SC-1: Policy and Procedures

SC-1 is one of the fastest controls to “check the box” and one of the easiest to fail in an assessment. Teams often have a security policy, maybe even a standards library, but they cannot show (1) that it covers the SC family in a concrete way, (2) that procedures exist and are used, and (3) that staff know where to find them and when to follow them.

For federal systems and contractors handling federal data, SC-1 matters because it connects your written governance to your technical reality. If your encryption, boundary protections, network segmentation, and secure communications controls exist only as configurations, assessors still expect to see the management intent and the operating playbooks that keep those configurations correct over time.

This page gives requirement-level implementation guidance you can operationalize quickly: who needs to own SC-1, what to write, how to publish it, what evidence to retain, and what examiners typically challenge. Where possible, it also gives reusable artifacts (control cards, evidence bundles, and health checks) so you can run SC-1 like an actual control instead of a document exercise.

Regulatory text

Requirement excerpt: “Develop, document, and disseminate to {{ insert: param, sc-1_prm_1 }}:” ¹

How to read this as an operator:
SC-1 requires you to (1) create written policy and procedures for the System and Communications Protection (SC) family, (2) keep them documented and under change control, and (3) distribute them to the people who must follow them. The parameter placeholder in the excerpt represents the intended audience (typically the roles involved in implementing and operating SC controls). Your job is to define that audience explicitly in your policy and prove dissemination.

Reference: SC-1 appears in the NIST SP 800-53 Rev. 5 control catalog and broader framework materials ².

Plain-English interpretation (what SC-1 really expects)

You need two layers of governance for SC controls:

1. Policy (management intent): What the organization requires for secure system communications and protections, who is accountable, and what triggers updates.
2. Procedures (runbooks): Step-by-step instructions that engineers and operators follow to implement and maintain SC controls consistently.

Assessors look for a clean line from policy → procedures → evidence of operation. If you cannot show that line, SC-family controls can be judged “not implemented” or “not operating as intended,” even when tooling exists.

Who it applies to

Entity types (common scoping):

• Federal information systems
• Contractor systems handling federal data ¹

Operational contexts where SC-1 becomes high-friction:

• Multi-team environments (network, cloud platform, app teams) where SC responsibilities are split.
• Hybrid environments (on-prem + cloud) with inconsistent boundary and encryption patterns.
• Heavy third party dependencies (CDN, SaaS, managed network/security providers) where SC protections are partly outsourced but accountability stays with you.

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

Use this sequence to get to an auditable state fast.

1) Define scope and ownership for the SC family

• Name the system(s) and environment(s) the SC policy covers (production, staging, corporate, etc.).
• Assign a single SC-1 control owner (accountable for governance) and list operator owners (network, platform, SOC, IAM, app security) for execution steps.
• Identify the “dissemination audience”: engineering, security operations, network/cloud ops, and any third party operators who perform SC-related work under contract.

Deliverable: SC-1 control record (owner, in-scope systems, audiences).

2) Write the SC policy (1–3 pages, decision-oriented)

Your SC policy should include:

• Purpose and scope
• Roles and responsibilities (RACI works well)
• Policy statements for the SC family (encryption expectations, boundary protections, secure admin access, segmentation, approved protocols)
• Exceptions process (who can approve, how long an exception lasts, required compensating controls)
• Review and update triggers (major architecture changes, new external connectivity, incident learnings, significant third party changes)
• Distribution method (where it is published; how staff are notified)

Avoid vague text that cannot be tested. A policy statement should be provable (by configuration, ticketing records, diagrams, or monitoring outputs).

Deliverable: Approved “System and Communications Protection (SC) Policy.”

3) Write procedures that match how work really happens

Pick the SC procedures that matter in your environment. Common ones:

• Secure network boundary change procedure (firewall/security group changes, approvals, testing)
• Encryption configuration procedure (data in transit requirements, certificate management)
• Remote administrative access procedure (bastion/jump host, MFA, session logging)
• Segmentation procedure (what must be isolated, how exceptions are handled)
• Third party connectivity onboarding procedure (VPN/peering/API connectivity, monitoring, offboarding)

Procedures should be runnable by a new on-call engineer. Use “if/then” decision points and include references to tooling (ticket types, CI/CD paths, Terraform modules, cloud accounts).

Deliverable: SC procedures/runbooks in your controlled document repository.

4) Create a “requirement control card” for SC-1

Turn SC-1 into an operating control, not a PDF. Include:

• Control objective
• Control owner and delegates
• Trigger events (new system, network change, major third party connection, incident)
• Execution steps (review, update, approve, publish, notify)
• Exception rules (who approves, where recorded) This directly aligns with a proven best-practice approach for making requirements executable ¹.

Deliverable: SC-1 control card (one page).

5) Define the minimum evidence bundle (what you will show an auditor)

Decide now what “good evidence” looks like, per cycle:

• Inputs: change requests, architecture changes, risk assessments, incident learnings
• Approvals: policy owner approval, security leadership approval, system owner acknowledgment
• Outputs: final policy/procedure versions, version history, change log
• Dissemination: publication location, all-staff or targeted notifications, training acknowledgments if used This “minimum evidence bundle” approach is a recommended best practice for avoiding evidence gaps ¹.

Deliverable: Evidence checklist + storage location (GRC tool, ticketing system, doc repository).

6) Implement recurring control health checks

Health checks prove the control operates over time:

• Verify documents are current, approved, and accessible
• Verify procedures still match tooling (cloud console paths change; CI/CD pipelines change)
• Sample recent SC-relevant changes and confirm the procedure was followed (tickets, approvals, testing notes) Track findings to closure with owners and due dates; this is a recommended best practice for sustained operation evidence ¹.

