AT-1 is the policy control for the Awareness and Training family. It asks you to write down a policy and procedures for security and privacy training, assign an owner, and review them on a schedule.
800-53 binds federal systems and, through contract, others. For everyone else it is a reference, and auditors expect a documented training policy even from small teams.
What it means in practice
The policy must address purpose, scope, roles, responsibilities, management commitment, coordination among organizational entities, and compliance, and be consistent with applicable laws. Procedures explain how training is assigned, tracked and enforced. A designated official manages both, and you review them on a defined frequency and after defined events.
The guidance says the policy can be part of a wider security and privacy policy. Events that should trigger an update include audit findings, incidents or breaches, and legal changes. Restating the controls does not make a policy.
Evidence to collect
- The policy with owner, version, approver and date.
- Procedures: who is assigned what, when, and what happens if they miss it.
- Distribution proof, such as acknowledgments.
- A review record from the last cycle.
Common gaps
- A policy that says training is annual with no tracking behind it.
- No owner named.
- Procedures missing for contractors.
How to implement it
Two pages is plenty. State who must train, on what, how often, and what the consequence of missing it is. Tie it to AT-2 so the policy and the evidence line up.
Quick check
What can trigger an early policy update?
Audit findings, security incidents or breaches, and changes in applicable laws or standards.
Sources
- NIST SP 800-53 Rev 5, AT-1: https://csrc.nist.gov/projects/cprt/catalog#/cprt/framework/version/SP_800_53_5_1_1/home?element=AT-1
- NIST OSCAL catalog of SP 800-53 Rev 5: https://raw.githubusercontent.com/usnistgov/oscal-content/main/nist.gov/SP800-53/rev5/json/NIST_SP-800-53_rev5_catalog.json
