SI-1: Policy and Procedures

SI-1 sits in the System and Information Integrity (SI) family of NIST SP 800-53 Rev. 5 and functions as the “governance wrapper” for the rest of your SI controls. In practice, teams often implement malware protection, vulnerability scanning, and monitoring tools, but fail audits because they cannot show a coherent policy basis, defined procedures, and consistent dissemination to the people who operate those tools.

For a Compliance Officer, CCO, or GRC lead, SI-1 is straightforward but easy to under-scope. The requirement is not satisfied by a generic information security policy alone, nor by a wiki page that lacks approvals, ownership, and distribution. You need a policy that sets direction and accountability for SI topics, plus procedures that instruct operators how to execute key activities (for example, alert triage, flaw remediation intake, and integrity checks). Then you must prove those documents are current, communicated, and reflected in daily work.

This page gives requirement-level guidance you can apply immediately: who should own SI-1, what documents to produce, what artifacts to retain, and the audit questions that commonly expose gaps.

Requirement: SI-1 policy and procedures (what it is)

SI-1 requires you to develop, document, and disseminate an SI policy and supporting procedures to a defined audience. The control is foundational: it makes your SI program assessable by tying operational security integrity activities to written direction, consistent execution, and reviewable evidence. ¹

Plain-English interpretation

You must be able to hand an assessor:

1. an approved SI policy,
2. a set of SI procedures people can follow, and
3. proof you distributed these to the right groups and that they drive actual operations.

If any one of those three pieces is missing, SI-1 becomes a finding even if your tools are strong.

Who it applies to

SI-1 applies broadly wherever you use NIST SP 800-53 as your control baseline, including:

• Federal information systems, and
• Contractor systems handling federal data. ¹

Operationally, SI-1 matters most in environments where:

• security operations and IT operations are split across teams,
• third parties perform monitoring, scanning, or managed detection and response,
• multiple business units run different tool stacks,
• you need consistent handling of integrity events (malware detections, file integrity alerts, vulnerability findings, suspicious code changes).

Regulatory text

Excerpt: “Develop, document, and disseminate to {{ insert: param, si-1_prm_1 }}:” ²

Operator meaning (what you must do)

• Develop: Create an SI policy and SI procedures that match your environment and the SI controls you claim to implement.
• Document: Put them in controlled form (versioning, approvals, effective dates) so an auditor can verify currency and authority.
• Disseminate: Distribute them to the defined audience (typically security, IT operations, system owners, incident responders, and relevant third parties). Keep proof of distribution and access.

The placeholder parameter in the excerpt indicates NIST expects you to specify the target audience for dissemination in your implementation. Your job is to define that audience explicitly and keep it consistent across policy, procedures, and roles.

What you actually need to do (step-by-step)

Step 1: Name an SI-1 control owner and define the audience

Create a short SI-1 RACI that identifies:

• Control owner (often Security Governance / GRC or Security Operations leadership)
• Procedure owners (SOC lead, Vulnerability Management lead, Endpoint lead, System owners)
• Approvers (CISO or delegated security authority)
• Audience for dissemination (roles and groups, not just “all employees”)

Practical tip: include third parties in scope where they perform SI functions (managed SOC, MSP, vulnerability scanning provider). SI-1 dissemination must reach the people who execute the work.

Step 2: Write an SI policy that sets minimum expectations

Your SI policy should be short and directive. Include:

• Purpose and scope (systems, data types, and organizational boundaries)
• Roles/responsibilities (system owners vs SOC vs IT ops)
• Required SI capabilities at a policy level (monitoring, alert handling, flaw remediation intake, malware defense, integrity checks)
• Governance mechanics: review cadence trigger (event-driven and periodic), exception process, and enforcement

Avoid tool names in the policy unless required. Put tool-specific steps in procedures.

Step 3: Build procedures that mirror real workflows

Create procedures that map to the SI activities you perform. Common procedure “sets” that satisfy SI-1 expectations in practice:

• Alert triage and escalation procedure (who monitors, triage steps, severity mapping, escalation paths)
• Malware protection operations procedure (deployment baseline, signature/engine update handling, quarantine actions)
• Vulnerability/flaw remediation intake procedure (how findings enter your backlog, prioritization rules, ownership assignment)
• Integrity verification procedure (file integrity monitoring, log integrity, build artifact integrity, configuration drift checks)
• False positive handling procedure (documentation, tuning approvals)

Keep procedures operational: inputs, steps, outputs, and required records.

Step 4: Map SI-1 to owners, procedures, and recurring evidence artifacts

This is the fastest way to make SI-1 auditable. Create a one-page mapping table:

SI-1 element	Owner	Procedure link	Evidence produced	Storage location
SI policy	GRC/Security Gov	SI Policy	Approved policy PDF, version history	GRC repository
SI procedures	Respective ops leads	SI Procedures set	SOP documents, runbooks	Knowledge base
Dissemination	GRC + HR/IT	Distribution process	Attestation, LMS completion, access logs	LMS/GRC tool
Review/update	Control owner	Review workflow	Review ticket, approvals, change log	Ticketing/GRC

NIST-aligned best practice: explicitly map SI-1 to “control owner, implementation procedure, and recurring evidence artifacts.” ²

If you use Daydream, this mapping becomes a living requirement page: owner assignment, procedure references, and an evidence checklist you can schedule and track, so SI-1 does not degrade between audits.

