IR-1: Policy and Procedures

IR-1 sits at the front of the NIST SP 800-53 Incident Response (IR) control family. It is also one of the most frequently underestimated controls because it looks like a simple policy requirement. In practice, assessors use IR-1 as a credibility test: if your policy and procedures are vague, unowned, outdated, or not distributed to the people who must execute them, the rest of your incident response program becomes harder to defend.

For a Compliance Officer, CCO, or GRC lead, the goal is speed with correctness: establish a policy that defines scope, roles, and governance, then lock in procedures that translate that policy into operational steps (triage, escalation, communications, evidence handling, lessons learned). You also need to prove dissemination, not just authorship.

This page focuses on requirement-level implementation guidance for the ir-1: policy and procedures requirement using NIST SP 800-53 Rev. 5 as the authoritative source. It is written to help you assign ownership, produce the minimum viable document set, and create evidence that will survive an audit or assessment. ¹

Regulatory text

Control excerpt (IR-1): “Develop, document, and disseminate to {{ insert: param, ir-1_prm_1 }}:” ²

What the operator must do with this text

IR-1 requires three outcomes, each testable:

1. Develop: You must create an incident response policy and related procedures that match your environment (systems, data types, operating model, and threat profile).
2. Document: The policy and procedures must be written, versioned, approved, and controlled (so the organization can show what was in effect at a given time).
3. Disseminate: You must distribute them to the intended audience (the parameter placeholder indicates the recipients are defined by your organization’s control parameters), and you must be able to prove that distribution happened and remained current. ²

A practical reading: IR-1 fails when the documents exist but aren’t actionable, aren’t controlled, or aren’t in the hands of responders and decision-makers.

Plain-English interpretation (what IR-1 really demands)

You need a written incident response “constitution” (policy) plus “playbooks” (procedures) that teams can follow under pressure. The policy answers: who is responsible, what counts as an incident, what must happen, and who has authority. The procedures answer: how it happens, step-by-step, with tools, checklists, and decision points.

Assessors will look for alignment between:

• Policy statements (requirements and governance)
• Procedures (operational steps)
• Evidence (records showing the procedures were followed or can be followed on demand)

Who it applies to (entity and operational context)

IR-1 applies wherever you claim alignment with NIST SP 800-53 Rev. 5, and it is commonly expected for:

• Federal information systems and the organizations operating them
• Contractor systems handling federal data (including service providers operating systems on behalf of federal customers, or processing federal data in their environments) ¹

Operationally, IR-1 touches multiple functions, even if Security “owns” incident response:

• Security operations / IR lead
• IT operations (endpoint, network, identity)
• Legal and privacy (breach analysis, notifications)
• Communications (internal/external comms)
• HR (insider events, employee actions)
• Third-party management (incidents involving third parties)
• Business continuity / crisis management (if integrated)

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

Step 1: Define the IR-1 “parameter” recipients (your dissemination scope)

The control text expects you to define to whom the policy and procedures are disseminated. Convert that into a named distribution list by role, not by person:

• Incident Response Team members (primary and backup)
• SOC/monitoring analysts
• IT on-call and infrastructure leads
• Legal/privacy point of contact
• Executive incident sponsor (often CIO/CISO/COO)
• Communications lead
• Product/application owners for in-scope systems
• Third-party liaison for supplier incidents

Artifact to create: IR-1 Dissemination Matrix (Role → Document(s) → Delivery method → Frequency/trigger → Evidence source).

Step 2: Draft the Incident Response Policy (one doc, controlled and approvable)

Minimum content that holds up in an assessment:

• Purpose, scope, and definitions (what is an “incident” in your environment)
• Roles and responsibilities (RACI-style is fine)
• Severity classification and escalation authority
• Reporting requirements and timelines (state internal expectations even if law-driven timelines vary)
• Evidence handling expectations (chain of custody conceptually, who can collect/retain)
• Third-party incident handling expectations (who engages the third party; how you coordinate)
• Governance: approvals, exceptions, review cadence, and where the canonical version lives

Operator tip: Keep the policy stable; put volatile details (tool steps, screenshots, contacts) in procedures.

Step 3: Build procedures that match how your teams work

Procedures should be modular. Most teams need, at minimum:

• Intake & triage procedure (ticket creation, initial validation, who pages whom)
• Severity scoring procedure (clear criteria, decision log requirement)
• Containment procedure (identity actions, endpoint/network containment, who approves disruptive actions)
• Eradication & recovery procedure (restore steps, validation, return-to-service gates)
• Communications procedure (internal comms templates, executive updates, external statements approval path)
• Third-party incident coordination procedure (evidence requests, contractual notice path, shared timelines)
• Post-incident review procedure (lessons learned, corrective actions, control updates)

Make procedures executable:

• Preconditions (required access/tools)
• Step-by-step actions
• Decision points (if/then)
• Required records (what must be captured in the case/ticket)
• Outputs (e.g., incident report, root cause summary, action items)

Step 4: Assign control ownership and an evidence cadence

IR-1 fails in audits because nobody owns the artifacts end-to-end. Assign:

• Control owner: accountable for IR-1 being complete, current, and evidenced (often GRC or Security Governance)
• Document owners: policy owner and each procedure owner
• Approver(s): CISO/CTO/CIO, plus Legal/Privacy as needed
• Evidence owner: who pulls proof of dissemination and version control during audits

This is where Daydream fits naturally: map IR-1 to a named control owner, link each procedure to its evidence artifacts, and schedule recurring evidence collection so you are not scrambling during an assessment.

