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Have contractors implemented the NIST 800-171 controls? DoD Inspector General (IG) audit suggests not, recommends third-party audits. Are you ready?

A recent audit conducted in response to a request from the Secretary of Defense determined that DoD contractors did not consistently implement DoD‑mandated system security controls for safeguarding Defense information. Specifically, Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.204-7012 requires contractors that maintain Controlled Unclassified Information (CUI) to implement security controls specified in National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171, which lists security requirements for safeguarding sensitive information on non-Federal information systems. The requirements include controls for user authentication, user access, media protection, incident response, vulnerability management, and confidentiality of information.

DoD IG Report Findings

The findings across the DoD contractors audited included deficiencies related to:

  • Multifactor authentication;
  • Enforcing the use of strong passwords;
  • Identifying network and system vulnerabilities;
  • Mitigating network and system vulnerabilities;
  • Protecting CUI stored on removable media;
  • Overseeing network and boundary protection services provided by a third-party company;
  • Documenting and tracking cybersecurity incidents;
  • Configuring user accounts to lock automatically after extended periods and unsuccessful login attempts;
  • Implementing physical security controls;
  • Creating and reviewing system activity reports, and granting system access based on the user’s assigned duties.

The audit also found that while DoD requires contractors to protect CUI by complying with NIST 800-171 requirements, DoD contracting offices did not establish processes to:

  • Verify that contractors’ networks and systems met National Institute of Standards and Technology security requirements before contract award;
  • Notify contractors of the specific CUI category related to the contract requirements;
  • Determine whether contractors’ access, maintain, or develop CUI to meet contractual requirements;
  • Mark documents that contained CUI and notify contractors when CUI was exchanged between DoD agencies and the contractor; and
  • Verify that contractors implemented minimum security controls for protecting CUI.

The effect of these findings is that DoD does not know the amount of DoD information managed by contractors and cannot determine whether contractors are protecting unclassified DoD information from unauthorized disclosure.

The results of the audit probably don’t surprise the DoD or its many contractors but the recommendations in the DoD IG report, combined with the proposed Cybersecurity Model Certification (CMMC), should have contractors making plans to immediately implement the NIST 800-171 security requirements. All signs point to a game-changing, pre-RFP validation of compliance making cybersecurity a “go/no-go” factor for DoD contract awards.

DoD IG Report Recommendations

Recommendations out of the DoD IG report included:

  • Revise its current policy related to assessing a contractor’s ability to protect DoD information to require DoD Component contracting offices, as part of the Request for Proposal and source selection processes, and requiring activities, during the contract performance, to validate, at least annually, that contractors comply with security requirements for protecting CUI before contract award and throughout the contract’s period of performance.
  • Develop and implement a policy requiring DoD Component contracting offices and requiring activities to maintain an accurate accounting of contractors that access, maintain, or develop controlled unclassified information as part of their contractual obligations.
  • Revise its current policy to include language that would require DoD Component contracting offices to validate contractor compliance with minimum security requirements. We also recommend that the DoD Component contracting offices, in coordination with requiring activities, implement a plan to verify that the internal control weaknesses for the contractors discussed in this report are addressed.

All these recommendations are in alignment with the proposed CMMC efforts led by Katie Arrington, and DoD contractors who have delayed NIST 800-171 implementation should take notice and act now. Mandatory third-party validation of security requirements is coming in 2020 and failing to act will likely result in exclusion from contracting with the DoD. Both the recommendations from the DoD IG audit and CMMC are proposing third-party validation of control implementation as part of the Request for Proposal and source selection processes – self-certification and implementation after you win the work are going away. Contractors will need to demonstrate compliance before responding to an RFP and that means taking the necessary steps now before these inevitable changes are implemented in 2020.

Prepare for CMMC and NIST 800-171 Third-Party Verification

CMMC proposes that all companies conducting business with the DoD must be certified. The level of certification required depends upon the Controlled Unclassified Information (CUI) a company handles or processes and the intent of CMMC is to combine various cybersecurity control standards such as NIST SP 800-171 into one unified standard for cybersecurity. Given NIST 800-171 security requirements are at the core of CMMC, and NIST 800-171 implementation has been mandated for nearly two years now, that’s where DoD contractors should focus their efforts. Under CMMC the DoD is building on and strengthening, not abandoning NIST 800-171. Implementing the NIST 800-171 security requirements now is the best way to prepare for CMMC and meet your existing contractual requirements around DFARS 252.204-7012 Safeguarding Covered Defense Information and Cyber Incident Reporting and NIST 800-171.

Implementing the NIST 800-171 requirements includes writing a System Security Plan (SSP) and with 110 security requirements, you can expect to be out of compliance with some number of those individual requirements. For requirements not yet implemented you will need to also document Plans of Action & Milestones (POA&Ms). The heavy lifting is in implementing the security requirements as you prepare for CMMC and controls like Multi-Factor Authentication and Incident Response which require time to fully implement. With 2020 less than six months away implementing all 110 security requirements will be a challenge and DoD contractors, subcontractors and vendors taking a wait and see approach to CMMC are ignoring the last decade of clear warning signs that security has become the foundation of acquisition. The DoD IG audit and recommendations are simply the most recent in a flurry of activity that should have contractors taking immediate action to comply.

5 Steps to CMMC Preparation

Download our 5 Step Guide to CMMC Preparation to plan and enable certification as a documented, automated outcome of day-to-day operations. This easy to follow guide presents a plan to prepare for CMMC in a way that fits your business and budget. Third party certification is coming in 2020, get the compliance and control implementation expertise you need to stay competitive!

5 Steps to CMMC Preparation

NIST 800-171 Revision 2 and 800-171B drafts were released for comment last week, and as expected there have been no major changes proposed to the controls in NIST 800-171 Revision 2. For DoD contractors waiting to implement the required security requirements of NIST 800-171 Revision 1 pending the latest updates, the proposed updates won’t buy you any time. The fact is enforcement is underway and compliance with DoD cybersecurity requirements is a go/no go decision if you are serious about being eligible to do business with the DoD.

The 800-171B draft enhanced security controls are in addition to 800-171 controls, in cases where the information held by the contractor is determined to be a high-value target. The enhanced requirements are to be applied to nonfederal systems and organizations processing, storing, or transmitting controlled unclassified information (CUI), when such information is contained in a critical program or designated high-value asset. The enhanced security requirements of the 800-171B draft were designed to address advanced persistent threats (APTs) and are mapped to the security controls in NIST 800-53. The implied maturity level required and associated costs with implementing the 800-171B draft enhanced security controls is significant.

The enhanced security requirements include three, mutually supportive and reinforcing components:

(1) penetration resistant architecture;

(2) damage limiting operations; and

(3) designing for cyber resiliency and survivability.

The Path Forward for DoD Contractors

With a tremendous amount of activity related to The Cybersecurity Maturity Model Certification (CMMC), DCMA audits of NIST 800-171 compliance, False Claims Act litigation, and the 800-171 revisions and supplements, the path forward for DoD contractors is clear:

Fund and execute compliance with NIST 800-171 now. Despite all of the proposed changes, the fact remains that the DFARS 252.204-7012 clause in ANY of your contracts requires the implementation of NIST 800-171. That is your contractual requirement and all changes proposed so far rely on NIST 800-171 as a foundation of compliance.

There has been a level of paralysis by analysis across industry caused by the questions of cost reimbursement, proposed changes and uneven auditing of compliance. This is the kind of noise that has caused many DoD contractors across the supply chain to delay their DFARS compliance efforts but that high-risk approach invites legal and competitive pain that should be avoided. While there are many changes to be aware of CyberSheath advises focusing on what you are required to do today as the best approach to current and future compliance requirements. Nothing that has been proposed eliminates the requirement to implement NIST 800-171.

Compliance with the DFARS and NIST 800-171 requirements involves much more than writing a System Security Plan (SSP) and vendors selling you a tool to get compliant are misleading you. There are 110 security requirements in NIST 800-171 and you have to actually implement them, there isn’t a single product to solve this problem.

5 Steps To DFARS Compliance

Download our 5 Steps to DFARS Compliance Guide to plan and enable compliance as a documented, automated outcome of day-to-day operations. This easy to follow guide presents a plan you can follow to achieve compliance in a way that fits your business and budget. DoD contractors, subcontractors and vendors taking a wait and see approach before achieving compliance are ignoring the last decade of clear warning signs that security has become the foundation of acquisition. Act now!

5 Steps to DFARS Compliance

 

The recently announced Cybersecurity Maturity Model Certification (CMMC) scheduled for completion by January 2020 has many DoD contractors scrambling to anticipate how to prepare (learn more about the CMMC announcement here). While there are many unknowns regarding what the CMMC will ultimately look like, DoD contractors should focus on what is already known and currently mandatory with DFARS 252.204-7012, which requires the implementation of NIST 800-171. Stop trying to read the tea leaves and doing the bare minimum by writing System Security Plans (SSP’s) and start implementing the 110 security requirements of NIST 800-171. Demonstrable action, that is NIST 800-171 control implementation, is the best way to prepare for the CMMC.

