CP-1 opens the Contingency Planning family. Like the first control of every family, it asks for a policy and procedures. Here the subject is how you keep running, and how you recover, when systems fail or are compromised.
The statement asks you to develop, document and share a contingency planning policy and procedures with the roles you define. The policy covers purpose, scope, roles, responsibilities, management commitment, coordination among organizational entities and compliance, and it must be consistent with applicable laws and standards. You designate an official to manage the policy and procedures, and you review and update both at a set frequency and after defined events.
800-53 binds US federal systems and others by contract. For a small or mid size company it is a reference, and a business continuity policy is a routine request in customer reviews.
What it means in practice
NIST's guidance says organization level policy is preferable and can remove the need for system specific policy. It can be part of a general security policy or several documents. Procedures describe how the policy is carried out, and can sit in system plans or separate documents. Events that should prompt an update include assessment or audit findings, incidents or breaches, and changes in law or standards. The guidance also warns that restating the controls does not make a policy.
A workable policy states which systems need recovery objectives, who declares a contingency, who owns the plan and how often it is tested. The detail goes in CP-2.
Evidence to collect
- The approved policy with version and date.
- The procedures, or runbooks that serve as procedures.
- The named policy owner.
- Distribution records.
- The last review record and any event driven updates.
Common gaps
- The policy exists, but no plan or test backs it up.
- No owner is named.
- The last review predates a major architecture change.
- Procedures are out of date after a vendor migration.
How to implement it
Write two pages, link them to CP-2, CP-4 and CP-9, and calendar the review. Add incidents and test failures as update triggers.
Quick check
Does a template policy satisfy CP-1?
Only if it reflects your actual systems, roles and process. Restating controls without tailoring is not enough.
