidence to retain, and how auditors tend to test it. The goal is assessment-ready execution, not a theoretical policy document. References: ISO/IEC 27001 overview; ISMS.online Annex A control index.

Regulatory text

Provided excerpt: “ISO/IEC 27001:2022 Annex A control 6.4 implementation expectation (Disciplinary Process).” ¹

Operator interpretation (what you must do):

• Establish a documented disciplinary process that covers information security policy violations.
• Ensure the process is consistently applied, fair, and integrated with HR procedures (so discipline is enforceable, defensible, and repeatable).
• Be able to prove operation through records of cases, decisioning, and outcomes. Auditors generally accept redacted samples.

This control is not asking you to “punish people.” It requires a predictable mechanism to address violations, deter repeat behavior, and reinforce the ISMS.

Plain-English interpretation

Annex A 6.4 expects you to have an agreed way to respond when someone breaks an information security rule (intentionally or accidentally). The process must answer:

• What counts as a violation?
• How is it reported and investigated?
• Who decides outcomes and on what basis?
• What actions are available (coaching, warnings, termination, contract remedies)?
• How do you document and retain evidence?

If you cannot show consistent handling across similar incidents, expect auditor follow-ups on control effectiveness.

Who it applies to

Entity scope: Any organization implementing an ISO/IEC 27001:2022 ISMS, including service organizations. ²

Operational scope (who in your environment):

• Employees (all functions; privileged roles often warrant additional scrutiny).
• Contractors and temporary staff (handled via contract terms plus onboarding acknowledgements).
• Third parties with access to systems or data (handled through contractual enforcement paths, access suspension, and reporting to the third party employer).

Where it matters most:

• Roles with elevated access (admins, engineers, IT operations).
• Teams handling regulated data (customer data, HR data, financial data).
• Environments with heavy third-party access (managed services, outsourced support).

What you actually need to do (step-by-step)

1) Define “security violations” and map them to policy sources

Create a simple crosswalk that links common violations to the policy/standard they break. Keep it practical:

• Examples: sharing passwords, bypassing MFA, unauthorized SaaS, mishandling confidential data, unapproved code changes, failure to report a suspected incident.
• Tie each to the authoritative document (policy, standard, acceptable use, secure development rules).

Output: “Information Security Violations Matrix” (policy-to-violation mapping).

2) Align HR + Legal + Security on roles and decision rights

Write down who does what, so cases do not stall:

• Security: identifies potential violation, preserves technical evidence, advises on impact.
• HR: runs the disciplinary process and maintains personnel records.
• Legal (as needed): reviews high-risk cases, helps maintain fairness and local compliance.
• Line management: provides context and participates in corrective action planning.

Decision rights to clarify:

• Who can suspend access immediately?
• Who approves final discipline level?
• When must Legal be involved?

Output: RACI for disciplinary actions tied to security violations.

3) Create a graded consequence model that supports consistency

Define discipline bands that match your HR practice (your HR policy may already do this). What auditors want is consistency and documentation.

• Band examples (name them to match HR language): coaching/remediation, written warning, final warning, termination.
• Define aggravating factors (intentional misuse, repeated behavior, privileged access abuse, obstruction).
• Define mitigating factors (self-reporting, training gap, unclear procedure, first-time mistake).

Output: “Security Disciplinary Guidelines” that HR can apply.

4) Build the case workflow (intake → triage → investigation → decision → close)

Use a ticketed workflow that can produce evidence while protecting confidentiality.

Recommended workflow checkpoints:

1. Intake: Report comes from monitoring, manager, hotline, or incident process.
2. Triage: Decide if this is (a) training issue, (b) process defect, (c) disciplinary case, or (d) security incident needing incident response.
3. Investigation: Collect logs, access records, emails, interview notes. Preserve chain-of-custody where relevant.
4. Decision meeting: HR-led; Security advises; Legal consulted as required; document rationale.
5. Outcome + corrective actions: Document both the HR action and the security fixes (access change, retraining, procedure updates).
6. Closure: Confirm evidence retention, lessons learned, and any ISMS updates (policy clarification, control improvement).

Output: Disciplinary case procedure + case record template.

5) Extend the approach to contractors and third parties

Employees are the easy case. Contractors and third parties require enforceable terms:

• Contract clauses for acceptable use, security compliance, investigations support, and consequences (access termination, contract termination, notification to employer).
• Onboarding acknowledgements for non-employees with access.
• A clear internal rule: Security can suspend third-party access pending investigation.

Output: Standard contract addendum language (owned by Legal/procurement) + third-party access suspension SOP.

6) Prove operation with recurring evidence capture

Annex A 6.4 commonly fails on evidence. Build a lightweight evidence pack:

• A central log of disciplinary cases tagged “information security violation.”
• Redacted case files showing consistent workflow steps.
• Trend reporting to management (without personal identifiers) to show the ISMS learns.

Daydream (or any GRC system you already run) becomes useful here as a control operations layer: map Annex A 6.4 to the HR/Security workflow, schedule recurring evidence pulls, and package redacted samples for audits without scrambling.