Katie Arrington, the special assistant to the Assistant Secretary of Defense for Acquisition for Cyber in the Office of the Under Secretary of Acquisition and Sustainment in DoD, recently said that only 1% of the Defense Industrial Base has implemented the required controls.  “If we were doing all the necessary security controls, we wouldn’t be getting exfiltrated to the level that we are. We need to level set because a good portion of our defense industrial base doesn’t have robust cyber hygiene. Only 1% of [Defense Industrial Base] companies have implemented all 110 controls from the National Institute of Standards and Technology. We need to get to scale where the vast majority of DIB partners can defend themselves from nation state attacks.”

Why are Contractors Delaying NIST 800-171 Implementation?

Across hundreds of NIST 800-171 implementations, CyberSheath has found the most common reason for delay by DoD contractors has come down to, “Who is going to pay for this?”

Arrington clearly spoke to that concern last week at an event sponsored by the Professional Services Council in Arlington, Virginia, saying “I need you all now to get out your pens and you better write this down and tell your teams: Hear it from Katie Arrington, who got permission to say it from Mr. [Kevin] Fahey [the assistant secretary of Defense for Acquisition in the Office of the Under Secretary of Acquisition and Sustainment] security is an allowable cost. Amen, right?”

After more than a decade of policy, law, memorandums and continued momentum towards enforcement businesses who continue to delay actual implementation of the 110 security requirements will be in a far worse position come January 2020 when the CMMC rolls out. Don’t wait, implement the NIST 800-171 security requirements in a way that is actionable, measurable and audit ready.

Beyond Your SSP’s and POA&Ms

Compliance with the DFARS and NIST requirements involves much more than writing a SSP’s and vendors selling you a tool to get compliant are misleading you. There are 110 security requirements in NIST 800-171 and you have to actually implement them, there isn’t a single product to solve this problem. Implementing security requirements like multifactor authentication, incident response, encryption and more require thoughtful decisions leveraging what you already own. For the gaps identified in your existing people, processes, and technologies a product purchase, if required, needs to be part of the larger plan to achieve compliance. Too often businesses are over-sold on silver bullet product purchases that aren’t thoughtfully integrated into a system of documented and repeatable control implementation.

5 Steps to DFARS Compliance

To enable compliance as a documented, automated outcome of day-to-day operations download our 5 Steps to DFARS Compliance Guide. This easy to follow guide presents a plan you can follow to achieve compliance in a way that fits your business and budget. Act now to move from thinking about implementation to taking action towards full compliance.

5 Steps to DFARS Compliance

 

The window of opportunity for achieving compliance with DFARS 252.204-7012, which requires the implementation of NIST 800-171 across the DoD supply chain, continues to get smaller as the ability to self-certify is set to expire.

CyberSheath attended the Professional Service Council’s 2019 Federal Acquisition Conference where Special Assistant to DoD’s Assistant Secretary of Defense Acquisition for Cyber Katie Arrington stated clearly that “…cost, schedule, and performance cannot be traded for security.” Security is the foundation of defense acquisition.

Much has been written about The Defense Department (DoD) Office of the Under Secretary Acquisition of Sustainment creation of a new certification model to enforce compliance, but the fact is compliance is already required. So, while it is important to understand where the DoD is headed in enforcing compliance, it’s more important to stop delaying and act now. The DoD has been working with industry for more than a decade to address the cybersecurity problem across the supply chain and contractors who continue to self-certify with Plans of Action & Milestones (POA&Ms) that never actually get implemented will be frozen out of acquisition as DoD makes cybersecurity a “go/no-go” part of procurement.

Cybersecurity Maturity Model Certification (CMMC) and the New Certification

The Cybersecurity Maturity Model Certification (CMMC) and the new certification will have required CMMC levels once the certification is released, with levels ranging between one and five –from basic cyber hygiene requirements through “state-of-the-art” cybersecurity capabilities.

Arrington is moving quickly to complete the CMMC by January 2020, and contractors can expect to start seeing the certification in contract requests for information by June 2020.

Within CMMC, a third-party cybersecurity certifier will also conduct audits, collect metrics, and information risk mitigation for the entire supply chain.

“With 70 percent of my data living in your environment, I’m home, so we need to work together to secure it,” Arrington said. “Who is the government? You are when you’re the taxpayer. That’s your money. That’s your data that you have paid for that our adversaries are taking and using it against us. We should be infuriated as a nation about our data. With $600 billion a year being expelled by our adversaries; this room should be irate.”

All of these developments, coupled with the May 8, 2019, California court Civil False Claims Act decision as the first reported FCA decision involving allegations of non-compliance with DFARS 252.204-7012 should spur action towards immediate compliance. Checklist compliance and continued delays of actual control implementation will absolutely cost you more in the long run so get started now, make a plan and execute.

5 Steps To DFARS Compliance

Compliance with the DFARS and NIST requirements involves much more than writing a System Security Plan (SSP) and vendors selling you a tool to get compliant are misleading you. There are 110 security requirements in NIST 800-171 and you have to actually implement them, there isn’t a single product to solve this problem.

Download our 5 Steps to DFARS Compliance Guide to plan and enable compliance as a documented, automated outcome of day-to-day operations. This easy to follow guide presents a plan you can follow to achieve compliance in a way that fits your business and budget. DoD contractors, subcontractors and vendors taking a wait and see approach before achieving compliance are ignoring the last decade of clear warning signs that security has become the foundation of acquisition. Act now!

5 Steps to DFARS Compliance

 

“Those who do not learn from history are condemned to repeat it.”

Over the years, variations of this famous quote have been spoken by everyone from philosophers to world leaders. The message — that we must learn from our mistakes or continue to repeat them — is also highly relevant to cybersecurity.

Both the National Institute of Standards and Technology (NIST) and the SANS Institute describe the learning phase of incident response as one of the most crucial steps, helping businesses to refine and strengthen both their prevention and response protocols.

However, 42% of businesses fail to review and update their incident response plans on a regular basis. If you find yourself experiencing the same security breaches over and over again, you might be one of them. Here’s why you should actively learn from the experience, and how to go about it.

Lessons Learned Session

A lessons learned session takes place after the resolution of a security incident. It involves taking stock of the incident; getting to the root of how and why it happened; evaluating how well your incident response plan worked to resolve the issue; and identifying improvements that need to be made.

Identifying Areas of Weakness

The most obvious benefit of a lessons learned session is that it helps you to identify gaps in your organizational security practices. Was the lapse due to human error? Systems failure? Inadequate security practices? If you don’t know these problems exist, you can’t take the appropriate action to fix them.

Improving Incident Response

Lessons learned sessions help you to understand not only why the incident occurred, but also how effective your response was. For example, were you able to respond quickly and effectively, or did red tape get in the way? Did your team know exactly what to do, or did they struggle to remember their training? Questions like these will highlight areas that need to be improved for next time.

Recognizing the Positive

Don’t just focus on what went wrong in a lessons learned session; it’s also important to highlight what went well. Taking the time to identify successful elements of your response can help to inform robust future security practices while acknowledging and rewarding positive employee performance will set a standard and incentivize similar behaviors in the future.

Lessons Learned Training

Just as frameworks like NIST 800-171 require you to periodically test your Incident Response processes using activities like tabletop exercises, incorporate your lessons learned sessions into these activities as well. Not only will that lead to improvements in your incident response plan, but it will train your teams in how to do effective lessons learned analysis.

The Lessons Learned Process

According to Lessons learned: taking it to the next level, an incident response paper by Rowe and Sykes, lessons learned sessions are most effective when they follow a well-defined five-step process:

  1. Identify and collect all comments and recommendations that may be useful for future projects.
  2. Document all findings and share them with key stakeholders.
  3. Analyze and organize all documentation for future application.
  4. Store documentation in a repository that can be accessed by all key stakeholder.
  5. Retrieve documentation for use on current or future incidents.

This process should be implemented as soon as possible after an incident when the particulars are still fresh in everybody’s minds. In fact, if the incident will take an especially long time to resolve, then beginning the process even sooner might uncover helpful information to support the resolution.

Stakeholders from as many key groups as possible should be present for lessons learned sessions. It’s especially important to have representatives from your IT and executive teams, as the former will be able to implement recommendations and the latter will be able to authorize action and remove bureaucratic obstacles.

We’ve Held a Lessons Learned Session — What Next?

Your lessons learned session will likely turn up numerous security gaps, weaknesses, and other areas that need attention. This is the part that often discourages businesses from lessons learned sessions in the first place — after all, if you go looking for problems to fix, then you must fix them! If you don’t have the time or money to do this, then it’s tempting to skip this step altogether and hope for the best.

