Information Security Disciplinary Process
A Structured Process for Handling Information Security Violations
The Information Security Disciplinary Process defines how an organization should handle suspected violations of information-security requirements by employees, contractors, and other personnel.
The process is designed to ensure that security violations are handled consistently, fairly, proportionately, and in accordance with applicable organizational, contractual, employment, privacy, and legal requirements.
The process should distinguish between an honest mistake, negligence, repeated non-compliance, reckless behavior, and deliberate misconduct.
Identify → Report → Preserve → Investigate → Assess → Decide → Act → Record → Follow Up → Improve
1. Purpose
The purpose of this process is to:
- Provide a consistent approach to security violations
- Protect organizational information and systems
- Ensure immediate security risks are contained
- Establish facts before making decisions
- Support fair and proportionate disciplinary decisions
- Coordinate Security, HR, Management, and Legal functions
- Protect investigation evidence
- Address root causes
- Prevent recurrence
- Maintain appropriate audit evidence
The process is not intended to punish personnel for reporting genuine mistakes or security incidents in good faith.
2. Scope
This process applies to:
☐ Employees
☐ Contractors
☐ Consultants
☐ Interns
☐ Temporary personnel
☐ Privileged users
☐ Remote workers
☐ Other personnel with organizational access
For third-party personnel, the applicable supplier-management and contractual processes should also be followed.
3. Core Principles
Fairness
The organization should establish facts before reaching conclusions.
Proportionality
The response should reflect the seriousness of the violation and associated risk.
Consistency
Comparable situations should be handled consistently, subject to relevant differences in circumstances.
Evidence-Based Decisions
Decisions should be supported by reliable evidence.
Confidentiality
Investigation and disciplinary information should only be accessible to authorized personnel.
Non-Retaliation
Good-faith reporting of security incidents or concerns should not itself result in disciplinary action.
Risk Reduction
The objective is to reduce security risk and prevent recurrence.
Legal Compliance
The process must be applied in accordance with applicable employment, privacy, labor, contractual, and other legal requirements.
4. Security Incident vs Disciplinary Matter
Not every security incident requires disciplinary action.
Example 1 — Accidental
An employee clicks a phishing link and immediately reports it.
Response:
- Contain the risk
- Investigate as necessary
- Reset credentials if required
- Provide awareness reinforcement
Disciplinary action is not automatically appropriate.
Example 2 — Deliberate
An employee intentionally accesses customer records without authorization.
Response:
- Restrict access if required
- Preserve evidence
- Investigate
- Assess impact
- Coordinate with HR/Legal
- Determine appropriate action
The organization should assess each case based on facts and circumstances.
5. Process Overview
The complete process is:
Step 1 — Identify
Identify a suspected security violation.
Step 2 — Report
Report the concern through the approved channel.
Step 3 — Preserve
Protect relevant evidence and prevent evidence loss.
Step 4 — Contain
Take immediate security measures where required.
Step 5 — Investigate
Establish the facts.
Step 6 — Assess
Determine severity, intent, impact, and risk.
Step 7 — Decide
Determine the appropriate response.
Step 8 — Act
Implement disciplinary, security, corrective, or other actions.
Step 9 — Record
Document the decision and supporting evidence.
Step 10 — Follow Up
Verify corrective actions and address recurrence.
Step 11 — Improve
Use lessons learned to improve security controls.
6. Step 1 — Identify the Violation
A suspected violation may be identified through:
☐ Employee report
☐ Manager report
☐ Security monitoring
☐ Access review
☐ Security incident
☐ Internal audit
☐ Security review
☐ Phishing simulation
☐ Vulnerability assessment
☐ Investigation
☐ Customer complaint
☐ Supplier notification
☐ Automated security alert
☐ Other authorized source
7. Step 2 — Report the Concern
The person identifying the concern should report it through the appropriate channel.
Possible channels include:
- Security team
- IT service desk
- Manager
- HR
- Incident reporting mechanism
- Compliance function
- Whistleblowing or ethics channel where applicable
The reporting mechanism should be clearly communicated to personnel.
8. Step 3 — Initial Assessment
The receiving function should perform an initial assessment.
Determine:
☐ What happened?
