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This is a practical, end-to-end explanation designed for organisations implementing or maintaining an Information Security Management System (ISMS).
Understanding ISO 27001 Annex A 6.1
ISO 27001 Annex A 6.1 focuses on reducing information security risks introduced by people before they are granted access to information or systems. It recognises that employees, contractors, and third parties can pose significant risks if their access is not appropriately assessed, authorised, and monitored from the outset.
Unlike technical controls, Annex A 6.1 addresses human risk — one of the most common sources of data breaches, insider threats, fraud, and accidental misuse of information.
The control requires organisations to perform screening checks that are appropriate to the role, responsibilities, and access level of individuals before they join the organisation or gain access to sensitive information.
Why Employee Screening Matters in Information Security
People are central to information security. Regardless of how strong technical controls are, organisations remain vulnerable if individuals with access:
• misuse their privileges
• act maliciously
• fail to meet integrity expectations
• conceal conflicts of interest
• have undisclosed histories that increase risk
ISO 27001 Annex A 6.1 exists because preventing risk is more effective than reacting to incidents later. Screening helps organisations make informed decisions before granting trust.
From an audit perspective, screening is a preventive control that supports:
• confidentiality of sensitive data
• integrity of systems and processes
• availability of critical services
It also demonstrates organisational maturity, due diligence, and risk-based governance.
What ISO 27001 Annex A 6.1 Requires
Annex A 6.1 does not mandate a single universal screening method. Instead, it requires organisations to:
• define screening requirements
• ensure checks are appropriate to role and risk
• comply with legal and regulatory obligations
• apply screening consistently
• document and retain evidence
The emphasis is on proportionality and risk alignment, not blanket checks for all personnel.
Who Annex A 6.1 Applies To
Employee screening applies to any individual who may access information or information systems, including:
• permanent employees
• temporary staff
• contractors and consultants
• agency workers
• interns
• third-party service providers
If someone can access systems, data, facilities, or processes within the ISMS scope, Annex A 6.1 applies.
Risk-Based Screening: The Core Principle
ISO 27001 requires a risk-based approach, meaning screening depth must align with:
• role criticality
• access level
• data sensitivity
• regulatory exposure
• potential business impact
For example:
A customer support agent accessing basic CRM data may require minimal screening.
A system administrator with privileged access may require extensive checks.
Auditors expect organisations to justify why certain checks are performed for some roles and not others.
Types of Screening Covered by Annex A 6.1
ISO 27001 does not prescribe exact screening checks, but commonly accepted categories include:
Identity Verification
Confirming that an individual is who they claim to be. This often includes:
• government-issued ID checks
• right-to-work verification
• validation of personal details
This establishes a baseline of trust and prevents identity fraud.
Employment History Checks
Verifying previous employment information such as:
• job titles
• employment dates
• reasons for leaving
• reference validation
These checks help identify inconsistencies or misrepresentation that may indicate risk.
Education and Qualification Verification
For roles requiring specific expertise or certifications, organisations may verify:
• academic qualifications
• professional certifications
• licences or memberships
This ensures competence and reduces operational and security risk.
Criminal Record Checks (Where Lawful)
In some jurisdictions and roles, criminal background checks may be appropriate. These must always be:
• legally permissible
• proportionate
• role-specific
• privacy-compliant
ISO 27001 does not require criminal checks by default. Their use must be justified and documented.
Credit or Financial Checks (High-Risk Roles Only)
For roles involving:
• financial authority
• payment systems
• sensitive financial data
Limited financial screening may be used where legally allowed to assess fraud or coercion risk.
Conflict of Interest Declarations
Individuals may be required to disclose:
• external business interests
• relationships with competitors
• secondary employment
This supports transparency and insider threat mitigation.
Legal and Privacy Considerations
A critical aspect of Annex A 6.1 is compliance with employment, privacy, and data protection laws.
Screening must always be:
• lawful
• fair
• transparent
• proportionate
• documented
Organisations must define:
• what data is collected
• why it is collected
• how it is stored
• how long it is retained
• who can access it
Failure to align screening with privacy regulations (such as GDPR) is a common audit and regulatory risk.