With the financial impact of the average data breach running into hundreds of millions, this strategy is only going to cost you more money in the long run. Instead, face the incident head-on and use the lessons learned session as an opportunity to proactively fortify your business against future threats.

Here are some examples of actions you might take to improve your cybersecurity and incident response for next time:

  • If you found that the incident occurred because your staff missed the signs of a threat or were unsure how to respond, then you may invest in more comprehensive and/or frequent training.
  • If bureaucratic layers slowed down your response, you might meet with the C-suite to request executive delegation in future emergency situations, and enshrine this in your incident response plan.
  • If a loophole in one of your systems was exploited, conduct a thorough review of the system to ensure it is fit for purpose and replace if necessary.

Whatever you do, though…

Don’t Let History Repeat Itself

Every incident has a lesson to teach you, but we know that implementing these lessons isn’t always easy. That’s why CyberSheath specializes in providing comprehensive, affordable incident response solutions to businesses like yours. Contact us today to find out how we can help.

 

With the Department of Defense (DoD) promising the release of an update to NIST Special Publication 800-171, it is imperative defense contractors understand what DFARS 252.204-7012 and NIST SP 800-171 Clause is and how noncompliance with the Clause will impact their business.  Compliance is mandatory for contractors doing business with the DoD and the incentives to act now are many and include:

  • Compliance was mandatory as of December 2017; regardless of when you found out about the requirement, it’s been on the books for several years now
  • Noncompliance penalties for failure to meet the requirements can lead to criminal, civil, administrative, or contract penalties that include:
    • Breach of Contract Damages
    • False Claims Act Damages
    • Liquidated Damages
    • Termination for Default
    • Termination for Convenience
    • Poor Past Performance
    • Suspension/Debarment

Ultimately the DoD has been preparing the contractor community for more than a decade and with audits underway there is little doubt that cybersecurity compliance is becoming a competitive discriminator.

Read more about DoD audits of cybersecurity compliance here.

Understanding DFARS 252.204-7012 and NIST SP 800-171

The Defense Federal Acquisition Regulation Supplement, or DFARS, has been working to encourage DoD contractors to proactively comply with certain frameworks in order to achieve this goal. Clause 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting, is the latest mandatory addition.

Under the Clause, all contractors must comply with the National Institute of Standards and Technology’s Special Publication 800-171 (NIST SP 800-171), a framework that lays out how contractors must protect sensitive defense information and report cybersecurity incidents.

The NIST framework requires you, as a defense contractor, to document how you have met the following requirements in particular:

  • Security requirement 3.12.4 requires the contractor to develop, document, and periodically update System Security Plans (SSPs) that describe system boundaries, system environments of operation, how security requirements are implemented, and the relationships with or connections to other systems.
  • Security Requirement 3.12.2 requires the contractor to develop and implement Plans of Action designed to correct deficiencies and reduce or eliminate vulnerabilities in their systems.

Read more about implementing SSPs and POAs.

Under the Clause, DoD contractors are obliged to submit evidence of their compliance with NIST SP 800-171 to the U.S. Government. However, the Clause goes beyond NIST compliance and sets out additional rules for the protection of Covered Defense Information (CDI).

Supply Chain Management

DFARS Clause 252.204-7012 aims to encourage you, as a contractor, to take a proactive role in the protection of CDI. Not only are you required to demonstrate compliance within your own business, but in order to strengthen the entire supply chain, you must take steps to ensure that your subcontractors comply, too.

It is the responsibility of your subcontractors to inform you if their practices deviate in any way from the DFARS and NIST 800-171 guidelines, and it is your responsibility to demonstrate that an equally secure alternative practice is in place before you share CDI with that subcontractor.

Reporting Cybersecurity Incidents

A cybersecurity incident is defined as a breach of security protocols that negatively impacts, compromises, or endangers CDI held on your systems or networks, or those of your subcontractors.

In the event of a cybersecurity incident, your responsibility under DFARS Clause 252.204-7012 is to report the incident to the DoD within 72 hours. You must present the affected data and all related data covering the 90 days prior to the date of the report, along with any infected software. You must also conduct a thorough systems review and identify ways in which you will prevent future breaches.

If a subcontractor experiences a cybersecurity incident, they must report it to you, or to the next highest tier of subcontractor, and present the evidence as required. As the prime contractor, you’re then required to report the incident to the DoD and submit the evidence, as detailed above.

Cloud Service Provision

If you offer your own cloud services as part of your DoD contract, then DFARS states that you must enact the safeguards set forth in the Cloud Computing Security Requirements Guide (SRG), unless waived by the Chief Information Officer of the DoD. If you use a third-party cloud service, then you’re required to ensure that your cloud service provider follows the security provisions therein.

Not DFARS Compliant?

A quick look at documents like the above and it’s clear to see why some contractors are still struggling with compliance long after the December 31st, 2017 deadline has passed. Bringing your business in line with these extensive regulations is required and the stakes are so high.

Download our 5 Steps to DFARS Compliance Guide to avoid penalties and make compliance a documented, automated outcome of day-to-day operations. This easy to follow guide presents a plan you can follow to achieve compliance in a way that fits your business and budget.

 

The management of organizational risk is a key element in any organization’s information security program, particularly those like Department of Defense (DoD) contractors that process highly sensitive, critical data.

With this in mind, the National Institute of Standards and Technology (NIST) has developed the Risk Management Framework (RMF), a set of processes for federal bodies to integrate information security and risk management into their systems development life cycles.

The Six Steps of the Risk Management Framework (RMF)

The RMF consists of six steps to help an organization select the appropriate security controls to protect against resource, asset, and operational risk. They are:

Step 1: Categorize the system and the information that is processed, stored and transmitted by the system.

Step 2: Select an initial set of baseline security controls for the system based on the categorization, tailoring and supplementing as needed.

Step 3: Implement the security controls and document how they are deployed.

Step 4: Assess the security controls to determine the extent to which they are meeting the security requirements for the system.

Step 5: Authorize system operation based upon a determination that the level of risk is acceptable.

Step 6: Monitor and assess selected security controls in the system on an ongoing basis and reporting the security state of the system to appropriate organizational officials.

Who Needs to Implement the RMF and Why?

Industries with critical or highly sensitive data needs are increasingly adopting the RMF in an effort to cope with growing risk and comply with their strict legislation— think defense (DFARS), healthcare (HIPAA), and retail/payment (PCI).

However, it’s our professional opinion that every organization that handles sensitive data can benefit from adopting the RMF. Why?

First, the RMF functions as a very effective security planning tool that gives you a comprehensive picture of your organizational risk. This helps to inform a solid risk management strategy and focus your attention on the areas that matter most to your organizational security.

Second, the RMF is not specific to any one agency or body, which gives it the flexibility to be adopted and applied by organizations of all shapes, sizes, and industries — including yours.

Finally, the RMF is seen as the gold standard on which many risk management approaches are modeled. For that reason, it wouldn’t be surprising to see it mandated in some form in the near future, particularly for high-risk industries, but possibly across the board.

This happened recently with the EU’s General Data Protection Regulation (GDPR), which mandated that any and every company handling sensitive data comply with the regulations, regardless of industry.

By adopting RMF in your own organization, you’ll be automatically compliant if and when any similar legislation comes into force on our own shores, while your competitors will likely be scrambling to catch up.

RMF and Defense Contractors

Contractors of the DoD have a set of legal obligations under the Defense Federal Acquisition Regulation Supplement, or DFARS. This legislation requires such contractors to demonstrate proactive compliance with, among other frameworks, the NIST Special Publication 800-171 (NIST 800-171), which lays out how they must protect sensitive defense information and report cybersecurity incidents.

So, if a contractor is already DFARS-compliant, and they’re already implementing the security controls set out in NIST 800-171, why do they need to adopt the RMF too? (Not DFARS Compliant? Download our 5 Steps to DFARS Compliance Guide to avoid penalties and make compliance a documented, automated outcome of day-to-day operation.)

In working with our defense clients on securing their acquisitions processes, we’ve consistently observed the need for security controls above and beyond what NIST 800-171 requires. That’s exactly what the RMF provides, paying attention to areas such as resilience enhancements and tailoring requirements.

It’s our opinion, then, that the RMF can help defense contractors to plan risk-based security control implementation in a much more broad, holistic manner than DFARS and NIST 800-171 compliance alone.

Limitations of RMF

Because it’s a framework, the NIST RMF doesn’t tell you how to achieve the recommended steps. That means that for small and medium organizations without significant information security experience, or the resources to obtain it, implementing the framework can be a challenge.

That’s Where CyberSheath Comes In

Our cybersecurity experts can help you to minimize your organizational risk with comprehensive risk management planning, including the implementation of the NIST Risk Management Framework. Contact us now to find out how we can help protect your organization.

In a previous blog post we detailed how the November 6th, 2018, DoD’s Acting Principal Director for Defense Pricing and Contracting (DPC) memorandum titled, “Guidance for Assessing Compliance and Enhancing Protections Required by DFARS Clause 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting” was expected to be transformative in the enforcement of compliance throughout the acquisition process.

