PS-1: Policy and Procedures

PS-1 requires you to create, approve, and distribute a Personnel Security (PS) policy and the procedures that make that policy executable, then keep them current and provable. To operationalize it quickly, assign an owner, write a short policy with mandatory topics, publish role-based procedures, and maintain evidence that people can find, follow, and that you review on a defined cadence. ¹

Key takeaways:

• PS-1 is a documentation-and-dissemination control: policy plus procedures, distributed to defined audiences. ¹
• Auditors look for traceability: named owner, approval, version control, training/acknowledgement, and proof the procedures match actual operations.
• The fastest path is a mapping table: PS-1 → owner → procedure(s) → evidence artifacts → review trigger.

The ps-1: policy and procedures requirement is the foundation for the entire Personnel Security (PS) control family in NIST SP 800-53. If your PS controls are “real” but undocumented, you will still fail assessment readiness because PS-1 expects formal policy and procedures that are disseminated to the right audiences and can be produced on demand. The practical outcome you want is simple: anyone with a role in personnel security (HR, Security, Legal, IT, managers, and relevant third parties) can find the authoritative PS policy, follow step-by-step procedures, and you can prove governance and currency with clean artifacts.

PS-1 is also where teams get stuck. They write a generic HR policy, forget system access steps, or publish a security standard without assigning operational responsibility. Assessors then see “documents exist” but cannot verify that the documents control behavior. Your job as a Compliance Officer, CCO, or GRC lead is to connect policy language to actual workflows: onboarding, background screening (as applicable), access provisioning, role changes, offboarding, and exception handling.

This page gives requirement-level guidance you can implement immediately: what to write, who must approve it, how to disseminate it, what evidence to keep, and what exam teams typically challenge.

Regulatory text

Excerpt (PS-1): “Develop, document, and disseminate to {{ insert: param, ps-1_prm_1 }}:” ¹

Operator interpretation: PS-1 expects a documented Personnel Security policy and documented Personnel Security procedures, and it expects you to distribute them to the audiences defined by your environment (the “parameter” is organization-specific). Your implementation has to answer three assessor questions:

1. Did you develop and document the PS policy and PS procedures?
2. Did you disseminate them to the right stakeholders?
3. Can you prove this is governed (owned, approved, current) and executed (people follow it)?

NIST publishes the control in the SP 800-53 Rev. 5 catalog and overview materials. ²

Plain-English requirement (what PS-1 means in practice)

You need two layers of documentation:

• Policy: the “what” and “who” at the governance level (scope, responsibilities, minimum requirements, exceptions).
• Procedures: the “how” with steps that teams actually perform (workflows, ticketing, approvals, evidence capture, escalation paths).

Then you must disseminate both so that the people who perform or oversee personnel security can reliably access them (and ideally acknowledge them).

Who it applies to

PS-1 is relevant wherever NIST SP 800-53 is in scope, especially:

• Federal information systems and programs assessed against NIST SP 800-53. ³
• Contractor systems handling federal data, where NIST controls are flowed down contractually or used to support an authorization boundary. ³

Operationally, PS-1 applies to:

• HR and Talent/People Ops
• Information Security and IAM
• IT service desk / provisioning teams
• Legal/Compliance
• Business unit managers (approvals, supervision)
• Third parties involved in hiring, screening, staff augmentation, or managed services, when they touch your workforce lifecycle or system access decisions

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

1) Define the PS-1 dissemination audience (“the parameter”)

PS-1 includes a placeholder for who receives the policy/procedures. Make it explicit in your documentation. Typical audiences include: HR, Security, IT/IAM, hiring managers, and relevant third-party workforce providers.

Deliverable: “Dissemination” section in the policy stating target audiences, plus where documents are published (GRC tool, intranet, document repository).

2) Assign control ownership and governance

Pick a single accountable owner for PS-1 (often Head of Security Governance, HR Risk, or GRC), plus required approvers (Security, HR, Legal). Document:

• Owner
• Approver(s)
• Effective date
• Review triggers (organizational changes, major incidents, audit findings, system boundary changes)

Practical tip: Put this in the first page header so an auditor doesn’t hunt for it.