☐ When did it happen?
☐ Who may be involved?
☐ What system is affected?
☐ What information is involved?
☐ Is the activity ongoing?
☐ Is access still available?
☐ Is customer information involved?
☐ Is personal data involved?
☐ Is privileged access involved?
☐ Is immediate containment required?
☐ Is there potential regulatory impact?
9. Step 4 — Immediate Security Containment
Where there is an immediate security risk, security controls may need to be applied before the investigation is complete.
Possible actions:
☐ Disable account
☐ Suspend privileged access
☐ Revoke VPN access
☐ Revoke cloud access
☐ Revoke source-code access
☐ Revoke database access
☐ Rotate credentials
☐ Revoke tokens
☐ Isolate device
☐ Restrict physical access
☐ Preserve logs
☐ Preserve relevant devices
Security containment should be based on risk and authorized procedures.
Security containment is not automatically a disciplinary decision.
10. Step 5 — Preserve Evidence
Where investigation is required:
☐ Relevant logs identified
☐ Authentication records preserved
☐ Access records preserved
☐ Relevant communications preserved
☐ Device information preserved where appropriate
☐ Cloud activity preserved
☐ Source-code activity preserved
☐ Security alerts preserved
☐ Evidence access restricted
☐ Evidence integrity protected
☐ Chain of custody established where appropriate
Evidence should be collected and handled by authorized personnel.
11. Step 6 — Determine Investigation Ownership
Depending on the case, responsibility may be assigned to:
| Function | Typical Responsibility |
|---|---|
| Information Security | Security investigation and risk |
| IT | Technical evidence and access |
| HR | Employee disciplinary process |
| Management | Business decision and escalation |
| Legal | Legal assessment |
| Compliance | Regulatory/compliance implications |
| Internal Audit | Independent assurance where appropriate |
One person should be designated as the case owner.
12. Step 7 — Investigation
The investigation should establish facts rather than assume intent.
Review:
☐ Relevant policies
☐ Procedures
☐ Training records
☐ Access records
☐ System logs
☐ Security alerts
☐ Emails or communications where authorized
☐ Relevant system activity
☐ Previous incidents
☐ Previous warnings where relevant
☐ Employee explanation
☐ Customer or supplier impact
☐ Applicable contractual requirements
13. Step 8 — Interview Relevant Personnel
Where appropriate, authorized personnel may interview:
- Reporting person
- Individual involved
- Manager
- System owner
- Security personnel
- Witnesses
- Relevant third parties
Interview records should be handled confidentially and according to applicable organizational and legal requirements.
14. Step 9 — Determine What Happened
The investigation should determine, where possible:
What?
What activity occurred?
When?
When did it occur?
Where?
Which system, device, application, or location was involved?
Who?
Who performed or authorized the activity?
Why?
What was the stated purpose or reason?
Impact?
What information, systems, customers, or operations were affected?
Intent?
Was the activity:
- Accidental
- Negligent
- Reckless
- Intentional
- Unknown
15. Step 10 — Assess Severity
Classify the matter according to the organization’s approved methodology.
| Severity | Typical Characteristics |
|---|---|
| Low | Limited risk and limited impact |
| Medium | Meaningful security weakness or repeated violation |
| High | Significant security risk or impact |
| Critical | Severe, deliberate, or potentially major impact |
Consider:
☐ Information sensitivity
☐ System criticality
☐ Access level
☐ Customer impact
☐ Personal-data exposure
☐ Financial impact
☐ Regulatory impact
☐ Operational impact
☐ Intent
☐ Duration
☐ Scope
☐ Previous behavior
16. Step 11 — Determine Contributing Factors
The organization should identify why the violation occurred.
Possible factors:
☐ Lack of training
☐ Unclear policy
☐ Inadequate procedure
☐ Poor system design
☐ Excessive permissions
☐ Technical control weakness
☐ Process weakness
☐ Workload pressure
☐ Insufficient management oversight
☐ Human error
☐ Negligence
☐ Deliberate action
This prevents the organization from treating every event as an individual employee problem.
