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NIST SP 800-171 CUI Protection Center

03.15.01 — Policy and Procedures

Read the official CUI requirement and assessment content, then use the separately labeled Bare Metal Cyber perspective to connect it to implementation, evidence, and sustained operation.

1Parameters
17Source controls
6Assessment objectives
2Assessment methods

03.15 — Planning · NIST SP 800-171 Revision 3

Active
Official NIST requirement content

Security requirement

  1. a.Develop, document, and disseminate to organizational personnel or roles the policies and procedures needed to satisfy the security requirements for the protection of CUI.
  2. b.Review and update policies and procedures [Organization-defined: frequency].
Official NIST discussion

Discussion

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.

Official organization-defined parameters

Tailoring decisions required

Resolve these values through the governing organization’s approved tailoring and risk-management process before declaring the requirement implemented.

frequencyorganization-defined frequencythe frequency at which the policies and procedures for satisfying security requirements are reviewed and updated is defined.
Bare Metal Cyber interpretation

Implementation perspective

Treat Policy and Procedures as a CUI protection outcome that must be reflected in the system boundary, documented implementation, operational behavior, and assessment evidence. Pay particular attention to accurate plans, architecture, rules of behavior, system boundaries, and lifecycle alignment for CUI protection.

  1. Confirm the requirement is in scope for the CUI system components, services, users, and external connections being assessed.
  2. Resolve every organization-defined parameter through an approved governance and tailoring process.
  3. Map each clause of the requirement to an accountable owner, implementation mechanism, and evidence source.
  4. Verify that inherited and shared implementations are supported by current provider evidence and responsibility boundaries.
  5. Collect evidence during normal operation and review changes, exceptions, and deficiencies on a risk-based cadence.

Questions to ask

  • Which CUI assets, data flows, users, and services are protected by this requirement?
  • Which portions are implemented locally, inherited, shared, or not applicable, and what evidence supports that determination?
  • Do the system security plan, deployed configuration, operating process, and assessment evidence tell the same story?
  • What change, incident, or threshold should trigger reassessment?

Evidence and validation

  • system security plans
  • architecture and data-flow diagrams
  • rules-of-behavior acknowledgments
  • plan review and approval records

Common failure patterns

  • plans copied from templates without system specificity
  • diagrams that do not match deployed services
  • inherited protection claimed without provider evidence
  • plans updated only before assessment
Official NIST SP 800-171A content

Assessment objectives and methods

Assessment objectives (6)
  1. a.

    policies needed to satisfy the security requirements for the protection of CUI are developed and documented.

  2. a.

    policies needed to satisfy the security requirements for the protection of CUI are disseminated to organizational personnel or roles.

  3. a.

    procedures needed to satisfy the security requirements for the protection of CUI are developed and documented.

  4. a.

    procedures needed to satisfy the security requirements for the protection of CUI are disseminated to organizational personnel or roles.

  5. b.

    policies and procedures are reviewed [Organization-defined: frequency].

  6. b.

    policies and procedures are updated [Organization-defined: frequency].

Examine

  • security policies and procedures associated with the protection of CUI
  • audit findings
  • system security plan
  • other relevant documents or records

Interview

  • personnel with information security responsibilities
Official source-control relationships

Source NIST SP 800-53 controls

These controls are referenced by the official SP 800-171 Rev. 3 OSCAL record. Open the corresponding control pages for complete control text, enhancements, D3FEND mappings, and related learning.

Source record

Authoritative sources