3) Write a PS policy that is short and testable

Your PS policy should be brief but specific. Include:

• Purpose and scope (which workforce populations: employees, temps, contractors, interns; and which systems/boundaries)
• Roles and responsibilities (HR vs Security vs IT/IAM vs managers)
• Minimum personnel security requirements tied to lifecycle events:
  • pre-hire / onboarding prerequisites (as applicable)
  • access authorization and provisioning rules
  • role change (transfer/promotion) handling
  • termination/offboarding and access revocation expectations
• Exception process (who can approve, how exceptions are logged, expiration, and compensating controls)
• References to supporting procedures and standards

Check: Each policy statement should map to at least one procedure step and at least one evidence artifact.

4) Write procedures that match your workflows (not a textbook)

Create procedures as “runbooks” owned by the teams doing the work. Common PS procedure set:

• Onboarding procedure: identity proofing steps (if applicable), approvals, ticket creation, baseline access roles, and where evidence is stored.
• Access provisioning procedure: IAM request flow, manager approval, least privilege checks, and segregation-of-duties checks if relevant.
• Role change procedure: how you re-certify access on job change; how to remove legacy entitlements.
• Offboarding procedure: triggers (HRIS, manager notice), timelines for disabling accounts (define your internal SLA), device return, and third-party access termination.
• Exception procedure: documentation requirements, risk acceptance authority, and re-approval cadence.

Make procedures auditable: Put “Evidence to retain” as the last step of each procedure.

5) Disseminate and make it findable

Dissemination is not “it exists on someone’s laptop.” Do all of the following:

• Publish in a controlled repository with version history (SharePoint, Confluence with controls, GRC library).
• Notify target audiences (email distribution, HR/IT announcements, security governance forum).
• Train or brief the operators for the procedures (new manager training, service desk training).
• Collect acknowledgements where feasible (policy acknowledgement workflow, training completion record).

6) Create a PS-1 control mapping table (fastest way to stay audit-ready)

Maintain a single table (spreadsheet or GRC control record) with:

• Control: PS-1
• Owner
• Policy link + version
• Procedure links + owners
• Dissemination list
• Evidence list and storage location
• Review date and next review trigger

This directly supports the recommended operational pattern: map PS-1 to control owner, implementation procedure, and recurring evidence artifacts. ¹

7) Establish an operating rhythm (reviews and change control)

PS-1 does not work if documents drift from reality. Tie updates to:

• HRIS/IAM workflow changes
• Major org changes (reorg, acquisition)
• Audit findings and corrective actions
• Incidents involving unauthorized access, delayed offboarding, or insider risk concerns

Use your standard document change process: draft → review → approve → publish → announce → archive prior versions.

Required evidence and artifacts to retain

Keep evidence that proves development, documentation, and dissemination, plus governance:

Policy artifacts

• PS Policy (PDF or controlled page) with version, effective date, owner, approvals
• Document change log / revision history
• Exception template and risk acceptance form (if used)

Procedure artifacts

• PS procedures/runbooks (onboarding, provisioning, role change, offboarding, exceptions)
• RACI or responsibility matrix for PS activities

Dissemination artifacts

• Distribution list(s) or role-based audience definition
• Announcement emails/posts and timestamps
• Training materials and attendance/completion records (where applicable)
• Policy acknowledgement logs (where applicable)

Operational proof (sample-based)

• Tickets for onboarding/offboarding and access changes
• Access approval records
• Offboarding completion checklists
• Evidence storage map (where each record type lives)

Common exam/audit questions and hangups

Expect these questions and prepare the artifacts above:

1. “Who is the control owner and when was the last review?”
   Hangup: policy exists but has no accountable owner or review evidence.

2. “Show me the procedures the service desk follows.”
   Hangup: policy references procedures that don’t exist, or procedures don’t match the actual ticket workflow.

