Building a Phishing Resilience Program: An ISO 27001 Guide

Phishing remains a primary entry point for attackers, exploiting human error to bypass technical defences. A generic annual training is not enough. This guide shows you how to build a robust, measurable phishing resilience program using ISO 27001:2022 controls A.6.3 and A.6.4 to create a security aware culture and demonstrate tangible risk reduction.

What’s at stake

A single click on a malicious link can unravel an entire organisation’s security posture. Phishing is not merely an IT inconvenience; it is a critical business risk with cascading consequences that can threaten operational stability, financial health, and customer trust. The immediate impact is often financial, from fraudulent wire transfers to the crippling costs of ransomware recovery. But the damage runs much deeper. A successful phishing attack that leads to a data breach triggers a frantic race against the clock to meet regulatory obligations, such as GDPR’s 72 hour notification window, exposing the business to significant fines and legal action.

Beyond the direct financial and legal penalties, the operational disruption can be catastrophic. Systems become inaccessible, critical business processes grind to a halt, and productivity plummets as teams are diverted to containment and recovery efforts. This internal chaos is mirrored by external reputational damage. Customers lose faith in an organisation that cannot protect their data, partners become wary of interconnected systems, and the brand’s value erodes. Frameworks like ISO 27005 identify this human element as a primary risk source, while regulations like NIS2 and DORA now explicitly mandate robust security training to build resilience. Failing to build a strong human firewall is no longer just a security gap; it is a fundamental failure of governance and risk management.

For example, a small accounting firm employee clicks a phishing link disguised as a client invoice. This installs ransomware, encrypting all client files a week before tax deadlines. The firm faces immediate financial loss from the ransom demand, regulatory fines for the personal data breach, and loses several long term clients who can no longer trust them with sensitive financial information.

What good looks like

A successful phishing resilience program transforms security from a technical silo into a shared organisational responsibility. It cultivates a culture where employees are not the weakest link, but the first line of defence. This state is defined by proactive vigilance, not reactive fear. Success is not measured solely by a low click rate on simulated phishing emails, but by a high and fast report rate. When employees spot something suspicious, their immediate, ingrained reaction is to report it through a clear and simple channel, confident that their action is valued. This behavioural shift is the ultimate goal.

This ideal state is underpinned by the systematic application of ISO 27001:2022 controls. Control A.6.3, covering information security awareness, education, and training, provides the framework for a continuous learning cycle. This is not a one time event but an ongoing program of engaging, relevant, and role specific education. It is complemented by Control A.6.4, the disciplinary process, which provides a formal, fair, and consistent structure for addressing repeated, negligent behaviour. Crucially, this is all driven by leadership commitment, as mandated by Clause 5.1. When executives champion the program and participate visibly, they signal its importance to the entire organisation.

Imagine a marketing agency that runs quarterly phishing simulations. After a junior designer reports a particularly sophisticated test email mimicking a new client request, the security team not only thanks them privately but also publicly praises their diligence in the company wide newsletter. This simple act reinforces positive behaviour, encourages others to be equally vigilant, and turns a routine training exercise into a powerful cultural endorsement of the security program.

Practical path

Building an effective phishing resilience program is a journey of continuous improvement, not a single project with a finish line. It requires a structured, phased approach that moves from foundational planning to ongoing optimisation. By breaking the process down, you can build momentum, demonstrate early wins, and embed security behaviours deeply within your organisation’s culture. This path ensures your program is not just a compliance checkbox but a dynamic defence mechanism that adapts to evolving threats. Each phase builds upon the last, creating a mature, measurable, and sustainable security asset.

Phase 1: Laying the Groundwork (Weeks 1-4)

The first month is dedicated to strategy and planning. Before sending a single simulated phish, you must define what success looks like and secure the necessary support to achieve it. This foundational phase is critical for aligning the program with business objectives and the broader Information Security Management System (ISMS). It involves getting executive buy in, defining clear and measurable goals, and understanding your current vulnerability level. Without this strategic groundwork, any subsequent efforts will lack direction and authority, making it difficult to achieve meaningful change or prove the program’s value over time. Our implementation guide can help structure this initial alignment with your ISMS. Zenith Blueprint¹

• Secure Executive Sponsorship: Gain commitment from top management as required by ISO 27001 Clause 5.1. Present the business case by highlighting the risks of phishing and the tangible benefits of a resilient workforce.
• Define Objectives and KPIs: Establish clear, measurable goals in line with Clause 9.1. Key Performance Indicators should include not just the click rate, but also the report rate, the average time to report, and the number of repeat clicks by individual users.
• Establish a Baseline: Conduct an initial, unannounced phishing simulation before any training. This provides a clear baseline measurement of your organisation’s current susceptibility and helps demonstrate improvement over time.
• Select Your Tools: Choose a phishing simulation and security awareness training platform that fits your organisation’s size, culture, and technical environment. Ensure it provides good analytics and a variety of training content.