As a follow up to the November guidance; DoD has issued two additional guidance memoranda in the last 60 days further solidifying the DoD intent to enforce compliance. Contractors should be actively be addressing NIST 800-171 compliance.

Let’s See Your System Security Plans (SSP) Plans of Action and Milestones (POA&M)

On December 17, 2018, Kevin Fahey (Assistant Secretary of Defense for Acquisition) issued a memorandum, which provides contractual language addressing (i) access to and delivery of contractors’ and subcontractors’ SSPs (or extracts thereof), (ii) access to and delivery of a contractor’s plan to track flow down of CDI to subcontractors and restriction on unnecessary sharing/flow down of CDI and (iii) the requirement for a prime contractor to flow down (ii) and (iii) to its first-tier subcontractors.

The Fahey memo details requirements that were not clearly reflected in DFARS 252.204-7012.

The creation of SSPs and POA&M documents was included with NIST SP 800-171 and the November 6th guidance further clarified that DoD would require delivery of the Prime’s SSPs and POA&Ms to the government. Additionally, Prime contractors must ensure government access to the SSP and POA&Ms of its first- and second-tier subcontractors, vendors, and suppliers.

Contractors will need to ensure that their processes for subcontractors, vendors, and suppliers meet this requirement.

Auditing of DFARS Compliance

On January 21, 2019, Ellen Lord (Under Secretary of Defense for Acquisition and Sustainment) issued a second memorandum focused on assessing contractor compliance with the DFARS cyber clause via audits. The DCMA audits focus on contractor oversight of its first-tier subcontractors which can include first-tier subcontractors, vendors, and other suppliers.

The DCMA audits focus on contractor oversight for first-tier subcontractors and include:

  • Review Contractor procedures to ensure contractual DoD requirements for marking and distribution statements on DoD CUI flow down appropriately to their Tier 1 Level Suppliers.
  • Review Contractor procedures to assess compliance of their Tier 1 Level Suppliers with DFARS Clause 252.204-7012 and NIST SP 800-171.

While there is no specific requirement in the DFARS cyber clause for documented procedures to flow down CDI to first-tier subcontractors or any specific requirement to assess compliance of first-tier subcontractors with the DFARS cyber clause, it is expected these requirements will be mandated with the new contractual language in the December 17 Fahey memorandum.

Additionally, in May 2018 Defense Security Service (DSS) was directed to execute an operational plan for oversight of Controlled Unclassified Information (CUI) protection through collaboration with industry partners across the Defense Industrial Base (DIB).

Product Purchases Won’t Get You There

The disconnect between achieving compliance and the offerings that many product vendors are marketing is increasing both complexity and confusion. There isn’t a product in existence that addresses all 110 NIST 800-171 security requirements and many of the requirements can often be met with existing solutions contractors already own. Software that simply assesses your current compliance isn’t automated, despite claims, and does nothing to actually implement the required controls.

There are features or capabilities of products that can be mapped to the 110 NIST 800-171 security requirements but the first action in getting compliant doesn’t start with buying another product. Part of a comprehensive gap assessment will include detailing what you already own that can be configured, deployed or otherwise implemented to satisfy the control requirements.

Getting Compliant and Staying Compliant

Updated guidance, overlapping audits, and general confusion can make DFARS compliance difficult and expensive, but it doesn’t have to be. Cybersheath has enabled hundreds of contractors to achieve compliance and stay competitive in the DoD acquisition process and we guarantee success.

To learn more start here and Download our 5 Step Process To Comply With NIST 800-171. It’s free and if you have the right team and resources available you can do it all yourself.

Get expert assistance, before you are audited and achieve compliance in a way that fits your budget and mission, contact CyberSheath for a no-obligation scoping call to learn how to stay ahead of an audit and comply now!

DoD contractors, subcontractors and vendors taking a wait and see approach before achieving compliance are mistaken, the time is now!

On November 6th, 2018, DoD’s Acting Principal Director for Defense Pricing and Contracting (DPC) issued a memorandum titled, “Guidance for Assessing Compliance and Enhancing Protections Required by DFARS Clause 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting” that is expected to be transformative in the enforcement of compliance throughout the acquisition process.

While the implementation of DFARS and NIT 800-171 requirements have been mandatory since December 2017, many Department of Defense (DoD) contractors haven’t yet felt the sting of an audit and efforts were largely contained to completing checklists from government contracting officers or Primes. The DoD telegraphed a transition to enforcement and the impacts of non-compliance with guidance made available to the public for comment in Federal Register, Volume 83 Issue 79 (Tuesday, April 24, 2018). All comments were considered and integrated, when appropriate, into the final documents and as expected 2019 will be a game changer for non-compliant Prime and subcontractors.

The November 6th, 2018 memorandum references two new guidance documents providing for enforcement of DFARS 252.204-7012 & NIST 800-171 across the entire supply chain:

“DoD Guidance for Reviewing System Security Plans and the NIST SP 800-171 Security Requirements Not Yet Implemented”

“Guidance for Assessing Compliance of and Enhancing Protections for a Contractor’s Internal Unclassified Information System”

This new set of guidance empowers acquisition officers to enforce compliance throughout the entire acquisition lifecycle, both before and after contract award. Changes include:

  • A standard for the data content and format to be used in NIST SP 800-171 System Security Plans
  • Adding cybersecurity measures in addition to those found in NIST SP 800-171
  • Creating an “Acceptable” (Go/No Go threshold) rating, which can require “must-have” NIST 800-171 requirements to be in place before an award can be made
  • Incorporates 800-171 compliance as a technical evaluation factor, which often becomes part of the weighted score for contract awards
  • Conducting on-site assessments, using NIST SP 800-171A: Assessing Security Requirements for Controlled Unclassified Information
  • Requiring a contractor to complete a new form titled: ‘Contractor’s Record of Tier 1 Level Suppliers Receiving/Developing Covered Defense Information
  • Requesting a contractor’s plan to track flow down of Covered Defense Information
  • Requesting a contractor’s plan to assess the compliance of their own suppliers

With the ability to request a contractor’s plan to track flow down of Covered Defense Information (CDI) and request the contractor’s plan to assess the compliance of their own suppliers, Prime contractors are expected to document and demonstrate enforcement of their own supply chain’s compliance.

In 2019 Prime and Subcontractors can expect to be audited against actual implementation the DFARS 252.204-7012 & NIST 800-171 security requirements. For those taking a wait and see approach to the impact of your ability to do business with the DoD without implementing NIST 800-171; you just got your answer, 2019 will be a year of reckoning for non-compliant Prime and subcontractors.

If you have delayed documenting your SSP, POA&Ms or actually implementing the NIST 800-171 requirements, CyberSheath can lead your efforts to achieve compliance by conducting a gap assessment of your compliance with NIST 800-171, writing the required System Security Plan (SSP) and leading your implementation efforts. Contact Us today to get started!

As a subcontractor on a Department of Defense contract, you have likely had flow down requirements from your primes related to DFARS clause 252.204-7012, commonly referred to as NIST 800-171. Many subcontractors, as they scramble to secure their infrastructure to be in compliance before the December 2017 DFARS deadline, are also asking, “When should DFARS clause 252.204-7012 flow down to our subcontractors?”

To help you answer that question, here are some basics related to DFARS clause 252.204-7012: Safeguarding Covered Defense Information and Cyber Incident Reporting (effective October 21, 2016) and NIST 800-171.

The Basics of DFARS Clause 252.204-7012

This clause is required in all contracts except for those contracts solely for the acquisition of COTS items. It requires contractors and subcontractors to:

  1. Safeguard covered defense information (CDI) that is resident on or transiting through a contractor’s internal information system or network.
  2. Report cyber incidents that affect covered defense information or that impact the contractor’s ability to perform requirements designated as operationally critical support.
  3. Submit malicious software discovered and isolated in connection with a reported cyber incident to the DoD Cyber Crime Center.
  4. If requested, submit media and additional information for damage assessment.

What is Covered Defense Information (CDI)?

This term is used to identify information that requires protection under DFARS Clause 252.204-7012. Covered defense information is unclassified controlled technical information (CTI) or other information as described in the controlled unclassified information (CUI) Registry that requires safeguarding or dissemination controls*, and is either:

  • Marked or otherwise identified in the contract, task order, or delivery order and provided to contractor by or on behalf of DoD, in support of the performance of the contract or
  • Collected, developed, received, transmitted, used, or stored by or on behalf of the contractor, in support of the performance of the contract.

* Pursuant to and consistent with law, regulations, and Government-wide policies

Does DFARS clause 252.204-7012 flow down to subcontractors?

The clause impacts subcontractors when performance will involve operationally critical support or CDI. You should determine in consultation with your contracting officer if necessary, if the information required for subcontractor performance is or retains its identify as CDI, and requires safeguarding or dissemination controls. Flowdown is to be enforced by the prime contractor. If a subcontractor does not agree to comply with the clause, CDI should not be on that subcontractor’s information system.

