CP-1: Policy and Procedures

To meet the cp-1: policy and procedures requirement, you must create a documented Continuity Planning (CP) policy and supporting procedures, then disseminate them to the defined stakeholders (typically leaders, system owners, and continuity personnel). Operationalize CP-1 by assigning ownership, setting review cadence, mapping procedures to systems, and retaining evidence that policy and procedures are approved, distributed, and followed. ¹

Key takeaways:

• CP-1 is a documentation-and-dissemination control: auditors will look for approved CP policy, detailed procedures, and proof they reached the right audiences.
• “Evidence of operation” matters as much as the documents: change logs, distribution records, and training/attestations reduce assessment friction.
• The fastest path is a control map: owner, procedures, systems in scope, and recurring artifacts, tracked in one place. ¹

CP-1 sits at the front of the NIST SP 800-53 Contingency Planning family and functions as the “paper trail control” that makes the rest of CP assessable. If you cannot show an approved policy, procedures that implement it, and records proving the documents were disseminated to the right people, you will struggle to defend downstream continuity controls during an assessment. The operational goal is simple: define how your organization manages continuity planning for the system(s) in scope, and make that direction usable by the teams who must execute it.

For a Compliance Officer, CCO, or GRC lead, the quickest win is to treat CP-1 as a control you can fully close with disciplined governance: clear ownership, version control, a defined review and approval workflow, and repeatable evidence capture. This page gives you requirement-level guidance to implement CP-1 without turning it into a months-long documentation project. Where helpful, it also flags common audit hangups (for example, “procedure exists but is not actionable,” or “policy exists but nobody can prove it was distributed”). The aim is assessment-ready continuity documentation that operators can actually follow. ²

CP-1 requirement (plain-English)

CP-1 requires you to develop, document, and disseminate continuity planning policy and procedures to a defined audience. In practice, that means:

• A CP policy that sets management direction (scope, objectives, roles, governance, and minimum expectations).
• Procedures that translate the policy into repeatable steps for the system(s) and teams in scope.
• Proof the policy and procedures were shared with the right stakeholders, and are kept current through a managed lifecycle. ¹

Assessors usually treat CP-1 as a gating item. If CP-1 is weak, they question whether continuity controls are consistently implemented.

Regulatory text

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

Operator meaning: NIST intentionally leaves the audience parameterized, because each organization must define who needs these documents. Your job is to (1) name the recipient groups, (2) produce the policy and procedures, (3) distribute them, and (4) retain evidence that distribution happened and that updates are governed.

A practical way to handle the “{{…}}” placeholder is to define your dissemination list directly in the CP policy (or a referenced standard), such as: executive sponsor, CISO/BCP leadership, system owner, service owner, infrastructure lead, incident response lead, key third parties supporting recovery, and anyone with an on-call role tied to recovery steps.

Who it applies to (entity + operational context)

Entities:

• Federal information systems and programs implementing NIST SP 800-53 controls. ²
• Contractor systems handling federal data, where NIST SP 800-53 is contractually flowed down or used as the governing control baseline. ²

Operational context where CP-1 becomes urgent:

• You provide services that must recover after outages (SaaS, managed services, shared platforms).
• You rely on third parties for hosting, network, backups, call centers, payment processing, or key operational capabilities.
• You have defined RTO/RPO targets, mission-critical systems, or contractually required uptime/continuity commitments (even if those targets are documented outside CP).

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

1) Set scope and ownership (document first, then expand)

• Name the control owner (often BCP/Resilience lead, Security GRC, or IT Risk) and the approver (executive sponsor).
• Define scope: which systems, environments, and business processes the CP policy governs (enterprise-wide policy can work, but it must clearly bind the system(s) in scope).
• Identify procedure owners: the teams who will maintain runbooks (Infrastructure, SRE, AppOps, IAM, Network, Service Desk, DR/Backup administrators).

Deliverable: CP-1 control record with owner, approver, scope statement, and document list.

2) Draft the CP policy (1–2 pages if you want it to be used)

Your CP policy should be short and directive. Include:

• Purpose and scope (what “continuity planning” covers for your organization/system).
• Roles and responsibilities (who maintains plans, who executes recovery, who approves).
• Governance: review/approval, exception process, and where procedures live.
• Requirements: plan maintenance triggers (material system changes, org changes, post-incident lessons learned), testing expectations (you can reference separate documents), and recordkeeping expectations.
• Dissemination: the stakeholder groups who must receive the policy and procedures. ¹

3) Write procedures that are operational (runbook-level, not aspirational)

Procedures should answer: “If X happens, who does what, where, and in what order?” Common procedure sets:

• Plan maintenance procedure (how updates are requested, reviewed, approved, published).
• Communication and escalation procedure (who to page, how to declare an incident/outage).
• Backup/restore procedure references (where runbooks are, prerequisites, access controls).
• System recovery procedures (environment rebuild, configuration restore, dependency validation).
• Third-party coordination procedures (how to engage cloud provider support, MSPs, critical vendors, and what contractual artifacts to reference).

Tip: keep procedures modular. One CP policy can govern many system runbooks.

4) Disseminate, then prove it

Dissemination must be auditable. Choose a mechanism you can evidence:

• GRC tool attestation workflow (policy acknowledgement).
• Controlled document repository with access logs and mandatory-read workflow.
• Ticketed communications to named distribution lists with read receipts or attestation capture.

You must define who received it and when. ¹

5) Map CP-1 to recurring evidence artifacts (make audits boring)

Create a simple mapping so CP-1 stays closed over time:

• Control owner
• Document names and current versions
• System(s) covered
• Dissemination mechanism
• Review cadence and triggers
• Evidence you will collect each cycle (approval record, version history, dissemination record)

This is the fastest way to prevent the most common CP-1 risk factor: missing implementation evidence. ¹

Where Daydream fits naturally: Use Daydream to keep the CP-1 control record, link it to the specific systems and owners, and track recurring evidence artifacts (policy approvals, distribution attestations, and procedure updates) so you are not rebuilding audit support from scratch each assessment.

