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Security Disciplinary Process Template (ISO/IEC 27001 A.6.4)

Principles, breach categories C0 to C3, incident hand-off, investigation, fair process and appeal, outcomes and factors, contractors, records

СУІБ та ISO/IEC 27001ПовнийISO/IEC 27001:2022 A.6.4 (cited only); ISO/IEC 27002:2022securitydisciplinaryprocess

Як використовувати: Use it when you need a formal, communicated process for security policy breaches on top of your HR disciplinary procedure. Fill the breach categories and the incident hand-off first. The main pitfall is punishing honest, self-reported mistakes, which stops people reporting.

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Disciplinary Process for Security Breaches: [Organization name]

Formal, communicated process for handling breaches of information security policy by personnel: categories of breach, how a matter is raised and investigated, how HR and legal take part, how the process links to incident management, what outcomes are possible and which records are kept. It supports ISO/IEC 27001:2022 + Amd 1:2024, Annex A control A.6.4 (disciplinary process), with guidance in ISO/IEC 27002:2022, and works alongside A.5.24 to A.5.28 (incident management and evidence collection) and A.6.3 (awareness, education and training). It is a security layer on top of the organization's general disciplinary procedure, not a replacement for it. Replace every [bracketed] value and every row marked Example. This is a documentation format, not legal advice: employment law, works council rights and employee monitoring rules differ by country.

Document control

FieldValue
Document IDDOC-ISMS-052
Version[1.0]
Status[Draft / In review / Approved / Superseded]
Owner[@head-of-people] (process), [@isms-manager] (security layer)
Approvers/reviewers[@general-counsel], [@ciso], [@dpo], [employee representative body where consultation is required]
Last updatedYYYY-MM-DD
Classification[Internal] (process), case records [Confidential, restricted]
Standard and editionISO/IEC 27001:2022 + Amd 1:2024, A.6.4; guidance ISO/IEC 27002:2022
Base HR procedure[Reference to the general disciplinary procedure, for example built from hr/disciplinary-grievance-procedure]
Countries covered[Countries for which counsel has confirmed the process]
Next scheduled reviewYYYY-MM-DD (at least annually and after any appeal that changes practice)

Approvals

RoleNameDecisionDate
HR[@head-of-people][Prepared]YYYY-MM-DD
Legal counsel[@general-counsel][Approved for listed countries]YYYY-MM-DD
ISMS owner[@isms-manager][Approved]YYYY-MM-DD
Top management[@ceo][Approved]YYYY-MM-DD

Revision history

VersionDateAuthorChange
1.0 (Example)YYYY-MM-DD[@head-of-people]First approved version, communicated through the employee security handbook
1.1 (Example)YYYY-MM-DD[@isms-manager]Clarified honest-error route after the first annual review

Contents

  1. Purpose and scope
  2. Principles
  3. Roles and responsibilities
  4. Breach categories
  5. Raising a matter and the link to incident management
  6. Investigation
  7. Fair process, decision and appeal
  8. Outcomes and influencing factors
  9. Contractors, agency staff and suppliers
  10. Communication and awareness
  11. Size tiers
  12. Records and evidence
  13. Metrics
  14. References

1. Purpose and scope

This process makes sure that breaches of information security policy by people working for [Organization name] are handled consistently, fairly and in proportion to their seriousness, and that the existence of the process deters deliberate misuse. It covers employees at all levels, including managers and executives, and sets how breaches by contractors, agency staff and supplier personnel are handled through their contracts.

It applies to breaches of the information security policy (DOC-ISMS-001), the topic-specific policies listed in the policy framework (DOC-ISMS-005), the acceptable use policy (DOC-ISMS-040) and confidentiality agreements (DOC-ISMS-051).

2. Principles

  1. Proportionate. The response matches the seriousness of the breach, its intent and its consequences.
  2. Fair. The person is told what is alleged, sees the relevant evidence where the law allows, can respond, can be accompanied where the law or policy gives that right, and can appeal.
  3. Consistent. Similar breaches lead to similar outcomes regardless of seniority, team or relationships.
  4. Documented. Every step, decision and reason is recorded in the case file.
  5. Just culture. Honest mistakes and self-reported errors are handled by learning, coaching and training, not by sanctions. Reporting a security event is never itself a disciplinary matter, and neither is a disclosure that whistleblower law protects; retaliation against a person who reports in good faith is itself a breach under this process.
  6. Evidence first. Incident response preserves and collects evidence before any disciplinary interview (A.5.28).
  7. Lawful. Monitoring data and evidence are used only as local law, works council agreements and the monitoring notice given to staff allow.
  8. Confidential. Case details are shared only with those who need them.