What does DFARS Clause 252.204-7012 require?

Simply stated, this DFARS clause mandates adequate security. The contractor shall provide sufficient security on all covered contractor information systems. To provide satisfactory security for covered contractor information systems that are not part of an IT service or system operated on behalf of the Government, at a minimum, the contractor must implement NIST SP 800-171, as soon as practical, but not later than December 31, 2017.

What is NIST SP 800-171?

This standard:

  • Enables contractors to comply using systems and practices likely already in place.
  • Significantly reduces unnecessary specificity, as requirements are performance-baseda, and more easily applied to existing systems.
  • Provides standardized, uniform set of requirements for all CUI security needs.
  • Allows non-federal organizations to consistently implement safeguards for the protection of CUI (i.e., one CUI solution for all customers).
  • Allows contractors to implement alternative, but equally effective, security measures to satisfy CUI security requirements.

If you are struggling with interpreting these requirements or need help implementing the security controls? CyberSheath can help you determine a path forward for achieving compliance by conducting a gap assessment of your compliance with NIST 800-171, writing the required System Security Plan (SSP) and leading your remediation efforts. Contact Us today to get started!

With the deadline for compliance with DFARS Clause 252.204-7012 having passed on December 31st 2017, many companies are still scrambling to catch up. But in their haste, many may be ignoring a vital aspect of the mandate.

Chiefly designed to ensure adequate security in safeguarding “covered defense information” (CDI), DFARS requires Department of Defense (DoD) contractors and subcontractors to implement controls to protect sensitive data “collected, developed, received, transmitted, used, or stored by or on behalf of the contractor in support of the performance of the contract.”

However, it also includes clearly specified mandates for cyber incident reporting, when a contractor or subcontractor discovers that CDI has been compromised or adversely affected within their networks. In addition to safeguarding CDI, it is imperative that companies follow these prescribed reporting requirements if they experience a cyber incident.

Report Rapidly

Collecting information on cyber incidents allows the government to investigate key details in order to monitor and hopefully contain future cyber threats. As such, DFARS cyber incident reporting mandates are designed to assure businesses turn over this information quickly.

According to DFARS, a cyber incident is defined as “actions taken through the use of computer networks that result in a compromise or an actual or potentially adverse effect on an information system and/or the information residing therein.” If you have determined that a cyber incident has taken place, then in accordance with the “Rapid Reporting” requirement you must:

(i) Conduct a review for evidence of compromise of covered defense information, including, but not limited to, identifying compromised computers, servers, specific data, and user accounts. This review shall also include analyzing covered contractor information system(s) that were part of the cyber incident, as well as other information systems on the Contractor’s network(s), that may have been accessed as a result of the incident in order to identify compromised covered defense information, or that affect the Contractor’s ability to provide operationally critical support; and

(ii) Rapidly report cyber incidents to DoD at http://dibnet.dod.mil within 72 hours of discovery.

The DFARS provision defines a compromise as the “disclosure of information to unauthorized persons, or a violation of the security policy of a system, in which unauthorized intentional or unintentional disclosure, modification, destruction, or loss of an object, or the copying of information to unauthorized media may have occurred.”

Although there has been some debate as to what reporting triggers define the start of the 72-hour timeframe, implementing a clear cyber incident response plan can create a track record of internal consistency that would prove responsibility if a contractor’s reporting methods were ever to be scrutinized.

A full list of what to report can be found on this page of the DoD’s DIB Cyber Incident Reporting & Cyber Threat Information Sharing Portal.

Detect Malware

In the event that malicious software (malware) is found on a compromised system, the contractor must also collect information about the malware and submit it using a malware submission form to the DoD Cyber Crime Center (DC3) “in accordance with instructions provided by DC3 or the Contracting Officer.”

Preserve Your Media

The DoD may also choose to conduct a thorough post-incident investigation, also known as a damage assessment. To allow for this, they require companies that have been breached to “preserve and protect images of all known affected information systems” and “all relevant monitoring/packet capture data” for at least 90 days following the discovery of an intrusion.

Advice on Reporting

Opening up the lines of communication with the DoD prior to any incident ensures that the process is less complicated and helps you to report in a timely fashion.

In addition, making sure your forensics tools and procedures meet the DoD collection requirements will also ensure that you’re able to quickly gather the required information and report all the pertinent details in full.

Preparation is key. Make sure to practice using your forensics collection procedures so you can quickly report and recover without missing a beat. It’s also important to note that any report of a cyber incident must have a DOD-approved medium assurance certificate. Information on how to obtain this certificate can be found at  iase.disa.mil.

Need Assistance?

If you’re looking for someone to stay on top of your reporting so you don’t drop the ball, or if you just need further assistance understanding the complex process of reporting a cyber incident, Contact Cybersheath today for a free consultation.

 

 

On December 31, 2017, the deadline passed for defense suppliers to comply with NIST 800-171, a requirement specified in Defense Federal Acquisition Regulation Supplement 252.204-7012 “Safeguarding Covered Defense Information and Cyber Incident Reporting.

This mandate attempted to ensure a higher standard of security controls surrounding the processes and procedures for protecting controlled unclassified information (CUI). As defined by the National Archives, CUI is “information that requires safeguarding or dissemination controls pursuant to and consistent with applicable law, regulations, and government-wide policies but is not classified under Executive Order 13526 or the Atomic Energy Act, as amended.”

Confused? You’re not alone! Assessing what is and what isn’t CUI, as well as navigating the complex and potentially costly road to compliance, has left many contractors struggling to stay on schedule. Although the deadline has passed, a large number of companies are still standing around scratching their heads, wondering how to proceed.

Consequences of Non-compliance

Non-compliance is not going to be acceptable for much longer. Clause 3.12.4 of NIST 800-171 allows for the submission of a Security System Plan (SSP) and a Plan of Actions and Milestones (POA&M) to help companies define how they will bridge the gap, but it is also reasonable to expect that the U.S. Government will soon begin to terminate contracts that fail to meet the accepted requirements. Defense prime contractors will also begin to terminate non-compliant subcontractors and suppliers to avoid having to report themselves as non-compliant.

Because so many companies have fallen behind, those that have achieved this rare milestone will have positioned themselves to receive the lion’s share of future defense contracts. Simply put, if companies want to remain competitive, they must move as quickly as they can to get on track or risk falling behind their competition.

Becoming Compliant

If your company has fallen behind, don’t get discouraged. The path to compliance is a confusing one, but it’s possible to find your way. Start by taking the following steps…

1. Define CUI

CUI is situation-specific and can be tricky to assess. In some cases, the information that needs to be protected are specified in the awarded contract. However, most of the time the definition is unclear.

In their own definition, DFARS has included CUI that is “collected, developed, received, transmitted, used, or stored by or on behalf of the contractor in support of the performance of the contract.” Information that has been created or received by contractors, but not marked, may also need to be appropriately safeguarded. Identifying what needs to be protected is the first step.

2. Identify where it lives

The next step is to figure out exactly where the CUI is being stored, processed, or transmitted from so that you know which systems need to be secured.

Creating a Data Flow Diagram (DFD) is a helpful way to begin figuring out how CUI is traveling through your network. It could also be useful to create a network diagram to identify what controls you already have in place that are effectively safeguarding your CUI. Together, these tools can help you identify the weak points you’ll need to address to close the gaps in your systems.

3. Document your progress

Having identified CUI and where it lives, you should now begin the process of referring back to NIST 800-171 to figure out the controls you will need to put into place.

As you forge ahead in making these updates, it’s critical to document what you’ve changed, how it will improve security, what controls are not applicable to your current situation, and why they won’t be needed.

This process will create a record demonstrating your ability to assess and safeguard sensitive information, moving you closer to your ultimate goal of declaring full compliance with the DFARS/NIST 800-171 mandate.

Your Competitors are Working on Compliance — Are You?

If you’re not currently working towards meeting the DFARS/NIST requirements, rest assured your competitors are! The window for implementing this essential security update is closing rapidly, so don’t lose your competitive edge — contact us now for a free consultation on achieving your compliance goals.

On December 31, 2017, the deadline for compliance with the NIST 800-171, a mandate for contractors serving local and federal governments, came and went.

This Special Publication provided guidance on the processes and procedures needed to adequately safeguard controlled unclassified information (CUI), defined as any information created by the government or entities on behalf of the government that is unclassified, but still must be appropriately safeguarded.

While some companies were quick to adapt to these new regulatory measures, many companies fell behind because of a lack of resources, confusion over the head-spinning compliance process, or just downright procrastination.

With the deadline long gone and the Department of Defense (DoD) making it crystal-clear that NIST 800-171 is here to stay, becoming compliant is an absolute must for those looking to remain competitive in the industry.