17. Step 12 — Review Training and Awareness
Determine whether the individual:
☐ Received relevant training
☐ Completed required training
☐ Passed required assessment
☐ Received role-specific training
☐ Was informed about policy changes
☐ Had access to the relevant policy
☐ Had previously been informed of the requirement
Training records should be considered as part of the overall evidence.
18. Step 13 — Determine the Appropriate Response
Possible responses include:
☐ No action
☐ Security awareness
☐ Coaching
☐ Additional training
☐ Policy clarification
☐ Increased monitoring
☐ Access restriction
☐ Formal warning
☐ Corrective action
☐ Performance management
☐ Formal disciplinary action
☐ Contractual action
☐ Termination, where lawful and appropriate
☐ Legal escalation
The appropriate response should be determined by authorized personnel under the organization’s HR and legal processes.
19. Step 14 — Immediate Correction
Immediate correction addresses the current problem.
Examples:
- Revoke unauthorized access
- Reset credentials
- Remove unauthorized software
- Recover exposed information
- Correct configuration
- Remove inappropriate access
- Stop unauthorized processing
Immediate correction does not necessarily address the root cause.
20. Step 15 — Corrective Action
Corrective action addresses the reason the violation occurred.
Examples:
- Update procedure
- Improve training
- Implement technical control
- Modify access permissions
- Improve monitoring
- Clarify policy
- Change workflow
- Introduce additional approval
- Improve system design
Correction fixes the immediate problem. Corrective action reduces recurrence.
21. Step 16 — HR Review
Where an employee disciplinary matter is involved, HR should review the case according to the organization’s employment and disciplinary processes.
HR may consider:
- Applicable employment policies
- Previous relevant actions
- Consistency
- Employee response
- Proportionality
- Applicable employment law
- Contractual requirements
Information Security should provide relevant security facts and risk information but should not independently make employment decisions outside its authority.
22. Step 17 — Legal Review
Legal review may be required where there is:
☐ Significant data exposure
☐ Personal-data breach
☐ Regulatory implications
☐ Customer contractual implications
☐ Potential criminal conduct
☐ Employment-law concerns
☐ Litigation risk
☐ Evidence preservation requirements
☐ Cross-border implications
Legal involvement should be based on the organization’s defined escalation criteria.
23. Step 18 — Management Decision
The appropriate authorized decision-maker should approve the response.
Decision
☐ No violation established
☐ Coaching
☐ Training
☐ Corrective action
☐ Access restriction
☐ Formal warning
☐ Formal disciplinary action
☐ Contractual action
☐ Termination process
☐ Legal escalation
☐ Further investigation required
24. Step 19 — Communicate the Decision
Where appropriate, communicate the outcome to relevant parties.
Communication should:
- Be factual
- Be proportionate
- Protect confidentiality
- Avoid unnecessary disclosure
- Explain required actions
- Identify follow-up requirements
The organization should not disclose confidential disciplinary information to unrelated personnel.
25. Step 20 — Access Restoration
If access was temporarily restricted:
☐ Investigation completed
☐ Risk assessed
☐ Approval obtained
☐ Required corrective actions completed
☐ Credentials reset where required
☐ MFA verified
☐ Privileged access reviewed
☐ Access restored only when appropriate
☐ Access scope minimized
☐ Restoration recorded
Access should not automatically be restored merely because the disciplinary case is closed.
26. Step 21 — Case Closure
Before closing the case, verify:
☐ Investigation completed
☐ Findings documented
☐ Evidence retained
☐ Security risks addressed
☐ Corrective actions assigned
☐ Disciplinary decision documented
☐ HR requirements completed
☐ Legal requirements addressed where applicable
☐ Access reviewed
☐ Required notifications completed
☐ Residual risk assessed
☐ Management approval obtained where required
27. Disciplinary Case Record
| Field | Details |
|---|---|
| Case ID | |
| Date Reported | |
| Date Detected | |
| Person/Role | |
| Department | |
| Manager | |
| Violation | |
| Relevant Policy | |
| Systems Affected | |
| Information Affected | |
| Severity | |
| Intent Classification | |
| Investigation Owner | |
| Evidence | |
| Immediate Action | |
| Root Cause | |
| Corrective Action | |
| HR Decision | |
| Legal Review | |
| Access Decision | |
| Final Outcome | |
| Closure Date | |
| Approver |
28. Good-Faith Reporting
Personnel should be encouraged to report security mistakes quickly.
