Policy and Procedure Management

Why it matters

Outdated or unenforced policies create compliance gaps and leave staff unclear on security expectations, increasing risk of policy violations and audit findings. Without a structured review and acknowledgment process, you cannot demonstrate that policies are current, communicated, or actually being followed—a core requirement for SOC 2 CC5.3 attestation.

Evidence to collect

• Policy registry with version numbers, owner names, approval dates, and next scheduled review dates for at least 5 key policies (e.g., acceptable use, access control, incident response)
• Screenshot of policy acknowledgment records from your HR or GRC system showing employee sign-off dates and policy versions acknowledged
• Email or system notification demonstrating policy distribution to affected staff (e.g., 'New Acceptable Use Policy v3.2 approved 2024-01-15, due for acknowledgment by 2024-02-15')
• Evidence of at least one completed policy review cycle within the past 12 months, including review notes, change log, and approval sign-off

Testing procedure

Request the organization's complete policy registry and verify each policy has a documented owner, approval date, and next review date. Cross-reference a sample of 5 policies with employee acknowledgment records to confirm all affected staff signed off within 30 days of distribution. Re-examine the registry 12 months later to confirm policies flagged for review actually underwent review and were either updated or explicitly re-approved with new sign-off dates. Check audit logs in the GRC system for evidence of overdue review alerts.

Common gotchas