A Common Problem

Unlike previous security mandates, this is the first that impacts sub-contractors working further down the federal supply chain. This means that for many companies, it’s the first time they’re having to figure out compliance.

If this describes your company, you’re by no means alone. Because these standards must be met by anyone who stores, processes, or transmits CUI for the DoD, General Services Administration (GSA), NASA, or other federal or state agencies, many contractors are struggling to wrap their heads around the complex process ahead.

As it’s critical to a supplier’s ability to win new business and keep current defense contracts, both prime and sub-contractors will want to confirm that they are, at the very least, on the path to compliance with NIST 800-171.

Achieving Compliance

Of course, becoming compliant is easier said than done. The fact that there is no certification process for NIST means contractors work on the honor system, attesting that they have reviewed and heeded the applicable requirements specified in the regulation.

This also means that becoming compliant is not a one-time achievement. Rather, it’s an ongoing process of continuous evaluation. Here are the three key actions you can take to get started…

Assess Your Compliance Level

First, you’ll need to do due diligence in identifying CUI as it applies to you. Check with your contracting officers or look through your contract to see if CUI has been clearly defined. In many cases, it may not be, and you’ll have to review the CUI registry to find similar examples of CUI.

Once you’ve clearly defined what you need to protect, you can begin to figure out if it’s actually being protected sufficiently. You’ll have to carefully review your critical systems, including servers, laptops, storage devices, network devices, end-user workstations. You’ll also need to assess the physical security of those devices that contain CUI to make sure they are properly safeguarded.

Design a Plan of Action

Chances are there will be a gap between where you are now and where you need to be. This is common so don’t worry!

Fortunately, clause 3.12.4 allows for the submission of a Security System Plan (SSP) and a Plan of Actions and Milestones (POA&M) to buy yourself some time as you work towards your compliance goal. Since many contractors are not yet compliant, these documents are required to show procurement officials you are heading in the right direction.

An SSP will provide an overview of the security requirements needed for every system you use, describe the curent controls you have in place, and outline the expected behaviors of all who access them. Your POA&M will show a clearly defined corrective strategy for exactly when and how you plan to resolve any security weaknesses. 

Begin Implementation  

All this planning and assessing means nothing if you don’t step up and deliver! Once you’ve put milestones in place, you’ll need to train your staff and ensure they adhere rigorously to these deadlines. You’ll also need to document critical advancements in your quest for compliance, properly maintaining your records as you go.

Still Nowhere Near Compliance? Don’t Panic!

If you missed the December 2017 deadline and you’re starting to feel the pressure, don’t panic. CyberSheath’s Managed Security Services can help you to define your CUI obligations, create a plan of action, and move step-by-step towards full compliance. Contact us today for a free consultation.

 

 

More than two years ago, the Department of Defense (DoD) sounded the alarm for increased cybersecurity with a new set of controls designed to raise the level of safeguarding standards across the industry.
The requirements specified in Defense Federal Acquisition Regulation Supplement (DFARS) provision 252.204-7012, “Safeguarding Covered Defense Information and Cyber Incident Reporting”, were gleaned from Special Publication (SP) 800-171, authored by the National Institute of Standards and Technology (NIST).
A non-regulatory government agency designed to promote U.S. innovation and industrial competitiveness, NIST identified a set of 110 security control requirements, appropriate for non-government organizations, to be implemented by December 31st of 2017. But even with the deadline long since passed, many contractors are still struggling to meet these standards. Here are the three main reasons why…

Lack of Resources

NIST’s daunting to-do list has left many small to medium companies wondering how they’ll close the gap between what is required and what they can afford to implement.
Put at a disadvantage by budget and workforce limitations, companies find themselves falling behind due to a lack of cost-effective solutions and an inability to dedicate the manpower to keep their cybersecurity standards up-to-date.
Companies must report any shortcomings or gaps in their compliance to the DoD’s Chief Information Officer (CIO) within 30 days of any contract award. That means that the time and resource constraints are only exacerbated if the people in charge don’t have an intimate understanding of the NIST SP 800-171 security controls.
These companies need help but don’t know where to turn. As a result, they’ve found themselves exposed to increasingly advanced cybersecurity threats and will continue to accrue non-compliance penalties until they can find the assistance they need.

Complexity

In an attempt to provide flexibility, make the controls technology-neutral, and allow for contractors to implement whatever solutions best fit their company, NIST has inadvertently made it difficult to know whether your company has actually achieved compliance or not.
The first challenge contractors face is assessing whether or not an information system is processing covered defense information (CDI). CDI is defined by the registry maintained by the National Archives and Records Administration and includes Controlled Technical Information (CTI) and Controlled Unclassified Information (CUI).
If these information systems are precisely specified in the awarded contract, the process is simplified. But DFARS has also included CUI that is “collected, developed, received, transmitted, used, or stored by or on behalf of the contractor in support of the performance of the contract.”
This opens the door for large chunks of information that have been created or are received by contractors, but not marked, to also be considered CDI, making the process of identifying which systems process this information much more difficult.
On top of this, the DoD does not currently have any system in place to certify compliance and has not authorized any third-party certification process, leaving it up to you to accurately assess where you stand at any given moment. 

Being Human

As with any complex set of rules, the risk for human error also enters the mix. In the midst of wrapping their heads around a barrage of complicated regulations, many people simply drop the ball.
In companies that are already struggling to dedicate the necessary human resources to compliance, the overwhelm of adjusting to a whole new world of security requirements can lead to small errors that pave the way for much bigger problems.
In cases like these, it’s essential to have an extra set of eyes on the details to make sure problems don’t snowball and create an avalanche down the line.

Rising to the Challenge

If you’re a defense contractor struggling to keep up with NIST 800-171 requirements, performing a compliance assessment should be your top priority. CyberSheath’s Managed Security Services can help you identify the roadblocks on your path to NIST compliance and find cost-effective solutions to overcome them. Contact us today for a free consultation to find out more.

Every day, hackers and thieves are becoming more sophisticated, daring, and aggressive in their attempts to turn stolen data into substantial paydays. And with criminal entities regularly on the prowl for cyber weaknesses to exploit, it’s no wonder that the number of data breaches is growing at a record pace. Partially in response to this rise in cyber attacks, Ohio Attorney General Mike DeWine’s CyberOhio Initiative has introduced The Data Protection Act, signed into law by Governor John Kasich on August 3rd 2018.

Whereas most of the preceding cybersecurity legislation has sought to motivate businesses with punitive and disciplinary action, the DPA is a looking to take a new approach by giving companies a positive and confident push forward towards a more secure future.

The first law of its kind in the nation to provide an affirmative legal defense, the DPA is an absolute boon to any company involved the handling of sensitive data. Beneficial for all involved, it’s designed to inspire a proactive approach to cybersecurity to make the exchange of sensitive information safer and more comfortable for everyone.

The law incentivizes businesses to further protect themselves against cybersecurity risks by providing legal protection to those who deal with personal information in case of a breach, provided that they comply with a designated cybersecurity framework.

A Safe Harbor

Fairly or not, people affected by data breaches often look for a scapegoat. In many cases, they end up trying to hold the breached company liable for losses or damages they’ve incurred.

With even the smallest attack leaving a business vulnerable to serious legal consequences, this bill represents a valuable tool for those looking to limit their liability. Although it doesn’t provide immunity to your company if you comply, it does afford you a ‘safe harbor’ against tort claims that failed cybersecurity measures resulted in the data breach.

Both businesses and consumers should be set to benefit from this development as companies become more motivated to up their game and meet industry standards for cybersecurity.

How to Comply

As of November 2nd, 2018, your business can trigger the ‘safe harbor’ provided that you adopt a cybersecurity program designed to:

  • Protect the security and confidentiality of personal information;
  • Protect against any anticipated threats or hazards to the security or integrity of the personal information; and
  • Protect against unauthorized access to and acquisition of information that is likely to result in a material risk of identity theft or other fraud.

Since no two companies are alike, the law does acknowledge that the above guidelines are not meant to be a one-size-fits-all approach to cybersecurity. An effective program will have to be scaled to match:

  • The size, complexity, and nature of your business and its activities;
  • The level of sensitivity of the personal information your business possesses;
  • The cost and availability of tools to improve your security and reduce vulnerabilities; and
  • The resources your business has at its disposal to expand on cybersecurity.

Further guidance also advises businesses to ‘reasonably conform’ to one of the following industry-recognized frameworks:

  • The National Institute of Standards and Technology’s (NIST) Cybersecurity Frameworks;
  • NIST Special Publication 800-171, or Publications 800-53 and 800-53a;
  • The Federal Risk and Authorization Management Program (FedRAMP) Security Assessment Framework;
  • The International Organization for Standardization (ISO)/International Electrotechnical Commission’s (IEC) 27000 Family – Information Security Management Systems Standards;
  • Center for Internet Security’s Critical Security Controls for Effective Cyber Defense;
  • The Security Rule of the Health Insurance Portability and Accountability Act (HIPAA) for healthcare industry businesses subject to HIPAA oversight;
  • The Federal Information Security Modernization Act of 2014 (P.L. 113-283); and
  • The Safeguards Rule of the Gramm-Leach-Bliley Act, for certain financial institutions.