3. “How do you disseminate to managers and third parties?”
   Hangup: dissemination is limited to Security, but managers approve access and third-party staffing firms initiate onboarding.

4. “Prove offboarding happens consistently.”
   Hangup: you show a policy statement but no operational tickets or completion evidence.

Frequent implementation mistakes and how to avoid them

• Mistake: Treating PS-1 as a policy-only control.
  Fix: write procedures with evidence steps; map each policy statement to a workflow.

• Mistake: Over-scoping the policy with vague commitments.
  Fix: keep policy testable. If you can’t prove it, rewrite it.

• Mistake: No dissemination proof.
  Fix: store screenshots/PDFs of announcements, keep training exports, and capture acknowledgements where feasible.

• Mistake: HR and Security disagree on the “system of record.”
  Fix: define authoritative sources (HRIS for employment status; IAM for access state) inside the procedures.

Enforcement context and risk implications

No public enforcement cases were provided in the source material for PS-1. Your risk is still concrete: weak personnel security documentation and dissemination commonly translates into inconsistent onboarding/offboarding, delayed access removal, and brittle audit responses. Assessors typically treat missing PS-1 artifacts as a governance failure that casts doubt on the effectiveness of related PS controls.

Practical 30/60/90-day execution plan

First 30 days (stabilize and make auditable)

• Assign PS-1 owner and approvers; document governance fields in the policy header.
• Draft PS policy with clear scope and responsibilities.
• Publish policy in a controlled repository with versioning.
• Build the PS-1 mapping table (owner → documents → evidence).

Days 31–60 (make procedures real)

• Write or update the core procedures: onboarding, provisioning, role change, offboarding, exception handling.
• Align procedures to current HRIS/IAM/service desk workflows; add “Evidence to retain” steps.
• Run a tabletop walkthrough with HR, IAM, and Service Desk; fix gaps.

Days 61–90 (prove dissemination and operating rhythm)

• Disseminate to defined audiences; capture communication artifacts.
• Train operators and managers who approve access; retain completion evidence.
• Pull a sample of tickets (onboarding/offboarding/access change) and confirm the evidence is consistently captured.
• Set review triggers and schedule a recurring document review in your GRC calendar.

Where Daydream fits naturally: If you manage multiple frameworks or business units, Daydream can store the PS-1 mapping (owner, procedures, evidence) and keep assessment-ready packaging consistent, so you can answer auditor requests with a single control record rather than a scramble across HR, IT, and Security.

Frequently Asked Questions

What counts as “disseminate” for PS-1?

Disseminate means the intended audiences can access the current policy and procedures, and you can prove you communicated them. In practice, publish to a controlled repository and retain announcements, training records, or acknowledgement logs.

Can HR policies satisfy PS-1 on their own?

Sometimes HR policy language can contribute, but PS-1 also expects executable procedures tied to system access and workforce lifecycle steps. If HR policy does not cover IAM provisioning/offboarding workflows, add security and IT procedures.

Do contractors and other third parties need the PS policy?

If third parties participate in onboarding, approve access, administer systems, or provide staff, they are part of the operational context. Include them in the dissemination audience and provide the relevant procedures or contractually required equivalents.

How detailed do PS procedures need to be?

Detailed enough that a new operator could follow them and produce consistent evidence. If your procedure cannot be validated against tickets and system logs, it is too vague.

What’s the minimum evidence to keep for PS-1?

Keep the approved policy, the procedures, and proof of dissemination. Then keep a small set of operational samples (tickets/approvals) to show the procedures are actually used.

How do we handle exceptions without creating audit risk?

Document a formal exception workflow with named approval authority, required justification, and an expiration or review point. Store exceptions in a central register so you can show consistency and closure.

Footnotes

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

2. NIST SP 800-53 Rev. 5; Source: NIST SP 800-53 Rev. 5 OSCAL JSON

3. NIST SP 800-53 Rev. 5