Required evidence and artifacts to retain (assessment-ready checklist)

Keep these artifacts in a controlled repository and link them to the system boundary:

Policy artifacts

• Approved CP policy (versioned, dated)
• Approval record (signature, workflow approval, or meeting minutes)
• Policy exception register (if you allow exceptions)

Procedure artifacts

• CP procedures / runbooks (versioned)
• Procedure change log (what changed and why)
• References to dependent runbooks (backup, restore, failover, communications)

Dissemination artifacts

• Distribution list definition (roles or named individuals)
• Evidence of dissemination (attestations, email/ticket record, portal acknowledgement)
• Training or tabletop attendance where policy/procedures were reviewed (if used as dissemination support)

Governance artifacts

• Document review schedule or triggers documented in the policy/procedure set
• Control mapping showing owner, scope, and recurring evidence plan ¹

Common exam/audit questions and hangups

Expect these questions:

1. “Who is {{ cp-1_prm_1 }} in your organization?”
   Have a written dissemination list tied to roles, plus named alternates for key roles.

2. “Show me the procedure that implements the policy requirement.”
   Auditors reject policies that say “teams must maintain DR plans” without a procedure for how teams do it.

3. “How do you know people received it?”
   A SharePoint link is not dissemination evidence by itself. Bring acknowledgements or workflow records.

4. “Is this current and used for the system in scope?”
   If the policy is enterprise-level, show the crosswalk: which system(s) it governs and where the system-specific runbooks are stored.

5. “What triggers updates?”
   If you cannot show triggers, updates become arbitrary, and assessors will probe recent changes and incidents.

Frequent implementation mistakes (and how to avoid them)

• Mistake: one generic policy with no system tie-in.
  Fix: add a scope statement listing the system boundary and where the system runbooks live.

• Mistake: procedures are “nice to have” narratives.
  Fix: require procedures to include prerequisites (access, tooling), ordered steps, and verification steps (“service health checks,” “dependency validation”).

• Mistake: dissemination is assumed.
  Fix: implement attestations for in-scope roles. Store exportable evidence.

• Mistake: no owner for procedure maintenance.
  Fix: assign procedure owners by domain (network, app, database) and enforce change control.

• Mistake: evidence exists but is scattered.
  Fix: maintain a single CP-1 evidence index that points to the authoritative locations and most recent artifacts. Tools like Daydream help keep that index current.

Risk implications (why operators care)

CP-1 failures usually show up during real outages as confusion: unclear authority to declare incidents, missing runbooks, and outdated contact paths. From a compliance posture, weak CP-1 creates second-order failures: you cannot convincingly claim your continuity capabilities are governed, repeatable, or maintained. The practical risk is extended recovery time and higher operational impact when systems fail. ²

Practical execution plan (30/60/90-day)

You asked for speed. Use phases with clear deliverables.

First 30 days (establish governance and minimum viable documentation)

• Assign CP-1 owner and approver; define system scope.
• Draft CP policy with dissemination list and update triggers.
• Inventory existing runbooks; identify gaps for critical recovery steps.
• Stand up a controlled repository and versioning for CP documents.
• Decide dissemination method (attestation workflow preferred for evidence).

Days 31–60 (procedures, dissemination, and evidence capture)

• Write or remediate procedures for the top recovery scenarios (by system/service).
• Run a dissemination cycle: publish policy/procedures and collect attestations.
• Create the CP-1 evidence index: policy, procedures, approvals, dissemination proof.
• Add CP-1 mapping to owner + recurring artifacts in your GRC system (or Daydream) so it stays current. ¹

Days 61–90 (operationalize and make it durable)

• Validate procedures through a tabletop or dry-run review (focus on clarity and access prerequisites).
• Close gaps found (missing permissions, stale contacts, unclear failover authority).
• Implement a lightweight change-management trigger so major system changes prompt CP document updates.
• Prepare an assessor-ready packet: one folder or export with the CP-1 evidence set and crosswalk to in-scope systems.

Frequently Asked Questions

Who should be on the dissemination list for CP-1?

Include anyone who approves, maintains, or executes continuity activities for the system in scope: executive sponsor, security/BCP leadership, system owner, and operational teams with recovery duties. Document the roles explicitly to satisfy the “disseminate to {{…}}” requirement. ¹

Can a single enterprise policy satisfy CP-1 for multiple systems?

Yes, if the policy clearly applies to the systems in scope and points to system-specific procedures or runbooks. Auditors will still expect evidence that the relevant operators for each system received the documents.

What counts as acceptable “proof of dissemination”?

Use attestations, controlled-document workflow approvals, or ticketed communications tied to a defined distribution list. Keep artifacts that show the recipient population and the date of dissemination. ¹

How detailed do CP procedures need to be?

Detailed enough that an on-call engineer can execute recovery steps under pressure: ordered actions, prerequisites, and verification steps. If the procedure reads like a policy statement, it is not a procedure.

We have DR runbooks owned by engineering. Do we still need a CP policy?

Yes. CP-1 expects both policy (management direction) and procedures (execution). The policy is where you define governance, roles, dissemination, and maintenance expectations. ¹

How do we keep CP-1 “closed” between audits?

Track a recurring evidence plan: policy review/approval records, procedure change logs, and dissemination attestations for each update cycle. A GRC system, including Daydream, helps by tying those artifacts to control ownership and system scope.

Footnotes

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

2. NIST SP 800-53 Rev. 5