Phase 2: Launch and Educate (Weeks 5-12)

With a solid plan in place, the next two months focus on execution and education. This is where you roll out the program to employees, moving from theory to practice. The key to this phase is communication. You must frame the program as a supportive, educational initiative designed to empower employees, not a punitive measure to catch them out. The goal is to build trust and encourage participation. This phase involves delivering the initial wave of training, launching regular simulations, and providing immediate, constructive feedback to help employees learn from their mistakes in a safe environment.

• Communicate the Program: Announce the initiative to all employees. Explain its purpose, what they can expect, and how it will help protect both them and the company. Emphasise that the goal is learning, not punishment.
• Deliver Foundational Training: Assign initial training modules that cover the basics of phishing. Explain what it is, show common examples of malicious emails, and provide clear instructions on the official process for reporting suspicious messages.
• Begin Regular Simulations: Start sending out scheduled phishing simulations. Begin with relatively easy to spot templates and gradually increase the difficulty and sophistication over time.
• Provide Point of Failure Training: For employees who click a simulated phishing link or submit credentials, automatically assign a short, targeted training module that explains the specific red flags they missed. This immediate feedback is highly effective for learning. Our detailed guidance on implementing A.6.3 can help structure this training cycle. Zenith Controls²

Phase 3: Measure, Adapt, and Mature (Ongoing)

Once the program is operational, the focus shifts to continuous improvement. A phishing resilience program is a living system that must adapt to your organisation’s changing risk landscape and the evolving tactics of attackers. This ongoing phase is driven by data. By consistently tracking your KPIs, you can identify trends, pinpoint areas of weakness, and make informed decisions about where to focus your training efforts. Maturing the program means moving beyond universal training to a more risk based approach, integrating it with other security processes, and ensuring accountability is maintained.

• Analyse and Report on KPIs: Regularly review your key metrics. Track the trends in click rates, report rates, and reporting times. Share anonymised results with leadership and the wider organisation to maintain visibility and momentum.
• Segment and Target High Risk Users: Identify individuals or departments that consistently underperform in simulations. Provide them with more intensive, one on one, or specialised training to address their specific knowledge gaps.
• Integrate with Incident Response: Ensure your process for handling reported phishing emails is robust. When an employee reports a potential threat, it should trigger a defined incident response workflow for analysis and remediation. This closes the loop and reinforces the value of reporting.
• Apply the Disciplinary Process: For the small number of users who repeatedly and negligently fail simulations despite targeted training, invoke the formal disciplinary process as outlined in ISO 27001 control A.6.4. This ensures accountability and demonstrates the organisation’s commitment to security.

Policies that make it stick

A successful phishing resilience program cannot exist in a vacuum. It must be formalised and embedded within your ISMS through clear, authoritative policies. Policies provide the mandate for the program, define its scope, and set clear expectations for every member of the organisation. They transform awareness activities from a discretionary “nice to have” into a mandatory, auditable component of your security posture. Without this formal backing, your program lacks the authority needed for consistent application and long term sustainability.

The cornerstone document is the Information Security Awareness and Training Policy.³ This policy should explicitly state the organisation’s commitment to ongoing security education. It must define the objectives of the phishing simulation program, outline the frequency of training and testing, and assign responsibilities for its management and oversight. It serves as the primary source of truth for auditors, regulators, and employees, demonstrating a systematic and planned approach to managing human risk. Furthermore, the Acceptable Use Policy plays a crucial supporting role by establishing the fundamental duty of every user to protect company assets and promptly report any suspicious activity, making vigilance a condition of using company resources.

For instance, during an external ISO 27001 audit, the auditor asks how the organisation ensures that all new hires receive security awareness training. The CISO presents the Information Security Awareness and Training Policy, which clearly mandates that HR must ensure completion of the foundational security module within the first week of employment. This documented, non negotiable requirement provides concrete evidence that the control is implemented effectively and consistently.

Checklists

To ensure your program is comprehensive and effective, it helps to follow a structured approach covering its entire lifecycle. From initial design and rollout to daily operations and periodic verification, using checklists ensures that no critical steps are missed. This systematic method helps maintain consistency, simplifies delegation, and provides a clear audit trail of your activities. The following checklists break down the process into three key stages: building the program, operating it day to day, and verifying its continued effectiveness.