3. Roles and responsibilities

RoleResponsibility
Line managerRaises concerns, does not investigate alone, takes part in coaching outcomes
ISMS manager or security teamAssesses the security facts, provides technical findings, classifies the breach category with HR
Incident leadRuns incident response, preserves evidence, decides when the disciplinary track may start without harming the investigation
HROwns the procedure, appoints the investigating officer, arranges meetings, keeps the case file
Investigating officerGathers facts, interviews, writes the investigation report, does not decide the outcome
Decision makerSenior manager not involved in the investigation, decides outcome
Legal counselAdvises on law, monitoring evidence, external reporting and litigation risk
Data protection officer or privacy leadAdvises on lawful use of personal data in evidence, access requests to case files
Appeal officerMore senior manager or panel not involved earlier
Employee representative bodyConsulted or informed where law or agreement requires

4. Breach categories

CategoryDescriptionExamples (Example)Default route
C0 Honest errorUnintentional mistake, no negligence, often self-reportedSends an internal file to the wrong colleague and reports it at onceLearning route: coaching, targeted training, process fix
C1 Minor breachCareless non-compliance with limited impactLeaves an unlocked laptop in the office, repeated failure to complete mandatory training after remindersInformal action by line manager with HR record of the conversation
C2 Serious breachNegligent or knowing breach with real or likely harmShares a password, disables endpoint protection, stores Confidential data in a personal cloud accountFormal process (sections 6 and 7)
C3 Gross misconductDeliberate, malicious or highly damaging breachExfiltrates customer data, sells access, deliberately sabotages systems, accesses records without any business reasonFormal process, possible suspension during investigation, possible referral to authorities

Rules:

  • Repeat C0 events by the same person in a short period are reviewed by HR and the ISMS manager to decide whether a process or training issue, or a C1, applies.
  • A failed phishing simulation is never a disciplinary matter by itself (see isms/phishing-simulation-plan).
  • Managers who instruct or knowingly allow a breach are assessed as if they committed it.

5. Raising a matter and the link to incident management

A matter can start from:

  • a security incident or event where personnel conduct contributed (compliance/incident-response-plan, DOC-ISMS-020, and the incident register DOC-ISMS-021);
  • an audit finding, access review or monitoring alert;
  • a report by a colleague, manager or third party, including through the whistleblowing channel. Keep the reporter's identity confidential as the applicable whistleblower law and policy require, and share it with the investigation only where that law allows.

Hand-off steps:

  1. The incident lead records in the incident record that personnel conduct may be involved, and informs HR and the ISMS manager only.
  2. The incident lead preserves evidence with chain of custody (security/forensic-evidence-record) and confirms when interviews will not compromise containment or the investigation.
  3. HR and the ISMS manager agree the provisional category (section 4). C0 goes to the learning route and the case closes with a training or process action.
  4. For C1, the line manager acts with HR. For C2 and C3, HR opens a case (ID DISC-YYYY-NNN) and appoints an investigating officer.
  5. Legal counsel decides whether any external reporting (regulator, data protection authority, police) is required. Reporting duties under incident management are never delayed by the disciplinary track.

6. Investigation

  1. Terms of reference. HR writes the scope of the investigation, the allegations and the investigating officer's name.
  2. Suspension. For C3, suspension on full pay or removal of access may be used as a neutral, protective act, not as a sanction, where local law and the general HR procedure allow it, and kept under review. Remove access through the urgent leaver steps in isms/offboarding-security-checklist where needed.
  3. Evidence. Use the technical findings from the security team, logs and records already collected under the incident process. Access to mailboxes, devices or monitoring data follows the monitoring notice, local law and legal counsel's advice.
  4. Interviews. Interview the person and witnesses, record notes, and let interviewees check their notes.
  5. Report. The investigating officer writes findings of fact, whether the allegation is supported, and a recommendation on whether a disciplinary meeting is needed. The report is not a decision.
Case IDCategorySourceOpenedInvestigating officerStatus
DISC-2026-001 (Example)C2INC-2026-0142026-03-02[@hr-investigator]Investigation
DISC-2026-002 (Example)C3Access review finding2026-04-18[external investigator]Decision pending

7. Fair process, decision and appeal

  • Invite the person in writing to a meeting with enough notice to prepare, state the allegations, and share the evidence relied on, removing information that would compromise security (for example detection logic) where legal counsel agrees.
  • Explain technical evidence in plain language. The security team may attend to explain findings but does not take the decision.
  • The decision maker considers the investigation report, the person's response and the factors in section 8, and confirms the outcome and the reasons in writing, with the right of appeal.
  • Appeals are heard by someone not involved before. The appeal decision is final within the internal process.
  • Where an employee representative body has rights of consultation or attendance, follow them.

