Identify, regularly review and document requirements for confidentiality or non-disclosure agreements reflecting the organisation's needs.
Also written as A6.6, Annex A 6.6, ISO 27001:2022 A.6.6, ISO27001 A.6.6.
Confidentiality or non-disclosure agreements is one of 8 People Controls in ISO/IEC 27001:2022 Annex A. Identify, regularly review and document requirements for confidentiality or non-disclosure agreements reflecting the organisation's needs. People controls are tested against HR records, so the evidence usually lives outside the security team — joiner/mover/leaver files, training completions, and signed acknowledgements need to reconcile with your current headcount.
When preparing your Statement of Applicability (SoA) for A.6.6, gather artefacts such as:
If you run more than one framework, the same evidence usually satisfies all of them. A.6.6 aligns with:
SOC 2: CC1.1 Integrity and ethical values, C1.1 Identification and protection of confidential information
NIST CSF 2.0: GV.OC-03 Legal, regulatory and contractual requirements, GV.SC-05 Supply chain requirements in contracts
A.6.6 consolidates the following ISO 27001:2013 control(s): A.13.2.4. If you are transitioning an existing ISMS, map your prior evidence for these to A.6.6 in your updated SoA.
Annex A controls are not mandatory in the abstract. Clause 6.1.3 requires you to compare your risk treatment plan against Annex A and justify, in the Statement of Applicability, any control you exclude. If your risk assessment surfaces a risk that A.6.6 addresses, excluding it needs a documented, risk-based rationale that an auditor will test.
In two passes. First design: does a documented control exist, is it owned, and does it address the risk? Then operating effectiveness: the auditor samples records from across the audit period to confirm the control actually ran. A Stage 2 audit will typically pull several samples, so evidence that only exists for the month before the audit is a common finding.
ISO 27001 sets no fixed interval — it requires review at "planned intervals" and after significant change. Annual review is the norm most certification bodies expect, with an out-of-cycle review triggered by incidents, major system changes, restructures, or new regulatory obligations. Record the review date and outcome either way; an undated control is treated as unreviewed.
A.6.6 aligns with SOC 2 CC1.1, C1.1 and NIST CSF GV.OC-03, GV.SC-05. Evidence gathered for one framework will usually satisfy the others, which is the basis for a test-once, satisfy-many control library.
A.6.6 consolidates 1 control(s) from the 2013 edition: A.13.2.4. When transitioning, re-point the existing evidence rather than rebuilding it — the underlying requirement has not changed materially.