Required evidence and artifacts to retain

Keep evidence sufficient to show the process is defined and operating, while respecting confidentiality:

Governance artifacts

• Disciplinary process document covering security violations.
• RACI and escalation criteria.
• Security disciplinary guidelines (bands, factors, examples).
• Cross-reference to HR policy and code of conduct.

Operational records (redacted where needed)

• Case register (case ID, date, category, role type, outcome band, closure date).
• Evidence of intake and triage (ticket screenshots, alerts, manager referral).
• Investigation notes and technical evidence references (log extracts, access history).
• Decision documentation (approvals, rationale, HR action taken).
• Corrective actions (training completion, access removal, policy update tickets).
• Management review notes where trends are discussed.

Retention Follow your HR/legal retention schedule for personnel matters, and ensure security evidence retention aligns with that schedule. Document the rule, then follow it.

Common exam/audit questions and hangups

Auditors typically test Annex A 6.4 through interviews plus sampling.

Common questions

• Show the documented disciplinary process for security violations. Where is it approved and who owns it?
• How do you ensure consistency across departments and locations?
• Provide a sample of cases from the period under audit (redacted) showing end-to-end handling.
• How do you handle contractor/third-party violations?
• How do you prevent retaliation and protect reporting confidentiality?
• How does this connect to incident management and HR investigations?

Hangups that trigger findings

• “We have an HR discipline policy” but it does not mention information security violations or Security’s role.
• No case evidence, or cases exist but are scattered across email and informal chats.
• Security applies consequences directly (access removal) without HR governance, creating inconsistency and employee relations risk.
• Contractors are excluded from the process.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Writing a security-only discipline policy	HR won’t run it; outcomes become ad hoc	Make HR the process owner; Security supplies violation taxonomy and evidence requirements
No defined triggers	Teams argue whether something is “disciplinary”	Define triage criteria and examples in the violations matrix
Conflating incident response with discipline	Incident workflow optimizes containment, not fairness	Run parallel tracks: incident handling and HR discipline, with clear handoffs
Over-collecting sensitive data	Creates privacy and HR record risks	Store minimum necessary evidence; keep a reference to logs where possible
Inconsistent treatment of similar cases	Auditor will view as ineffective	Use discipline bands + factors; require HR sign-off for deviations

Enforcement context and risk implications

No public enforcement cases were provided in the available source catalog for this requirement, so this page focuses on assessment and operational risk.

Risk-wise, weak disciplinary execution shows up as:

• Repeated policy violations without meaningful correction.
• Insider risk exposure (malicious or negligent behavior).
• Auditor findings tied to “control not operating effectively,” which can cascade into customer trust issues for service organizations.

Practical 30/60/90-day execution plan

First 30 days (stabilize and document)

• Assign owners: HR process owner, Security technical owner, GRC evidence owner.
• Draft the disciplinary workflow for security violations (integrate with existing HR discipline policy).
• Build the violations matrix (top recurring violations first).
• Define escalation triggers and who can suspend access.

By 60 days (operate and collect proof)

• Implement the case register (ticketing workflow or GRC workflow).
• Train HR partners and Security leads on triage and evidence capture.
• Run tabletop scenarios: lost laptop, credential sharing, unauthorized SaaS, data mishandling.
• Start capturing redacted case evidence in a consistent folder structure.

By 90 days (make it auditable and repeatable)

• Perform an internal control check: sample closed cases and confirm artifacts exist.
• Add trend reporting to management review (counts by category and outcome band, without identifiers).
• Extend to third parties: contract addendum template, onboarding acknowledgement, access suspension procedure.
• If you use Daydream, map Annex A 6.4 to the workflow steps and set recurring evidence tasks so audits become a retrieval exercise, not a rebuild.

Frequently Asked Questions

Do we need to document exact disciplinary consequences for every type of violation?

Document bands and decision factors, not a rigid penalty table. Auditors look for consistency and rationale, and HR typically needs discretion for context.

Can Security impose discipline directly by disabling accounts?

Security can suspend access for risk containment, but HR should own the disciplinary decision. Separate “access control action” from “HR consequence,” and document both.

How do we handle contractors who violate security policy?

Use contract terms and onboarding acknowledgements to make expectations enforceable. Your internal process should include access suspension and a defined notification/escalation path to the contracting firm.

What evidence is enough for an ISO audit?

A documented process plus a small set of redacted case samples that show intake, investigation, decision, and closure artifacts. A case register that ties everything together prevents gaps.

How do we protect confidentiality while still providing audit evidence?

Provide redacted case files and a sanitized case register. Keep detailed HR records in HR systems, and reference them from security/GRC evidence without duplicating sensitive content.

We had no disciplinary cases this year. Is that a problem?

Not automatically, but auditors may challenge whether monitoring and reporting work. Show the process, reporting channels, training/acknowledgements, and any “near miss” coaching or non-disciplinary corrections.

Footnotes

1. ISO/IEC 27001 overview; ISMS.online Annex A control index

2. ISO/IEC 27001 overview