Deliverable: SC-1 health check log + remediation tracker.

Required evidence and artifacts to retain

Keep evidence in a single “SC-1 binder” folder (digital is fine) with consistent naming.

Core artifacts

• SC policy (current) with version number and effective date
• SC procedures/runbooks (current) with owners
• Approval records (signatures, meeting minutes, GRC workflow approvals)
• Change log (what changed, why, who approved)
• Dissemination evidence (wiki publication record, email/announcement, ticket broadcast, training assignment if used)
• Exception register entries related to SC policy deviations (with approvals and expiry)
• Health check records and remediation closure evidence

Operational corroboration (high value in audits)

• Sampled tickets showing the procedure was followed for boundary or encryption changes
• Architecture/network diagrams referenced by the procedures
• Third party connectivity onboarding/offboarding records where they touch SC scope

Common exam/audit questions and hangups

Expect these, and pre-answer them in your binder:

1. “Show me the SC policy and the procedures that implement it.”
   Hangup: policy exists, procedures don’t—or procedures exist but are tribal knowledge.

2. “Who received this policy? How do you know?”
   Hangup: the document is on a wiki, but there is no evidence of dissemination or acknowledgment.

3. “When was it last reviewed, and what triggered the update?”
   Hangup: a “reviewed annually” statement with no proof of an actual review.

4. “Show me evidence the procedures were followed.”
   Hangup: procedures are generic and not tied to tickets, pipelines, or approvals.

5. “How do you handle exceptions?”
   Hangup: exceptions are granted in Slack with no expiration, no compensating controls, and no central register.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Writing one enterprise security policy and calling it SC-1.
  Fix: Write an SC-specific policy section or standalone policy that clearly addresses SC scope and maps to SC controls.

• Mistake: Procedures that describe principles, not actions.
  Fix: Add exact workflow steps (ticket type, approver, testing, rollout, rollback, evidence saved).

• Mistake: No named owners.
  Fix: Put a single accountable owner on SC-1 plus procedure owners; auditors look for accountability.

• Mistake: Dissemination = “it’s in SharePoint.”
  Fix: Capture a distribution event (announcement, ticket broadcast, required read receipt, or onboarding checklist entry) and retain it.

• Mistake: Documents updated, but systems drift.
  Fix: Tie SC-1 health checks to real sampling of SC-relevant changes and config evidence.

Enforcement context and risk implications

No public enforcement cases were provided in the source material for this requirement, so this page does not list enforcement actions.

Operationally, SC-1 failures still create tangible risk: when secure communications controls drift, you get inconsistent encryption, brittle network boundaries, undocumented third party connections, and emergency changes that bypass review. In assessments, SC-1 gaps often expand testing because assessors cannot rely on governance artifacts to understand how SC controls are supposed to work.

Practical 30/60/90-day execution plan

Use phases rather than date promises. Move faster if you already have a document control process.

First 30 days (Immediate stabilization)

• Assign SC-1 owner and procedure owners; confirm in-scope systems.
• Draft SC policy and the top procedures tied to your riskiest pathways (external connectivity, admin access, encryption in transit).
• Publish to a controlled repository with versioning.
• Create the SC-1 control card and evidence bundle checklist.

Days 31–60 (Make it auditable)

• Run a tabletop walkthrough: take one recent boundary change and one encryption/certificate change; validate the procedure matches reality.
• Add missing steps (approvals, testing, monitoring, rollback) and lock the updated versions.
• Stand up the exception workflow and central exception register entries for any current deviations.
• Start a simple health check log (who checked what, what was found, what was fixed).

Days 61–90 (Prove operating effectiveness)

• Sample multiple SC-relevant changes across teams and store the evidence with the SC-1 binder.
• Track remediation items to closure with due dates and owner sign-off.
• Confirm dissemination: add SC policy/procedures to onboarding and role-based training checklists.
• If you use Daydream, operationalize SC-1 as a control card with a predefined evidence bundle and recurring health checks so audits pull from one place instead of rework across teams.

Frequently Asked Questions

What counts as “disseminate” for SC-1?

Disseminate means the people who must follow the SC policy and procedures can access them and you can prove you communicated them. A controlled wiki plus an announcement record or onboarding checklist entry is common evidence.

Do we need a standalone SC policy, or can it be a section in the main security policy?

Either works if the SC content is explicit, scoped to systems, and backed by procedures. Auditors will challenge generic policy language that doesn’t map cleanly to SC operations.

How do we prove procedures are followed without creating extra bureaucracy?

Use existing operational exhaust: change tickets, pull requests, CI/CD logs, approvals, and monitoring outputs. Update procedures to reference those systems so evidence is produced as a byproduct of normal work.

Who should own SC-1: Security, IT, or Engineering?

Put ownership where you can enforce document control and cross-team workflow. Commonly the security governance/GRC function owns SC-1, with engineering/network teams owning the procedures and providing operating evidence.

What should we do about third parties that operate parts of our network or security tooling?

Keep accountability internal, and document how the third party’s work follows your SC procedures (or an approved equivalent). Retain third party change records, approvals, and offboarding steps as part of the evidence bundle.

How often do we need to review SC-1 policy and procedures?

Set a review cadence you can meet and add event-based triggers (architecture changes, incidents, major third party connectivity changes). Auditors care more about proof of real review and updates than a specific interval.

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