Step 5: Disseminate, then prove it

Dissemination must be more than “posted on SharePoint.” Use at least one controlled distribution mechanism:

• policy acknowledgment workflow (LMS or HRIS),
• ticketed distribution to role-based groups,
• access-controlled repository with access logs,
• onboarding checklist that assigns SI policy/procedure review for relevant roles.

Capture proof: who received it, when, and how you know they had access.

Step 6: Operationalize updates and exceptions

Set a change workflow:

• what triggers updates (tool changes, incident learnings, org changes),
• who can propose changes,
• required approvals,
• how you retire old versions.

Add an exception process for cases where a system cannot meet the procedure (with compensating controls and an expiry date).

Required evidence and artifacts to retain

Maintain an “SI-1 evidence folder” with:

• Approved SI policy (versioned, dated, owner, approver)
• SI procedures/runbooks (versioned and dated)
• Dissemination evidence (LMS exports, acknowledgment logs, distribution emails with recipient groups, repository access logs)
• Review/maintenance records (review tickets, meeting minutes, approvals, change log)
• Role assignments (RACI, org chart snippet, or control responsibility matrix)
• Crosswalk/mapping document tying SI-1 to procedures and artifacts (the table above)

Retention duration should follow your organization’s policy and contract/regulatory obligations; SI-1 expects demonstrable continuity, so keep prior versions and approval trails.

Common exam/audit questions and hangups

Assessors commonly ask:

• “Show me the SI policy and the last approval.”
• “Which procedures implement the SI policy requirements?”
• “Who received the policy? Prove dissemination to operators, not just leadership.”
• “Show evidence these procedures are executed (tickets, reports, logs, meeting notes).”
• “How do you keep documents current after tool or org changes?”

Hangups that cause findings:

• policy exists, procedures don’t;
• procedures exist, but no approvals/version control;
• dissemination is assumed, not evidenced;
• procedures don’t match actual practice (operators do something else).

Frequent implementation mistakes (and how to avoid them)

1. Generic policy with no SI scope. Fix: add explicit SI domains (monitoring, malware, flaw remediation, integrity verification) and accountable roles.
2. Procedures buried in tribal knowledge. Fix: publish runbooks in a controlled repository and require updates through a ticketed workflow.
3. No dissemination proof. Fix: require acknowledgment for in-scope roles and store exports as evidence.
4. Tool screenshots as “procedures.” Fix: procedures must be step-by-step instructions with decision points, not UI tours.
5. No mapping from requirement to artifacts. Fix: maintain a single mapping table and keep it updated as tools and teams change.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page focuses on assessment and operational risk.

Risk implications if SI-1 is weak:

• Your SI controls become “non-auditable.” A mature SOC can still fail an assessment if governance artifacts are missing.
• In incidents, lack of written procedures increases response variance: inconsistent triage, unclear escalation, poor recordkeeping.
• Third-party execution risk increases when providers operate without your documented expectations and you cannot prove you communicated them.

Practical 30/60/90-day execution plan

First 30 days (stabilize and publish)

• Assign SI-1 control owner and approver.
• Define dissemination audience by role (include third parties where applicable).
• Draft SI policy with scope, responsibilities, and governance mechanics.
• Inventory existing SI runbooks/procedures; identify gaps that block auditability.
• Create the SI-1 mapping table (owner → procedure → evidence).

Days 31–60 (operationalize procedures and evidence)

• Write or refresh top-priority SI procedures that match your actual workflows.
• Implement version control and approval workflow for policy/procedures.
• Stand up dissemination mechanism (LMS acknowledgment or ticketed distribution).
• Start collecting recurring evidence (sample tickets, reports, triage records) tied to each procedure.

Days 61–90 (test, tighten, and make it repeatable)

• Run a tabletop review: pick a recent SI event (malware alert or vuln finding) and trace it through your procedures and evidence.
• Fix mismatches between “paper process” and real execution.
• Add maintenance triggers (tool change, org change, incident postmortem) to your document review workflow.
• In Daydream (or your GRC system), schedule recurring evidence tasks and assign them to owners so SI-1 stays current between audits.

Frequently Asked Questions

Does a single corporate information security policy satisfy SI-1?

Usually not by itself. SI-1 expects SI-specific direction and procedures that operators follow, plus proof of dissemination and maintenance tied to system and information integrity activities. ³

Who should be the SI-1 owner: GRC or Security Operations?

Either can own it, but split ownership often fails. A common pattern is GRC owns the control and document governance, while SOC/Vuln Management/IT Ops own the procedures and evidence production.

What counts as “dissemination” in an audit?

Dissemination means you can prove the intended audience received or had controlled access to the policy/procedures. LMS acknowledgments, access logs, or documented distribution to role-based groups work better than “it’s on a shared drive.” ²

How detailed do SI procedures need to be?

Detailed enough that another qualified operator could execute them consistently: required inputs, decision points, escalation criteria, and required records. If the procedure depends on a tool, include tool-specific steps in an appendix or linked runbook.

How do we handle third parties who run our monitoring tools?

Treat them as in-scope for dissemination and evidence. Your SI procedures should specify interfaces (SLAs, escalation paths, reporting), and you should retain proof the third party received the procedures and follows them (for example, tickets and monthly reports aligned to your runbook).

What is the simplest way to keep SI-1 from becoming stale?

Tie SI document updates to real change triggers (new tools, incident learnings, org changes) and require a ticket for each change with approval and version history. Then schedule recurring evidence collection tasks so you always have fresh proof of operation.

Footnotes

1. NIST SP 800-53 Rev. 5; NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5 OSCAL JSON

3. NIST SP 800-53 Rev. 5