Examples:
- Accidental phishing click
- Wrong-recipient email
- Lost device
- Suspected credential exposure
- Unexpected MFA approval
- Accidental information disclosure
Prompt reporting may significantly reduce impact.
Report early → Contain quickly → Reduce damage
Employees should not be discouraged from reporting genuine mistakes.
29. Non-Retaliation
Personnel who report security concerns in good faith should be protected from retaliation in accordance with applicable organizational policy and law.
This includes reporting:
- Security incidents
- Security weaknesses
- Policy violations
- Suspected misuse
- Privacy concerns
- Control failures
Good-faith reporting does not provide immunity for unrelated misconduct.
30. Repeated Violations
When the same type of violation occurs repeatedly, assess:
☐ Was training effective?
☐ Was the requirement understood?
☐ Was the process practical?
☐ Was the technical control adequate?
☐ Were permissions excessive?
☐ Was management aware?
☐ Was corrective action effective?
☐ Is there a systemic problem?
The organization should address systemic causes rather than relying solely on individual disciplinary action.
31. Privileged User Cases
Additional controls may be required when the person has privileged access.
Immediately consider:
☐ Privileged access review
☐ Temporary access suspension
☐ Credential reset
☐ Session review
☐ Cloud activity review
☐ Database activity review
☐ Source-code activity review
☐ Log preservation
☐ Enhanced monitoring
☐ Management escalation
32. Customer or Personal Data Cases
If customer or personal data may have been exposed:
☐ Identify data
☐ Identify affected individuals/customers
☐ Determine scope
☐ Preserve evidence
☐ Start incident-response process
☐ Perform privacy assessment
☐ Assess contractual requirements
☐ Assess regulatory requirements
☐ Determine notification obligations
☐ Coordinate with Legal/Privacy
Disciplinary action must not replace the required security or privacy incident-response process.
33. Contractor and Third-Party Cases
For third-party personnel:
Report → Contain → Investigate → Notify Supplier → Assess Contract → Correct → Close
Possible actions include:
☐ Suspend access
☐ Notify supplier owner
☐ Request investigation
☐ Request corrective action
☐ Require personnel replacement
☐ Review supplier risk
☐ Apply contractual remedies
☐ Terminate access
☐ Offboard supplier personnel
34. Confidentiality and Record Protection
Disciplinary records may contain sensitive personnel and investigation information.
Protect records through:
☐ Restricted access
☐ Appropriate permissions
☐ Secure storage
☐ Encryption where appropriate
☐ Retention controls
☐ Secure disposal
☐ Access logging where appropriate
Records should only be retained for the period required by applicable organizational, contractual, legal, and regulatory requirements.
35. Case Metrics
Management may monitor aggregated metrics such as:
| Metric | Result |
|---|---|
| Security violations | |
| Confirmed violations | |
| Accidental events | |
| Negligent events | |
| Intentional violations | |
| Repeat violations | |
| Access restrictions | |
| Training-related cases | |
| Corrective actions | |
| Average closure time | |
| Open cases | |
| Overdue cases |
Individual personnel information should not be unnecessarily included in management dashboards.
36. Root Cause and Lessons Learned
After significant cases, determine:
What failed?
Why did it fail?
Was the person adequately trained?
Was the policy clear?
Were technical controls sufficient?
Could the process have prevented the event?
What should change?
37. AWS SaaS Startup Example
Consider a SaaS company using:
- AWS
- GitHub
- Production databases
- Customer data
- Microsoft 365
Scenario
A developer uses another employee’s credentials to access a production database.
Immediate Response
1. Contain
Suspend unauthorized access.
2. Preserve
Preserve AWS, database, identity, and relevant system logs.
3. Investigate
Determine:
- Who accessed the system
- What was accessed
- When it occurred
- Why it occurred
- Whether data was copied or modified
- Whether credentials were shared
- Whether similar activity occurred previously
4. Assess
Determine security, customer, privacy, contractual, and regulatory impact.
5. HR/Legal Review
Coordinate the employment and legal response.
6. Correct
Remove inappropriate access and address the root cause.
