The Policy Nobody Could Find
An auditor asked for the incident response plan. Three people remembered it existed. Nobody knew where it was. After an hour of searching, someone found a draft from two years ago in a departed employee's Google Drive. The auditor was not impressed.
Security documentation is the foundation of demonstrable compliance. You can have great security practices, but if you can't prove them, you fail audits, lose deals, and struggle during incidents.
This guide shows you how to build and maintain security documentation that satisfies auditors, supports operations, and doesn't become shelfware.
Why Documentation Matters
For Auditors
- Evidence of Intent — Policies show you've thought about security
- Consistency — Procedures ensure repeatable processes
- Accountability — Clear ownership and responsibilities
- Audit Trail — Evidence that policies are followed
For Operations
- Onboarding — New employees know what's expected
- Incident Response — Know what to do when something happens
- Decision Making — Clear guidelines reduce ambiguity
- Continuity — Knowledge doesn't walk out when people leave
If your security lead is on vacation and an incident occurs, can your team respond effectively? If not, you have a documentation problem. Good documentation enables action without the author present.
The Essential Security Documents
Tier 1: Required for Basic Compliance
Tier 2: Important for Mature Programs
- Risk Management Policy — How you identify and manage risks
- Vendor Management Policy — How you assess and manage vendors
- Change Management Policy — How changes are approved and deployed
- Encryption Policy — Encryption requirements and key management
- Password Policy — Authentication requirements
- Physical Security Policy — If you have physical locations
Tier 3: Operational Procedures
- Onboarding/Offboarding Procedures — Access provisioning steps
- Vulnerability Management Procedures — How vulns are tracked and fixed
- Backup and Recovery Procedures — Detailed recovery steps
- Incident Response Procedures — Specific response playbooks
- Access Review Procedures — How access reviews are conducted
Policies state WHAT and WHY: "All employees must use MFA." Procedures explain HOW: "To enable MFA, go to Settings, select Security, click Enable MFA..." Both are needed. Policies without procedures are unactionable. Procedures without policies lack authority.
Writing Effective Documentation
Structure Template
- Purpose — Why does this document exist?
- Scope — Who/what does it apply to?
- Roles and Responsibilities — Who's accountable for what?
- Policy Statements — The actual requirements
- Procedures — How to implement (or link to separate doc)
- Exceptions — How to request and approve exceptions
- Review and Maintenance — When is this document updated?
Writing Tips
Do:
- Write for your audience (not auditors)
- Be specific and actionable
- Use clear, simple language
- Include examples where helpful
- Define terms people might not know
- Keep it as short as possible
Don't:
- Copy enterprise templates verbatim
- Include aspirational requirements you don't follow
- Use vague language ("appropriate," "reasonable")
- Make it longer than necessary
- Promise things you can't deliver
- Forget to update when things change
A 3-page policy that people read and follow beats a 30-page policy that sits in a folder. Write for comprehension, not comprehensiveness. If your policy requires a lawyer to understand, it won't be followed.
Managing Documentation
Version Control
- Version Numbers — Track versions (v1.0, v1.1, v2.0)
- Change History — What changed and when
- Approval Records — Who approved each version
- Effective Dates — When the version became active
Review Cycles
- Annual Review — All policies reviewed at least annually
- Trigger-Based Review — After incidents, org changes, or new requirements
- Ownership — Each document has an owner responsible for updates
- Review Evidence — Document that reviews occurred (even if no changes)
Storage and Access
- Central Repository — One place for all documentation
- Easy to Find — Searchable, well-organized
- Access Control — Right people can access, edit as appropriate
- Backup — Documentation is backed up like other critical data
Evidence Collection
Documentation alone isn't enough—you need evidence that policies are followed:
- Policy Acknowledgments — Signed/electronic acknowledgment from employees
- Training Records — Completion records for security training
- Access Review Records — Evidence of quarterly access reviews
- Change Records — Tickets/approvals for system changes
- Incident Records — Documentation of incident response
- Meeting Minutes — Security review meetings, decisions made
Common Documentation Mistakes
Mistake 1: Aspirational Documentation
Your policy says you do quarterly penetration tests. You've never done one. Auditors check. Don't document what you wish you did—document what you actually do.
Mistake 2: Copy/Paste Templates
Enterprise templates mention technologies you don't use, processes you don't have, and requirements that don't apply. Customize templates to your actual environment.
Mistake 3: Write Once, Never Update
Your policy from 2019 references the firewall you decommissioned in 2021. Out-of-date documentation is worse than no documentation—it creates false confidence and audit findings.
Mistake 4: Documentation as Shelfware
If nobody reads your policies, they serve no operational purpose. Documentation should be referenced, not just created for auditors.
Quick Start: Your First Week
Day 1: Inventory Existing Docs
What documentation exists today? Where is it? When was it last updated?
Day 2: Identify Gaps
Compare to the essential list. What's missing? What's outdated?
Day 3-4: Prioritize
Information Security Policy and Incident Response Plan first. Then build out.
Day 5-6: Draft Priority Docs
Write or update your top 2-3 priority documents. Keep them short and practical.
Day 7: Organize
Set up your documentation repository. Create a structure. Plan review cycles.
Next Steps
Security documentation isn't about creating binders that impress auditors. It's about capturing how your organization actually handles security—so people can follow it, auditors can verify it, and the knowledge doesn't leave when people do.
Start with the essentials. Write for your actual audience. Keep it current. A living set of practical documents beats a comprehensive library of shelfware.
Building your documentation? vCISO Lite includes policy templates, version tracking, and review reminders—so your documentation stays current and audit-ready without constant manual effort.