If you accept card payments, you’ll also have to comply with the Payment Card Industry’s Data Security Standards (PCI-DSS).

Challenges Ahead

Although guidelines have been provided, demonstrating full compliance may prove challenging since many of the specified frameworks lack standard certification processes.

Also, since some data security laws have more flexible requirements than others, questions remain over how to demonstrate complete conformity, or which aspects to comply with to ensure the best legal defense. For this reason, when attempting to implement frameworks, it’s a wise move to consult with cybersecurity experts like CyberSheath.

Our Managed Services enables compliance with the Ohio DPA to ensure comprehensive, framework based compliance. We’ll guide you through the process from assessment through remediation, integrating your existing people, processes, and technologies with your chosen frameworks.

A Win-win for Your Business and Your Customers

Not only will CyberSheath’s managed services help you to achieve full compliance and reduce your legal liability, but you’ll also see a demonstrable improvement to your day-to-day operational security — a true win-win for your business and your customers.

 

Thanks to the increasingly sophisticated and aggressive cybersecurity threats facing the U.S., there has been much focus recently on reinforcing the nation’s cybersecurity. Much of this effort has revolved around strengthening the Department of Defense (DoD) supply chain.

The Defense Federal Acquisition Regulation Supplement, or DFARS, has been working to encourage DoD contractors to proactively comply with certain frameworks in order to achieve this goal. Clause 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting, is the latest mandatory addition.

Under the Clause, all contractors must comply with the National Institute of Standards and Technology’s Special Publication 800-171 (NIST SP 800-171), a framework that lays out how contractors must protect sensitive defense information and report cybersecurity incidents.

The NIST framework requires you, as a defense contractor, to document how you have met the following requirements in particular:

• Security requirement 3.12.4 requires the contractor to develop, document, and periodically update System Security Plans (SSPs) that describe system boundaries, system environments of operation, how security requirements are implemented, and the relationships with or connections to other systems.
Security Requirement 3.12.2 requires the contractor to develop and implement Plans of Action designed to correct deficiencies and reduce or eliminate vulnerabilities in their systems.

Read more about implementing SSPs and POAs.

Under the Clause, DoD contractors are obliged to submit evidence of their compliance with NIST SP 800-171 to the U.S. Government. However, the Clause goes beyond NIST compliance and sets out additional rules for the protection of Covered Defense Information (CDI).

Supply Chain Management

DFARS Clause 252.204-7012 aims to encourage you, as a contractor, to take a proactive role in the protection of CDI. Not only are you required to demonstrate compliance within your own business, but in order to strengthen the entire supply chain, you must take steps to ensure that your subcontractors comply, too.

It is the responsibility of your subcontractors to inform you if their practices deviate in any way from the DFARS and NIST 800-171 guidelines, and it is your responsibility to demonstrate that an equally secure alternative practice is in place before you share CDI with that subcontractor.

Reporting Cybersecurity Incidents

A cybersecurity incident is defined as a breach of security protocols that negatively impacts, compromises, or endangers CDI held on your systems or networks, or those of your subcontractors.

In the event of a cybersecurity incident, your responsibility under DFARS Clause 252.204-7012 is to report the incident to the DoD within 72 hours. You must present the affected data and all related data covering the 90 days prior to the date of the report, along with any infected software. You must also conduct a thorough systems review and identify ways in which you will prevent future breaches.

In the event that a subcontractor experiences a cybersecurity incident, they must report it to you, or to the next highest tier of subcontractor, and present the evidence as required. As the prime contractor, you’re then required to report the incident to the DoD and submit the evidence, as detailed above.

Cloud Service Provision

If you offer your own cloud services as part of your DoD contract, then DFARS states that you must enact the safeguards set forth in the Cloud Computing Security Requirements Guide (SRG), unless waived by the Chief Information Officer of the DoD. If you use a third-party cloud service, then you’re required to ensure that your cloud service provider follows the security provisions therein.

Don’t Know Where to Start?

A quick look at documents like the above and it’s clear to see why some contractors are still struggling with compliance long after the December 31st, 2017 deadline has passed. It truly is a daunting task bringing your business into line with these extensive regulations, especially when the stakes are so high.

That’s where a Managed Services expert like CyberSheath comes in. We’ve helped defense contractors large and small to achieve comprehensive DFARS and NIST compliance.

Put Your Cybersecurity Compliance in Expert Hands

We’ll take the stress and the guesswork out of compliance by handling every step of the journey, from assessment and gap identification to the development of robust System Security Plans and Plans of Action. And because we’re always monitoring the evolution of DoD frameworks, we’ll continue to update your plans in line with regulatory changes to guarantee ongoing compliance.

Let CyberSheath help you to protect your valuable DoD contracts and remain competitive in the defense supply chain. Contact us now for a no-obligation discussion to find out how.

As cyber-attacks become more frequent and sophisticated, addressing tighter security needs has become a priority for the federal government. Enforcement of “Controlled Unclassified Information” (CUI) protection continues to intensify as private contractors and organizations are now required to upgrade their cybersecurity systems and overall procedures to keep up with these increasing threats. On April 24, 2018, the Department of Defense (DoD) issued draft guidance for assessing contractors’ System Security Plans (SSPs) and the implementation of security controls in NIST Special Publication (SP) 800-171.  If you’re a defense contractor, you’re required to comply with these regulations and provide “adequate security” for networks where covered defense information (CDI) is processed, stored, or transmitted. DoD issued two draft guidance documents. The first, “Assessing the State of a Contractor’s Information System,” provides guidance on four different objectives.  They include what must be in an RFP, how the source selection authority would evaluate the requirement, what resources are available for that evaluation, and the contract provisions that will be needed to implement the requirement during performance. The second draft guidance document, “DoD Guidance for Reviewing System Security Plans and the NIST SP 800-171 Security Requirements Not Yet Implemented,” was developed by DoD to determine the risks that an unimplemented security control has on an information system, and which of the unmet controls need to be prioritized. What does “adequate security” mean? At a minimum, defense contractors must implement the requirements in NIST SP 800-171 to become compliant. Contractors need to provide an SSP to prove the implementation of the security requirements, and also develop plans of action and milestones (POA&M) that describe how any unimplemented security requirements will be met.

Unimplemented Controls Receive a Value Rating

NIST 800-171 is comprised of 110 technical controls to ensure the best security policies and procedures.  DoD has decided to assess the risk of unimplemented controls by assigning a “DoD Value” for each security requirement ranging from 5 (highest impact on the cybersecurity system) to 1 (lowest impact on the cybersecurity system). These priority codes are used for priority rankings that NIST assigns to the NIST SP 800-53 Revision 4 security controls that are used for government information systems and which form the basis for NIST SP 800-171.

Non-Compliance is Not an Option 

In 2018, proposed DOD guidance is already moving to full enforcement of compliance. Compliance failures can lead to more serious consequences than a data breach.  Failure to comply with DFARS can lead contractors to incur penalties either by the United States Government (civil, criminal, contractual actions in law and administrative), or by individuals and private organizations that were damaged by lack of compliance (actions for damages).

  • Bid Protests: While SSPs and POA&Ms are important for determining “adequate security,” it’s still unclear the exact part they’ll play in bid protests and the implementation of NIST SP 800-171. After reviewing the implementation status during the pre-award stage, the DoD can make an unacceptable or acceptable determination, and ultimately decide if the contract should be rewarded. Another option is to evaluate implementation as a “separate technical evaluation factor.” During the pre-award process, contractors may choose to protest terms where a solicitation’s treatment of NIST SP 800-171 implementation fails to be consistent with DoD’s guidance. On the other hand, if a contract was rewarded to another contractor, disappointed offerors may consider challenging the award to another offeror where the assessment of the protester’s or awardee’s implementation of NIST SP 800-171 is inconsistent with the guidance documents. If the DoD notices inconsistencies between the implementation of NIST SP 800-171 and your SSP and POA&M, they could award the contract to another contractor. During 2018, contract protests awarded to higher-priced bidders were based in part on compliance with cybersecurity and employing more than the minimum security requirements in NIST SP-800-171.
  • Termination Risk: The accuracy of your SSP and POA&M, along with providing proof that you’re moving toward full compliance, is crucial. For the most accurate evaluation, the draft guidance states that solicitations and contracts must include contract data requirements (CDRLs) to “require delivery of System Security Plan and any Plans of action after contract award.” Now that both SSPs and POA&Ms are a contractual obligation, failure to be in compliance may provide a basis for termination if compliance isn’t completed. Or, if the SSP does not accurately state the implementation status of the contractor’s cybersecurity.
  • DCMA Audits: DoD has recently stated that as part of its audit function, DCMA will pull out all the stops to confirm all contractors have an SSP and POA&M.  However, DCMA will not be providing an analysis if the SSP fully complies with the NIST 800-171 security requirements. It’s unknown at this point if the DCMA would leverage any of DoD’s guidance in its review.
  • False Claims Act: If a contractor is audited by DoD and found not to have implemented DFARS/NIST 800-171, the contractor can be on the receiving end of numerous penalties. For example, if your SSP misrepresents your actual cybersecurity status, DoD can bring an action based on fraud, which is a False Claims Act violation. DoD may also be able to prove that the original SSP was key to the Department’s award decision. If DoD’s argument is successful, your earnings under the original contract are at risk, along with the reputation of your organization.