7. Close
Document the case and verify corrective actions.
Security Containment → Investigation → Risk Assessment → HR/Legal Review → Decision → Corrective Action → Verification → Closure
38. Startup-Friendly Model
A startup can keep the process simple while maintaining an audit trail.
Security
Identifies and contains security risk.
HR
Manages employee disciplinary processes.
Management
Makes appropriate business decisions.
Legal
Provides legal guidance where required.
IT
Manages technical access and evidence.
Employee
Provides information and cooperates with the process.
The organization should clearly define these responsibilities before an incident occurs.
39. Common Mistakes
Avoid:
- Automatically disciplining employees after every security incident.
- Treating accidental mistakes as intentional misconduct.
- Discouraging employees from reporting incidents.
- Starting disciplinary action without establishing facts.
- Allowing managers to bypass HR processes.
- Failing to preserve evidence.
- Restoring access without risk assessment.
- Ignoring technical root causes.
- Using training as the solution for every security problem.
- Applying inconsistent disciplinary decisions.
- Sharing confidential disciplinary information unnecessarily.
- Failing to document the decision.
- Failing to verify corrective actions.
- Ignoring applicable employment and privacy requirements.
40. Relationship With Other ISMS Documents
| Document | Relationship |
|---|---|
| Information Security Disciplinary Policy | Defines disciplinary principles |
| Information Security Policy | Defines security requirements |
| Security Awareness Policy | Defines awareness requirements |
| Security Awareness Training Procedure | Defines training |
| Employee Security Responsibilities | Defines personnel responsibilities |
| Access Management Procedure | Controls access |
| Incident Response Procedure | Handles security incidents |
| Incident Investigation Procedure | Supports investigation |
| Evidence Preservation Procedure | Protects evidence |
| Corrective Action Tracker | Tracks remediation |
| Employee Offboarding Procedure | Removes access |
| Supplier Security Requirements | Applies to third-party personnel |
| HR Disciplinary Procedure | Governs employee disciplinary actions |
41. ISO 27001 Connection
An information-security disciplinary process supports the organization’s personnel-security and information-security governance arrangements by providing a defined response when security requirements are violated.
It can support areas related to:
- Information-security responsibilities
- Security awareness
- Access control
- Acceptable use
- Incident management
- Protection of information
- Personnel security
- Corrective action
- Continual improvement
The Information Security Disciplinary Process is not itself a universally prescribed ISO 27001 document. The organization should define its process according to its risks, personnel arrangements, applicable controls, contractual requirements, and legal obligations.
The process should also remain aligned with the organization’s formal HR disciplinary procedures.
42. Final Process Checklist
☐ Violation identified
☐ Concern reported
☐ Initial assessment completed
☐ Immediate security risk assessed
☐ Access restricted where required
☐ Evidence preserved
☐ Investigation owner assigned
☐ Relevant policies identified
☐ Training records reviewed
☐ Evidence reviewed
☐ Personnel interviewed where appropriate
☐ Intent assessed
☐ Severity assessed
☐ Impact assessed
☐ Root cause assessed
☐ Corrective action identified
☐ HR review completed where required
☐ Legal review completed where required
☐ Management decision obtained
☐ Decision communicated appropriately
☐ Access restoration assessed
☐ Corrective actions verified
☐ Residual risk assessed
☐ Case documented
☐ Case closed
☐ Lessons learned identified
43. Final Audit Trail
For a significant security violation, the organization should be able to demonstrate:
How was the violation identified?
Who reported it?
What immediate security action was taken?
Was evidence preserved?
Who investigated the matter?
What facts were established?
Was intent considered?
What information or systems were affected?
What risk was identified?
Was the response proportionate?
Were HR and Legal requirements considered?
What corrective action was taken?
Was access appropriately managed?
Was the corrective action verified?
What was learned from the event?
Final Principle
A disciplinary process should protect the organization without creating a culture where employees are afraid to report mistakes. The objective is to establish facts, manage risk, apply fair and proportionate action, and improve the security environment.
Disciplinary Process Lifecycle:
Identify → Report → Preserve → Contain → Investigate → Assess → Decide → Act → Verify → Close → Improve