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ISO 27001A.6 — Disciplinary process

A.6.4

Disciplinary process

ISO 27001 · ISO/IEC 27001:2022 · Last verified July 2026

Objective

Take formal disciplinary action against personnel who commit information security policy violations.

Points of focus

  • Document a formal disciplinary process co-owned by HR and security/compliance
  • Confirm policy acknowledgment happened before any enforcement action, not retroactively
  • Apply the process consistently across roles and seniority levels
  • Retain redacted case records demonstrating the process operates, not just that it exists on paper

Implementation notes

Write the disciplinary process into HR policy with explicit reference to information security violations — data mishandling, credential sharing, bypassing access controls, unauthorized disclosure — not just generic misconduct. Sequence matters for auditors: the code of conduct and acceptable use policy must be acknowledged during onboarding, before any enforcement could reasonably apply, and that acknowledgment needs a timestamp per employee. Define a proportionate escalation path (informal coaching, formal warning, termination) tied to severity and intent, and apply it the same way regardless of role or tenure — an exception for a senior engineer is the kind of inconsistency that undermines the whole control during interviews. If a real case has occurred, keep a redacted record showing what happened, what policy was violated, and what action followed; if none has occurred, that's a legitimate answer as long as the underlying acknowledgment and escalation-path evidence exists.

Audit tip: If you've never had a real violation, say so plainly and show the process design plus the signed acknowledgments proving employees knew the rules. Fabricating a case record to look operational is worse than an honest "not yet invoked."

Evidence auditors typically request:

  • HR disciplinary policy referencing information security violations specifically, not just general conduct
  • Signed acknowledgment of the code of conduct and acceptable use policy at onboarding, dated per employee
  • Redacted case log or example showing a violation, the action taken, and the date
  • Escalation matrix showing how severity maps to response (verbal warning through termination)

Common gaps

  • The disciplinary policy references "security policy violations" but the acceptable use policy it points to was never actually distributed for signature
  • A real incident occurred and was handled informally over Slack with no documented outcome tying back to the disciplinary policy
  • The process exists in the employee handbook but has never been invoked, so there's no way to confirm it works as written

Cross-Framework Mapping

FrameworkRequirementImplementation note
ISO 27001A.6.4This control
HIPAA164.308(a)(1)164.308(a)(1)(ii)(C) requires a sanction policy for workforce members who fail to comply with security policies and procedures — the most direct HIPAA parallel to A.6.4, right down to the emphasis on documented, applied sanctions rather than an unused policy.

Primary sources

Frequently Asked Questions

That's fine to state directly. What matters is showing the process is documented, employees acknowledged the underlying policies, and the escalation path is defined — not that you have a case history.

General HR discipline policy can cover it, but it must explicitly reference information security policy violations as a category, not rely on auditors inferring that "misconduct" includes security incidents.

HR typically owns and executes the process, while security or compliance defines what counts as a violation and feeds incidents into it. Auditors expect to see both functions represented.

The mechanism differs — contractors are usually governed by contract terms rather than an HR disciplinary policy — but the equivalent outcome (documented violation, defined consequence, applied consistently) should exist in the contractor agreement.

Framework versions referenced in this page:

  • ISO/IEC 27001 — ISO/IEC 27001:2022

Last verified: July 2026 · Primary sources linked above