SI-1: Policy and Procedures

Quick-reference card

What this control requires

SI-01 requires organizations to develop, document, and disseminate a system and information integrity policy and supporting procedures. The policy must define its purpose, scope, roles, responsibilities, management commitment, coordination among entities, and compliance requirements, and it must align with applicable laws, executive orders, directives, regulations, and organizational guidelines.

Beyond the policy itself, SI-01 also requires you to designate a specific official responsible for managing the development, documentation, dissemination, and ongoing maintenance of both the policy and its procedures. This designated authority ensures accountability doesn’t diffuse across teams or fall through organizational cracks.

The control further mandates that your organization review and update both the policy and procedures at frequencies you define and whenever specific triggering events occur. Triggering events typically include audit findings, security incidents, or changes to applicable regulations. Without a defined review cadence, policies stagnate and lose alignment with the threat landscape and regulatory environment your organization faces today. For broader context on what a comprehensive information security policy should cover, the policy development process under SI-01 provides a natural starting point.

Why it matters

Most organizations treat SI-01 as a checkbox exercise, drafting a system and information integrity policy once and letting it collect dust in a shared drive. That approach creates a compounding problem. When auditors review your security program, they don’t just verify that a policy document exists. They evaluate whether the policy reflects your current operating environment, whether procedures are actionable enough for staff to follow, and whether review cycles demonstrate genuine governance. A stale or generic policy signals weak oversight across the entire System and Information Integrity control family.

The compliance risk is direct. SI-01 sits at the foundation of every SI control. If your policy and procedures don’t address the full scope of requirements, including purpose, coordination, and management commitment, auditors will flag deficiencies that cascade into findings against downstream controls. Organizations pursuing Federal Information Security Modernization Act (FISMA) authorization or operating under federal contracts face real consequences when their policy documentation can’t withstand scrutiny.

Specifically, the risk management strategy your organization defines under PM-09 should inform the depth and rigor of your SI policies. When those two controls aren’t coordinated, the policy either overcommits resources the organization can’t sustain or underspecifies protections that the risk profile demands. That gap shows up during assessments as a misalignment between stated intent and operational reality.

In practice, poorly maintained integrity policies create openings that adversaries and audit failures alike exploit. Common threat vectors tied to policy gaps include:

• Outdated procedures that don’t account for current threat intelligence feeds, leaving integrity monitoring gaps across critical systems
• Undefined roles and responsibilities that delay incident response when system integrity events occur
• Missing review triggers that prevent policies from adapting after audit findings, regulatory changes, or security incidents
• Lack of coordination between security and privacy programs, creating blind spots where integrity controls overlap with privacy requirements
• Procedures that restate control language verbatim without translating requirements into operational steps staff can execute

How to implement

The most common failure with SI-01 isn’t writing a policy. It’s writing one that auditors accept as sufficient. Organizations frequently produce documents that restate NIST SP 800-53 control language without translating requirements into actionable, organization-specific procedures.

For your organization

Start by defining the scope and structure of your system and information integrity policy. The policy should cover all systems within your authorization boundary and address every control in the SI family at a level appropriate to your risk management strategy.

Assign a designated official to own the policy lifecycle. This individual is responsible for development, documentation, dissemination, and review. In practice, this role typically falls to the Chief Information Security Officer (CISO), a senior information security manager, or a compliance program lead. The key requirement is clear accountability, not a specific title.

Draft the policy to address seven required elements: purpose, scope, roles, responsibilities, management commitment, coordination among organizational entities, and compliance with applicable laws and directives. Each element should reflect your organization’s actual operating context rather than generic language copied from the standard.

Develop procedures that translate each policy statement into executable steps. Procedures should specify who performs each action, what tools or systems they use, what evidence they produce, and how exceptions are handled. A procedure that says “monitor system integrity” without naming the monitoring tool, alert thresholds, or escalation path won’t satisfy an auditor.

Establish a review cadence and define triggering events. Common review frequencies range from annual to biennial, but your cadence should align with the pace of change in your regulatory environment. Triggering events should include audit findings, security incidents, significant system changes, and updates to applicable regulations or executive orders.