Build Your Phishing Resilience Program

Before you can operate a program, you must build it on a solid foundation. This initial phase involves strategic planning, securing resources, and establishing the governance framework that will guide all future activities. A well planned build phase ensures your program is aligned with business goals, has clear objectives, and is equipped with the right tools and policies from day one.

• Secure executive sponsorship and budget approval.
• Define clear program goals and measurable Key Performance Indicators (KPIs).
• Select and procure a suitable phishing simulation and training platform.
• Develop or update the Information Security Awareness and Training Policy to mandate the program.
• Create a detailed communication plan to introduce the program to all employees.
• Run an initial, unannounced baseline simulation campaign to measure the starting point.
• Define the process for handling reported phishing emails and integrate it with your helpdesk or incident response team.

Operate Your Program

With the foundation in place, the focus shifts to consistent execution. The operational phase is about maintaining the rhythm and momentum of your program through regular, engaging activities. This means continuously testing employees, providing timely feedback, and keeping security top of mind throughout the organisation. Effective operation turns the program from a one time project into an embedded business as usual process.

• Schedule and execute simulation campaigns on a regular basis (e.g., monthly or quarterly).
• Continuously vary the phishing templates, themes, and difficulty levels to avoid predictability.
• Automatically assign immediate, just in time remedial training to users who fall for a simulation.
• Implement a system for providing positive reinforcement and recognition to employees who consistently report simulations.
• Publish anonymised performance metrics and trends to the organisation to foster a sense of shared progress.
• Keep training content fresh and relevant by incorporating information on new and emerging threat trends.

Verify and Improve

A security program that doesn’t evolve is one that will eventually fail. The verification phase is about stepping back to analyse performance, assess effectiveness, and make data driven adjustments. This continuous improvement loop ensures your program remains effective against changing threats and delivers a real return on investment. It involves looking at both quantitative data and qualitative feedback to get a holistic view of your security culture.

• Conduct quarterly reviews of KPI trends with the management team to demonstrate progress and identify areas for improvement.
• Periodically interview a cross section of staff to gauge their qualitative understanding and perception of the program.
• Correlate simulation performance data with real world security incident data to see if the training is reducing actual risk.
• Review and update training content and simulation templates at least annually to reflect the current threat landscape.
• Audit the process to ensure that cases of repeated, negligent failure are being managed in accordance with the formal disciplinary policy.

Common pitfalls

Even with the best intentions, phishing resilience programs can fail to deliver results if they fall into common traps. These pitfalls often stem from a misunderstanding of the program’s purpose, leading to a focus on the wrong metrics or the creation of a negative, counterproductive culture. Avoiding these mistakes is just as important as following best practices. A successful program is not just about the tools you use, but about the philosophy that guides their implementation. Being aware of these potential failures allows you to proactively steer your program toward a culture of empowerment and genuine risk reduction.

• Focusing only on the click rate. This is a vanity metric. A low click rate might simply mean your simulations are too easy or predictable. The report rate is a far better indicator of positive employee engagement and a healthy security culture.
• Creating a culture of fear. If employees are shamed or excessively punished for failing a simulation, they will become afraid to report anything, including real attacks. The primary goal must always be education, not humiliation.
• Infrequent or predictable testing. An annual phishing test is practically useless for building security habits. If simulations are always sent at the same time of the month, employees will learn the schedule, not the security skill. Testing must be frequent and random.
• No consequences for gross negligence. While the program should not be punitive, it must have teeth. For the rare cases where an individual repeatedly and negligently ignores training and clicks on everything, there must be a formal, fair process for accountability, as outlined in ISO 27001 A.6.4.
• Failing to close the loop. When an employee takes the time to report a suspicious email, they deserve a response. A simple “Thank you, this was a test and you did the right thing” or “Thank you, this was a real threat and our team is handling it” reinforces the desired behaviour. Silence breeds apathy.

Next steps

Building a resilient human firewall is a critical component of any modern ISMS. By grounding your phishing resilience program in the principles of ISO 27001, you create a structured, measurable, and defensible strategy for managing your biggest security risk.

• Download our complete ISMS toolkit to get all the templates you need to build your security program from the ground up. Zenith Suite
• Get all the policies, controls, and implementation guidance you need in one comprehensive bundle. Complete SME + Enterprise Combo Pack
• Start your ISO 27001 certification journey with our pack designed specifically for small and medium enterprises. Full SME Pack

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