When an organisation undergoes the transition from ISO 27001:2013 to the 2022 update, much of the attention naturally goes to technical upgrades like cloud security or threat intelligence. However, some of the most critical changes involve how we manage our people. One such area is the disciplinary process, now found under Annex A 6.4. While the concept of a disciplinary procedure isn’t new, its role within the modern security framework has become much more integrated and accountable.
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The Shift from 7.2.3 to 6.4
In the 2013 version of the standard, the disciplinary process was tucked away under Control 7.2.3 as part of the “Human Resources Security” domain. In many ways, it was treated as a “background” control, something that existed in an HR handbook but wasn’t always front-and-centre for the security team. It was often a reactive measure: if someone broke the rules, HR handled it.
In the 2022 update, this control has been rebranded as Annex A 6.4 and moved into the People Controls theme. This change in classification is significant. As the experts at Hightable.io note, reclassifying this as a “People Control” highlights that a fair and formal disciplinary process is a proactive security tool. It acts as a deterrent and a mechanism for maintaining a “security-first” culture, rather than just being a legal formality.
What Exactly is Annex A 6.4?
The requirement of Annex A 6.4 is clear: a formal disciplinary process must be established and communicated to all personnel and relevant interested parties. This process is used to take action against those who have committed an information security policy violation.
The 2022 version puts a stronger emphasis on the formalisation and communication of this process. It isn’t enough to have a policy hidden on an intranet; employees must be aware of the consequences of their actions before an incident occurs. According to Hightable.io, the primary purpose is to ensure that everyone understands that security violations have real-world ramifications, which helps prevent accidental or negligent breaches.
Key Differences and Modern Requirements
If you are moving from the 2013 standard to the 2022 version, you will notice a few subtle but powerful shifts in how you are expected to implement this control:
- Integration with Incident Management: The 2022 standard encourages a tighter link between the disciplinary process and your incident reporting workflow. You should be able to show how a reported security event leads to a fair investigation and, where necessary, a formal outcome.
- A Graduated and Proportional Response: The new framework expects the response to be “calibrated.” As highlighted by Hightable.io, your process should distinguish between an accidental mistake (like clicking a phishing link once) and deliberate misconduct (like stealing data). The consequence must fit the crime.
- Attribute Tagging: The 2022 version introduces metadata attributes for each control. Annex A 6.4 is now officially tagged as a Deterrent and Corrective control. This helps organisations report more clearly on how they are discouraging bad behaviour and correcting it when it happens.
Practical Implementation: Collaboration is Key
In the 2013 era, the “Security Officer” and the “HR Manager” often worked in silos. For ISO 27001:2022 compliance, Annex A 6.4 requires these two functions to be in sync. Your security policy needs to explicitly link to your HR disciplinary policy.
Hightable.io suggests that a successful transition involves creating a “Security Sanction Matrix.” This is a simple document that provides examples of security breaches (moderate, severe, gross) and the corresponding disciplinary actions. This ensures that the process is transparent and that identical breaches result in consistent consequences across the organisation, which is a major focus for ISO auditors in the 2022 version.
What Will an Auditor Look For?
Transitioning to the 2022 standard means you need a more robust evidence trail. An auditor won’t just ask “Do you have a disciplinary policy?” They will likely want to see:
- Proof of Communication: Evidence that staff have acknowledged the policy (e.g., through an HR portal or signed handbook).
- Consistent Application: If violations have occurred, the auditor will check if the documented process was followed fairly and consistently.
- Training Records: Confirmation that the individual involved had actually been trained on the policy they violated.
- Feedback Loops: Evidence that the outcomes of disciplinary cases are being used to improve training or update technical controls.
Why This Change Matters
The update to Annex A 6.4 reflects the reality that most modern security breaches have a human element. By elevating the disciplinary process to a primary “People Control,” ISO 27001:2022 ensures that accountability is a cornerstone of your ISMS. When people know the rules and understand the fair consequences of breaking them, they are more likely to stay vigilant.
As suggested by Hightable.io, the best way to move forward is to review your current HR policies against the 2022 requirements. Ensure your “misconduct” definitions include specific information security examples. This simple alignment doesn’t just pass an audit; it builds a culture of trust and transparency that protects both the business and its employees.