Document evidence of every review cycle. Maintain version-controlled copies of prior policies, meeting minutes from review sessions, and change logs that show what was updated and why. Auditors look for a living governance process, not just a current-state document.

Common mistakes include letting the policy sit outside the document management system your organization uses for controlled records, failing to disseminate updated procedures to all designated personnel, and treating the policy as a standalone artifact disconnected from the system security plan and privacy plan.

For your vendors

When evaluating a vendor’s SI-01 compliance, you’re assessing whether the vendor has a functioning governance process for system and information integrity, not just whether a policy document exists.

Request the following evidence during assessment:

• A current system and information integrity policy with a visible review date, version number, and designated policy owner
• Procedures that translate the policy into operational steps specific to the vendor’s environment
• Evidence of the most recent policy review cycle, including meeting minutes, change logs, or approval records
• Documentation showing how the vendor disseminates policy updates to designated personnel

Ask these questionnaire questions to probe governance maturity:

• Who is the designated official responsible for managing your system and information integrity policy and procedures?
• What is your defined review frequency for integrity policies, and what events trigger an unscheduled review?
• How do you disseminate updated procedures to all personnel with integrity-related responsibilities?
• Can you provide evidence of your most recent policy review, including what changes were made and why?

Watch for these red flags during vendor assessments:

• Policies with no revision date or a revision date older than the stated review frequency
• Procedures that mirror NIST control language verbatim without organization-specific context
• No designated official identified as the policy owner
• Inability to produce evidence of a completed review cycle
• Policies that don’t reference applicable laws, regulations, or organizational directives relevant to the vendor’s operating environment

Verify that the vendor’s policy and procedures align with what their system security plan and privacy plan describe. Inconsistencies between these documents indicate governance gaps that affect the reliability of every downstream SI control.

Evidence examples

Cross-framework mapping

Related controls

• PM-09 — Risk Management Strategy: Defines the risk management approach that should inform the depth, scope, and rigor of your SI-01 policy and procedures.
• PS-08 — Personnel Sanctions: Establishes consequences for personnel who fail to comply with the integrity policies and procedures that SI-01 requires you to document and disseminate.
• SA-08 — Security and Privacy Engineering Principles: Provides the engineering foundation that your integrity policy should reference when defining how systems are designed to maintain information integrity.
• SI-12 — Information Management and Retention: Governs how the policy documents, review records, and procedural artifacts produced under SI-01 are retained and managed throughout their lifecycle.

Frequently asked questions

What is NIST SP 800-53 SI-01

SI-01 is the NIST SP 800-53 control that requires organizations to develop, document, and disseminate a system and information integrity policy and corresponding procedures. The policy must address purpose, scope, roles, responsibilities, management commitment, coordination among entities, and compliance with applicable laws. Organizations must also designate a specific official to manage the policy lifecycle and establish defined review frequencies and triggering events for updates.

What happens if SI-01 is not implemented

Without SI-01 implementation, your organization lacks the documented governance foundation for every other control in the System and Information Integrity family. Auditors will flag the absence of a designated official, undefined review cadences, and missing dissemination records as findings that cascade across downstream SI controls. The resulting compliance gaps can delay or block authorization decisions under frameworks like FISMA, and they signal to assessors that integrity monitoring, incident handling, and vulnerability management across the SI family may lack consistent operational direction.

How do you audit SI-01

Auditing SI-01 starts with verifying that a system and information integrity policy exists, is current, and has been disseminated to all designated personnel. Assessors then check that the policy addresses all required elements: purpose, scope, roles, responsibilities, management commitment, coordination, and compliance with applicable laws and directives. They review evidence of completed review cycles, including version-controlled change logs and approval records, to confirm the organization follows its defined review frequency and responds to triggering events. The auditor also verifies that a designated official is formally responsible for managing the policy and procedures lifecycle.

How often should system and information integrity policies be reviewed

SI-01 doesn’t prescribe a fixed review frequency. Instead, it requires your organization to define its own review cadence and document the events that trigger unscheduled updates. Common practice ranges from annual to biennial reviews, with triggering events including audit findings, security incidents, and changes to applicable regulations or executive orders. The review frequency you choose should reflect the pace of regulatory change and threat evolution in your operating environment.