8. Outcomes and influencing factors

Possible outcomes, depending on the general HR procedure and local law:

OutcomeTypical use
No action, or learning actionAllegation not supported, or C0
Coaching and mandatory trainingC1, or C2 with strong mitigating factors
Written warning, with review periodC2
Final written warningRepeat C2 or C2 with aggravating factors
Removal of privileged access or change of roleWhere trust in a specific role is lost
DismissalC3, or repeat C2 after final warning, where lawful
Civil or criminal referralC3 involving fraud, theft or sabotage, on legal advice

Factors the decision maker weighs:

  • Aggravating: intent, concealment, personal gain, harm to customers, privileged position, prior warnings, refusal to cooperate.
  • Mitigating: self-reporting, honest belief, unclear policy or missing training, pressure from a manager, prompt cooperation, length of good record.

After each case, the ISMS manager checks whether a policy, control or training gap contributed and records an improvement in the continual improvement register (DOC-ISMS-088) or a corrective action (DOC-ISMS-087).

9. Contractors, agency staff and suppliers

RelationshipResponse to a breach
Individual contractorContract remedies: removal of access, termination for breach, claims under the confidentiality agreement (DOC-ISMS-051)
Agency staffRemoval from assignment, the agency applies its own disciplinary process, notification under the agency contract
Supplier personnelRequest removal of the individual, supplier corrective action under the supplier security agreement (DOC-ISMS-068), contract review

10. Communication and awareness

  • Summarise this process in the employee security handbook (isms/employee-security-handbook) and in induction training.
  • State the just-culture principle clearly: reporting mistakes is expected and protected.
  • Include the process in manager training so managers do not act alone.
  • Keep the process available on the intranet in every working language.

11. Size tiers

AspectSmall: Quillmere Analytics LtdMedium: Quillmere Health SystemsLarge: Quillmere Group
Who investigatesExternal HR adviser, technical facts from the ISMS manager (0.5 FTE)Trained HR investigators, 3-person security team for technical factsCountry HR teams, CISO office forensic support, group legal
Separation of rolesCEO decides, external adviser hears appealsDepartment director decides, executive hears appealsSite management decides, regional HR director hears appeals
Representative bodiesUsually noneDepends on office countriesWorks councils or unions at plants in several countries, consultation built into process
Volume and trackingA few cases a year, tracked in a restricted HR folderCase log in HR systemCase management system with country reporting

12. Records and evidence

RecordProvesOwnerLocationRetention
Approved process and communication recordProcess formal and communicatedHRPolicy portal, handbook acknowledgementsLife of version plus [3] years
Case file (terms of reference, report, decision, appeal)Fair, documented handlingHRHR system, restrictedPer legal register DOC-ISMS-014, Example: [6] years after case closure
Link between incident record and case IDHand-off from incident managementIncident lead, HRIncident register DOC-ISMS-021As incident register
Anonymised case statisticsConsistency and trendsHR, ISMS managerManagement review input[3] years
Lessons learned actionsImprovement after casesISMS managerDOC-ISMS-088 or DOC-ISMS-087As register

13. Metrics

MetricTarget (Example)
Cases closed with a documented decision and reasons100%
Cases started from self-reports that led to sanctions0 for C0
Median days from case opening to decisionSet per country, reviewed yearly
Staff acknowledgement of the handbook including this process98% or more

14. References

ReferenceEditionUse
ISO/IEC 27001:2022 + Amd 1:2024, https://www.iso.org/standard/82875.html, Amd: https://www.iso.org/standard/88435.html2022, Amd 1 2024-02-23Control A.6.4, links to A.5.24 to A.5.28 and A.6.3
ISO/IEC 27002:2022, https://www.iso.org/standard/75652.html2022Guidance on disciplinary process
ISO/IEC 27037:2012, https://www.iso.org/standard/44381.html2012Handling of digital evidence
NIST SP 800-53 Rev. 5 (release 5.2.0, August 2025), control PS-8 Personnel SanctionsRev. 5Optional crosswalk

Related templates: hr/disciplinary-grievance-procedure, compliance/incident-response-plan, isms/incident-register, isms/security-event-reporting-procedure, security/forensic-evidence-record, isms/confidentiality-nda, isms/offboarding-security-checklist, isms/phishing-simulation-plan, isms/employee-security-handbook, compliance/acceptable-use-policy, isms/continual-improvement-register, compliance/capa-nonconformity, isms/control-evidence-matrix.

Standard and licence note

Structure aligned with ISO/IEC 27001:2022 including Amd 1:2024, Annex A control A.6.4, with guidance in ISO/IEC 27002:2022. The principles, categories, process, examples and guidance are original wording; no ISO or IEC text is reproduced. ISO and IEC standards are copyrighted: obtain the official standard from ISO or your national standards body (https://www.iso.org/standard/82875.html). Check the current edition and amendments, and the employment law of each country, before use. This is a documentation format, not legal advice. Template licence: MIT.

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