Screening Timing: Before and During Employment
Annex A 6.1 applies primarily before employment or access is granted, but organisations may also perform:
• periodic re-screening
• screening on role changes
• screening after extended absences
Auditors expect clarity on when screening occurs and what triggers additional checks.
Documenting the Screening Process
ISO 27001 requires documented information to demonstrate that screening is:
• defined
• implemented
• repeatable
• auditable
Common documentation includes:
• screening policy
• role-based screening matrix
• onboarding procedures
• consent forms
• screening records
Documentation must align with actual practice. Paper compliance without execution is a common nonconformity.
Evidence Auditors Expect for Annex A 6.1
During certification or surveillance audits, auditors typically request:
• employee screening policy
• role-based risk justification
• anonymised screening records
• evidence of consent
• onboarding checklists
• third-party screening agreements
They may also interview HR, security, and managers to verify understanding and implementation.
Common Audit Findings Related to Employee Screening
Organisations often struggle with Annex A 6.1 due to:
• undocumented screening processes
• inconsistent application across roles
• lack of evidence retention
• excessive or unlawful screening
• unclear responsibility ownership
Auditors focus on consistency, proportionality, and governance, not perfection.
Relationship Between Annex A 6.1 and Other ISO 27001 Controls
Employee screening does not exist in isolation. It directly supports:
• Annex A 5.10 (Acceptable Use)
• Annex A 6.4 (Disciplinary Process)
• Annex A 6.6 (Confidentiality and NDAs)
• Annex A 5.16 (Identity Management)
Together, these controls form the people security lifecycle — from hiring to exit.
Screening Contractors and Third Parties
Third parties often represent higher risk due to:
• limited oversight
• shared access
• external employment relationships
ISO 27001 expects organisations to ensure that equivalent screening controls apply to contractors, either directly or contractually.
This may include:
• contractual screening clauses
• supplier attestations
• audit rights
• onboarding verification
Managing Screening Exceptions
There may be cases where screening cannot be completed due to:
• legal restrictions
• time constraints
• jurisdictional limitations
ISO 27001 allows exceptions, but they must be:
• risk-assessed
• approved by management
• documented
• time-limited
Uncontrolled exceptions are a common audit failure.
Maintaining Screening Records Securely
Screening records are sensitive and must be protected under the ISMS. Organisations should define:
• secure storage locations
• access restrictions
• retention periods
• disposal methods
Auditors expect screening data to be protected just like other sensitive information.
Scaling Employee Screening in Growing Organisations
As organisations scale, manual screening processes often break down. Common challenges include:
• inconsistent onboarding
• missed checks
• lack of visibility
• audit stress
Mature organisations integrate screening into:
• HR systems
• access provisioning workflows
• ISMS tooling
• audit evidence repositories
Automation supports consistency and reduces human error.
Best Practices for ISO 27001-Compliant Screening
High-maturity organisations typically:
• define screening tiers by role
• integrate screening with onboarding
• review screening risks annually
• involve HR, Legal, and Security
• maintain clear audit trails
These practices go beyond compliance and strengthen trust across the organisation.
The Business Value of Employee Screening
Beyond certification, effective screening:
• reduces insider threat risk
• supports regulatory compliance
• strengthens customer trust
• protects intellectual property
• prevents costly incidents
Employee screening is not just an ISO requirement — it’s a governance advantage.
Why Annex A 6.1 Is Foundational to ISMS Trust
ISO 27001 Annex A 6.1 sets the foundation for trust within the ISMS. By assessing people before granting access, organisations prevent risks rather than reacting to incidents later.
Screening supports confidentiality, integrity, and availability by ensuring the right people, with the right level of trust, gain the right level of access — at the right time.
Organisations that treat employee screening as a strategic security control, not a checkbox, consistently achieve stronger audit outcomes and lower incident rates.
Book a Demo: Simplify Employee Screening and ISO 27001 Compliance
Managing employee screening, onboarding evidence, and audit readiness manually quickly becomes complex — especially as teams grow and roles change.
Hicomply helps organisations centralise ISO 27001 people controls, including employee screening, role-based access governance, evidence tracking, and audit preparation — all in one platform.
If you want to streamline Annex A 6.1 compliance, reduce audit stress, and maintain consistent screening across your organisation, book a demo with Hicomply today and see how ISMS automation supports secure growth.