Step 5: Disseminate and prove it

Pick dissemination methods that generate records:

• Policy portal with acknowledgment workflow
• LMS assignment for required IR training that includes policy/procedure references
• Read-only controlled document repository with access logs
• Email distribution to a role-based group with retention (use sparingly; hard to keep current)

Minimum proof expectation: show the current version, who received it (by role), and that updates trigger re-dissemination.

Step 6: Operationalize updates (change control for IR documentation)

Define triggers that require policy/procedure review:

• Major incident or near miss
• Material system changes (new identity provider, new logging platform, new critical third party)
• Organizational changes (new on-call model, new legal counsel, M&A)

Maintain a simple change log: version, date, summary of change, approver.

Required evidence and artifacts to retain (audit-ready set)

Use this as your “IR-1 evidence binder” checklist:

Artifact	What it proves	Owner
Incident Response Policy (versioned, approved)	“Develop” + “Document”	Policy owner
IR Procedures (versioned)	Repeatable execution steps exist	Procedure owners
Approval records (sign-off, ticket, or e-sign)	Governance and authority	Control owner
Dissemination Matrix (roles → docs)	Defined recipients for distribution	Control owner
Dissemination evidence (ack logs, LMS completions, portal attestations)	“Disseminate” happened	Evidence owner
Document control log (version history)	Currency and traceability	Document owner
Crosswalk/control map (IR-1 → artifacts → owners → evidence)	Assessment readiness	GRC

Common exam/audit questions and hangups

Expect these questions:

1. “Who is the audience for IR policy and procedures?” If you can’t name roles, dissemination is untestable.
2. “Show me evidence people received the latest version.” A PDF in a shared drive rarely satisfies this alone.
3. “How do procedures reflect your actual tooling and org chart?” Generic templates without local fit raise follow-up testing.
4. “What happens when a third party is involved in the incident?” Many programs omit supplier coordination steps.
5. “How do you keep it current?” Assessors want a defined review trigger and proof of updates.

Frequent implementation mistakes (and how to avoid them)

Mistake 1: Writing a policy that reads like a textbook

Fix: Make the policy a governance document: authority, roles, scope, escalation, and required records.

Mistake 2: Procedures with no decision points

Fix: Add explicit gates: “If severity is high, notify Legal within internal escalation expectations,” plus required documentation steps.

Mistake 3: No proof of dissemination

Fix: Use a dissemination mechanism with logs (policy acknowledgment, LMS assignment, or controlled portal attestations).

Mistake 4: Unowned documents that decay

Fix: Put owners in the header of each document, and assign a control owner accountable for the set.

Mistake 5: Missing evidence mapping

Fix: Create a one-page IR-1 control map tying each requirement element to the exact artifact and evidence source. This is the fastest “audit friction reducer.”

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite enforcement outcomes. Practically, IR-1 gaps increase the chance that incident handling becomes inconsistent, delayed, or poorly documented, which can cascade into contractual noncompliance, missed customer notice obligations, and failed assessments against NIST-aligned requirements. ¹

Practical 30/60/90-day execution plan

First 30 days (get to a defensible baseline)

• Assign IR-1 control owner, policy owner, and procedure owners.
• Define the dissemination audience by role and build the IR-1 Dissemination Matrix.
• Publish a first-pass IR Policy with approval workflow and version control.
• Inventory existing playbooks/runbooks and decide which become formal IR procedures.

Days 31–60 (make it executable and evidenced)

• Convert runbooks into formal procedures with decision points and required records.
• Implement a dissemination method that produces audit logs (acknowledgments or LMS).
• Create the IR-1 control map: IR-1 → artifacts → owners → evidence → location.
• Run a tabletop or walkthrough to validate procedures match reality; log action items for document updates.

Days 61–90 (make it durable)

• Close gaps identified in the walkthrough and publish updated versions with change logs.
• Establish a standing review trigger process (post-incident and major change).
• Test evidence collection: pull dissemination logs and approvals as if an auditor asked today.
• Optional but high value: centralize all IR-1 artifacts and recurring evidence tasks in Daydream so the program stays current without calendar-chasing.

Frequently Asked Questions

Do I need separate documents for “policy” and “procedures” to satisfy IR-1?

You need both policy intent and operational procedures. They can live in one controlled document set, but keep policy content stable and procedures detailed enough for responders to follow.

What counts as “dissemination” for IR-1?

Dissemination means targeted distribution to the defined roles plus proof. A controlled portal with acknowledgments or LMS assignment is easier to evidence than a static shared drive.

Our incident response is mostly handled by an MSP/SOC third party. How does IR-1 apply?

You still need your own policy, your escalation/authority model, and procedures for coordination with the third party. Your evidence should include how the third party receives and follows your procedures, plus how you govern updates.

How detailed do IR procedures need to be?

Detailed enough that a trained on-call engineer can execute them under time pressure: steps, decision points, required records, and who approves disruptive actions. Keep tool screenshots in appendices or linked runbooks if they change often.

Who should approve the IR policy?

Approval should come from the executive responsible for security risk (often the CISO or equivalent) and any required stakeholders such as Legal/Privacy based on your operating model. The key is documented authority and traceable sign-off.

What’s the most common audit failure for IR-1?

Teams can’t prove dissemination of the current version, or they can’t show ownership and version control. Fix it with a dissemination matrix, logged acknowledgments, and a simple control map that points to evidence.

Footnotes

1. NIST SP 800-53 Rev. 5

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