AT-1—Policy and Procedures
>Control Description
Develop, document, and disseminate to ⚙organization-defined personnel or roles: (a) Addresses purpose, scope, roles, responsibilities, management commitment, coordination among organizational entities, and compliance; and (b) Is consistent with applicable laws, executive orders, directives, regulations, policies, standards, and guidelines; and
[Selection (one or more): Organization-level; Mission/business process-level; System-level] awareness and training policy that:
Procedures to facilitate the implementation of the awareness and training policy and the associated awareness and training controls;
Designate an ⚙organization-defined official to manage the development, documentation, and dissemination of the awareness and training policy and procedures; and
Review and update the current awareness and training:
Policy ⚙organization-defined frequency and following ⚙organization-defined events; and
Procedures ⚙organization-defined frequency and following ⚙organization-defined events.
>DoD Impact Level Requirements
FedRAMP Parameter Values
AT-1 (c) (1) [at least annually] AT-1 (c) (2) [at least annually] [significant changes]
>Discussion
Awareness and training policy and procedures address the controls in the AT family that are implemented within systems and organizations. The risk management strategy is an important factor in establishing such policies and procedures. Policies and procedures contribute to security and privacy assurance.
Therefore, it is important that security and privacy programs collaborate on the development of awareness and training policy and procedures. Security and privacy program policies and procedures at the organization level are preferable, in general, and may obviate the need for mission- or system-specific policies and procedures. The policy can be included as part of the general security and privacy policy or be represented by multiple policies that reflect the complex nature of organizations.
Procedures can be established for security and privacy programs, for mission or business processes, and for systems, if needed. Procedures describe how the policies or controls are implemented and can be directed at the individual or role that is the object of the procedure. Procedures can be documented in system security and privacy plans or in one or more separate documents.
Events that may precipitate an update to awareness and training policy and procedures include assessment or audit findings, security incidents or breaches, or changes in applicable laws, executive orders, directives, regulations, policies, standards, and guidelines. Simply restating controls does not constitute an organizational policy or procedure.
>Related Controls
>Assessment Interview Topics
Questions assessors commonly ask
Process & Governance:
- •What formal policies and procedures govern the implementation of AT-1 (Policy And Procedures)?
- •Who are the designated roles responsible for implementing, maintaining, and monitoring AT-1?
- •How frequently is the AT-1 policy reviewed and updated, and what triggers policy changes?
- •What training or awareness programs ensure personnel understand their responsibilities related to AT-1?
Technical Implementation:
- •Describe the specific technical mechanisms or controls used to enforce AT-1 requirements.
- •What automated tools, systems, or technologies are deployed to implement AT-1?
- •How is AT-1 integrated into your system architecture and overall security posture?
- •What configuration settings, parameters, or technical specifications enforce AT-1 requirements?
Evidence & Documentation:
- •What documentation demonstrates the complete implementation of AT-1?
- •What audit logs, records, reports, or monitoring data validate AT-1 compliance?
- •Can you provide evidence of periodic reviews, assessments, or testing of AT-1 effectiveness?
- •What artifacts would you present during a FedRAMP assessment to demonstrate AT-1 compliance?
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