NIST SP 800-53 Rev. 5 CP-1 — Policy And Procedures

What this control requires

Develop, document, and disseminate contingency planning policies/procedures, defining roles, responsibilities, and compliance. Assign oversight officials and review regularly for relevance. This control supports the Governance capability within the Contingency Planning family.

In plain English

Develop, document, and disseminate contingency planning policies/procedures, defining roles, responsibilities, and compliance. In practice, this means you can prove you policy procedures-level controls on a defined cadence.

Why it matters

SP 800-53 is the catalogue every U.S. federal authorisation (FedRAMP, FISMA, CMMC) and most regulated industries point at. A missing control surfaces as a Plan of Action & Milestones (POA&M) item that an Authorizing Official must approve before the Authority To Operate is granted or renewed.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

What an auditor looks for

A 3PAO (FedRAMP) or Independent Assessor (NIST RMF) tests against NIST SP 800-53A assessment procedures. For each control they expect a documented implementation that addresses every assessment objective (Examine, Interview, Test) and an implementation summary in the System Security Plan.

Within Contingency Planning, the assessor will trace your implementation back to the catalogue reference (Control CP-1) and look for objective evidence on the latest two assessment cycles.

How to implement

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Operational checklist

• Policy. Document the trigger, the owner and the cadence.
• Review. Document the trigger, the owner and the cadence.
• Control. Document the trigger, the owner and the cadence.
• Compliance. Document the trigger, the owner and the cadence.
• Contingency. Document the trigger, the owner and the cadence.
• Scope: procedures, management, compliance, review, capability, policy, roles.

Evidence to collect

• Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policy or standard documents the safeguard. Focus: Policy And Procedures.

Common pitfalls

• Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• HIPAA (45 CFR Part 164) 164.308(a)(5)(ii)(B) — Security Awareness, Training, and Tools - Protection from Malicious Software
• NIST SP 800-171 Rev. 3 3.7.1 — Recategorized as NCO.
• BSI C5:2020 SP-01 — Documentation, communication and provision of policies and instructions
• ISO/IEC 27001:2022 A.5.5 — Contact with authorities
• SOC 2 (2017 TSC) CC2.3 — External Communication on Internal Control Matters

Related controls in NIST SP 800-53 Rev. 5

• Control SA-1 — Policy And Procedures
• Control CP-7(2) — Accessibility
• Control CP-7(4) — Preparation For Use
• Control CP-7(6) — Inability To Return To Primary Site
• Control AU-1 — Policy And Procedures
• Control IA-1 — Policy And Procedures

References

• NIST Computer Security Resource Center — NIST SP 800-53 Rev. 5
• Catalogue identifier: Control CP-1

Topics: governance riskpolicy management