AU-1 Audit and Accountability Policy and Procedures (L) (M) (H)

NIST 800-53 (r4) Control:

The organization:

a. Develops, documents, and disseminates to [Assignment: organization-defined personnel or roles]:

1. An audit and accountability policy that addresses purpose, scope, roles, responsibilities, management commitment, coordination among organizational entities, and compliance; and

2. Procedures to facilitate the implementation of the audit and accountability policy and associated audit and accountability controls; and

b. Reviews and updates the current:

1. Audit and accountability policy [FedRAMP Assignment: (L)(M) at least every 3 years; (H) at least annually]; and

2. Audit and accountability procedures [FedRAMP Assignment: (L)(M) at least annually; (H) at least annually or whenever a significant change occurs].

NIST 800-53 (r4) Supplemental Guidance:

This control addresses the establishment of policy and procedures for the effective implementation of selected security controls and control enhancements in the AU family. Policy and procedures reflect applicable federal laws, Executive Orders, directives, regulations, policies, standards, and guidance. Security program policies and procedures at the organization level may make the need for system-specific policies and procedures unnecessary. The policy can be included as part of the general information security policy for organizations or conversely, can be represented by multiple policies reflecting the complex nature of certain organizations. The procedures can be established for the security program in general and for particular information systems, if needed. The organizational risk management strategy is a key factor in establishing policy and procedures. Related control: PM-9.

References: NIST Special Publications 800-12, 800-100.

NIST 800-53 (r5) Discussion:

Audit and accountability policy and procedures address the controls in the AU 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 audit and accountability 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 audit and accountability 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.

38North Guidance:

Meets Minimum Requirement:

• Develop, document, and disseminate AU policies and procedures.

• AU policies and procedures must address:

  • • All AU controls contained within the AU family including all guidelines and processes for the system.

    • Policy must include: purpose, scope, roles, responsibilities, management commitment, coordination among organizational entities, and compliance.

    • Review, approve and update (when a review indicates updates are required) documented AU policies and procedures at least annually or if there is a major change in the environment.

Best Practice:

• TBD

Unofficial FedRAMP Guidance:

• TBD

Assessment Evidence:

• The most recent AU policies and procedures for the system. The policies and procedures should identify the most recent version, identify the last update that occurred, and the last approval date with identification of the approver.

CSP Implementation Tips:

• Amazon Web Services (AWS): TBD

• Microsoft Azure: TBD

• Google Cloud Platform: TBD