Policy and Procedures (03.15.01)_policy-and-procedures

Policy and Procedures (03.15.01) Policy and Procedures

High-Level Description

Family: Planning Framework: NIST SP 800-171 Rev 3 Applicability: Systems processing, storing, or transmitting CUI

Develop, document, and disseminate to organizational personnel or roles the policies and procedures needed to satisfy the security requirements for the protection of CUI. Review and update policies and procedures [organization-defined].

What to Check

• Verify Policy and Procedures (03.15.01) Policy and Procedures is implemented for CUI systems
• Review SSP documentation for Policy and Procedures (03.15.01)
• Validate CMMC Level 2 assessment objective for Policy and Procedures (03.15.01)
• Confirm POA&M addresses any gaps for Policy and Procedures (03.15.01)

How to Test

Step 1: Review System Security Plan

Examine the SSP for Policy and Procedures (03.15.01) implementation description and responsible parties.

Step 2: Assess Implementation

# Verify security controls protecting CUI
# Check access controls, encryption, monitoring as applicable

# For Linux systems:
ls -la /etc/security/ 2>/dev/null
grep -r "CUI\|controlled" /etc/security/ 2>/dev/null

# For cloud:
# Use cloud-audit-mcp tools to assess posture

Step 3: CMMC Assessment Validation

Verify this requirement passes CMMC Level 2 assessment methodology per SP 800-171A Rev 3.

Tools

Remediation Guide

Requirement Statement

Develop, document, and disseminate to organizational personnel or roles the policies and procedures needed to satisfy the security requirements for the protection of CUI. Review and update policies and procedures [organization-defined].

Supplemental Guidance

This requirement addresses policies and procedures for the protection of CUI. Policies and procedures contribute to security assurance and should address each family of the CUI security requirements. Policies can be included as part of the organizational security policy or be represented by separate policies that address each family of security requirements. Procedures describe how policies 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 plans or in one or more separate documents.

Risk Assessment

CWE Categories

References

• NIST SP 800-171 Rev 3
• NIST SP 800-171A Rev 3 (Assessment)
• CMMC Model Overview
• NIST OSCAL Content

Checklist

• SSP documents Policy and Procedures (03.15.01) implementation
• Evidence of operating effectiveness collected
• POA&M addresses any gaps
• CMMC assessment objective met
• Continuous monitoring active