Make Compliance a Priority Before it’s Too Late!

At CyberSheath, we know that implementing these new security controls can seem like a daunting undertaking. We’ve successfully assessed and implemented the required NIST 800-171 controls for leading organizations in the defense industrial base supply chain.

Last week the Washington Post reported that in January and February of this year Chinese government hackers stole 614 gigabytes of material relating to a closely held project known as Sea Dragon from a Navy contractor’s unclassified network. Stolen data included signals and sensor data, information relating to cryptographic systems, and the Navy submarine development unit’s electronic warfare library.  Officials said the material, when aggregated, could be considered classified and this should come as no surprise to anyone familiar with unclassified defense contractor networks.

Unclassified contractor networks often contain a wealth of important information related to the important work they do in support of the Department of Defense DoD and other government entities. This reality is one of the many reasons that the DoD made compliance with DFARs clause 252.204-7012 Safeguarding Covered Defense Information and Cyber Incident Reporting and implementation of NIST 800-171 mandatory no later than December 31, 2017. Unfortunately, many companies are still struggling with implementing the NIST 800-171 requirements or worse, writing the required System Security Plans (SSP) and Program of Action and Milestones (POA&M) and never getting around to implementing the security requirements.

The delay in implementing the NIST 800-171 requirements is likely in part why on April 24th, 2018 the DoD released its draft “Guidance for Reviewing System Security Plans and the NIST SP-800-171 Security Requirements Not Yet Implemented.” The extensive document contains more stringent guidelines on exactly how the DOD will enforce and assess the implementation of security controls for awarding contracts and evaluating proposals. It also provides detailed recommendations for properly assessing System Security Plans (SSPs) and Plans of Action and Milestones (POA&M).

The DoD Guidance provides additional information on how they might penalize business partners who fail to adhere to new security rules, including penalties and not being awarded new contracts. Aside from the obvious competitive business reasons to immediately implement the NIST 800-171 security requirements this latest theft of project Sea Dragon data is a reminder of the implications to national security. Most of NIST 800-171 is just good cybersecurity hygiene that at a minimum will make contractors harder targets for hostile nation-states.

In February, Director of National Intelligence Daniel Coats testified that most of the detected Chinese cyberoperations against U.S. industry focus on defense contractors or tech firms supporting government networks. During his April nomination hearing to lead U.S. Indo-Pacific Command, Adm. Philip S. Davidson, told the Senate Armed Services Committee “One of the main concerns that we have, is cyber and penetration of the dot-com networks, exploiting technology from our defense contractors, in some instances.”  These comments along with the new DoD guidance are a clear indication that compliance isn’t going away.

Attention and focus on contractor networks started in earnest at least ten years ago when industry and the DoD started working together, voluntarily, to select NIST 800-53 base security requirements for implementation and defining cyber incident and information sharing processes. That effort has now evolved into the mandatory implementation of DFARs clause 252.204-7012 Safeguarding Covered Defense Information and Cyber Incident Reporting and implementation of NIST 800-171. The deadline for achieving compliance has come and gone.

At CyberSheath, we know that successfully implementing these new security controls can be a daunting undertaking for your organization. We’ve successfully assessed and implemented the required NIST 800-171 controls for organizations large and small in the defense industrial base supply chain. We’ll ensure your System Security Plan (SSP) and associated Plans of Action & Milestones (POA&M) are documented and fully implemented. Our cybersecurity experts will take care of all identified gaps in your information systems, schedule implementation of any outstanding items and ensure your organization is compliant with all of the latest requirements. We follow all DOD guidance to ensure review of SSPs and POA&Ms and “assist in prioritizing the implementation of security requirements not yet implemented.” After we have delivered a fully compliant solution we offer managed services to maintain your compliance and incorporate any updates from the DoD.

Contact CyberSheath today for a no-obligation phone consultation, and learn how we can ensure compliance with NIST SP 800-171 in five steps sales@cybersheath.com

 

 

The December 31, 2017 deadline for achieving compliance with NIST 800-171 has come and gone. If you’re still not compliant, you’re at risk for penalties, and chances of winning future contracts and bids are at great risk. The good news is it’s not too late!

It’s understandable if you haven’t yet actually implemented the required NIST 800-171 security requirements. In the past, the DOD permitted businesses to choose a future date for implementing required security controls through the Plan of Actions & Milestones (POA&M) policy. As a result, businesses and organizations used POA&M merely as a simple checkbox system, which led to weak System Security Plans and stalled control implementations. Today, the DOD has upped their game by insisting on stronger cybersecurity practices among its business partners. They’ve moved to an enforcement phase for cybersecurity compliance and requirements with recently released DoD Guidance.

On April 24th, 2018 the U.S. Department of Defense released its draft “Guidance for Reviewing System Security Plans and the NIST SP-800-171 Security Requirements Not Yet Implemented.” The extensive document contains more stringent guidelines on exactly how the DOD will enforce and assess the implementation of security controls for awarding contracts and evaluating proposals. It also provides detailed recommendations for properly assessing System Security Plans (SSPs) and Plans of Action and Milestones (POA&M).

The DoD Guidance provides additional information on how they might penalize business partners who fail to adhere to new security rules, including penalties and not being awarded new contracts.

Failure to Implement the Required NIST 800-171 Controls will Lead to Lost Bids, Vendors and Revenue

For the best chances of new contract awards and superior contract performance in the competitive cybersecurity market, you need to implement the Security Controls and heightened information security requirements as outlined in NIST SP 800-171.

NIST has a set of 110 security requirements that stem from the NIST SP 800-53, which governs the cybersecurity standards for government systems. The new guidance was also designed to help businesses assess and prioritize the most effective ways for them to begin implementing these crucial 110 security controls specified in NIST SP 800-171.

The DOD has a new tactic for reviewing SSPs and security requirements not yet implemented, which is to assign risk scores to controls. For example, security controls that are considered high risk and haven’t been implemented pose an extremely high risk to the data being protected and your ability to win DoD contracts.

Security controls that haven’t been implemented are given a DOD Risk Value for each security requirement that ranges from the highest, which is 5 (highest risk and priority for implementation) to 1 (lowest risk and priority for implementation).

If you don’t meet the 110 security requirements, it will likely lead to losing potential contracts through poorly written SSPs and high-risk scores resulting from a failure to implement the required controls.

Relax. We’ve Got This!

At CyberSheath, we know that successfully implementing these new security controls can be a daunting undertaking for your organization. We’ve successfully assessed and implemented the required NIST 800-171 controls for organizations large and small in the defense industrial base supply chain. We’ll ensure your System Security Plan (SSP) and associated Plans of Action & Milestones (POA&M) are documented and fully implemented. Our cybersecurity experts will take care of all identified gaps in your information systems, schedule implementation of any outstanding items and ensure your organization is compliant with all of the latest requirements. We follow all DOD guidance to ensure review of SSPs and POA&Ms and “assist in prioritizing the implementation of security requirements not yet implemented.” After we have delivered a fully compliant solution we offer managed services to maintain your compliance and incorporate any updates from the DoD.

Contact CyberSheath today for a no-obligation phone consultation, and learn how we can ensure compliance with NIST SP 800-171 in five steps.

It’s time to demonstrate compliance with DFARS Clause 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting, which requires contractors to implement National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 Rev. 1, “Protecting Controlled Unclassified Information in Nonfederal Information Systems and Organizations”.

There is No Excuse for Non-compliance

Compliance with NIST SP 800-171 and DFARS clause 252.204-7012 is mission-critical for DoD contractors and demonstrating adherence to the requirements has become a competitive discriminator. For a deeper dive and a chance to ask questions specific to your implementation, please join us for the comprehensive webinar “NIST SP 800-171 DFARS clause 252.204-7012 Compliance in 5 Steps” on Thursday, March 29, 2018, 12:00 PM EST.

During the webinar you get answers to these critical questions and more:

  • Did the government extend the deadline?
  • How do I determine compliance with NIST SP 800-171 Rev. 1.?
  • What exactly does it mean to be compliant?
  • How do I know if I am already compliant?
  • What needs to be included in my System Security Plan (SSP)?
  • What are Plans of Actions & Milestones (POA&M’s)?
  • How do the controls apply to manufacturing environments?
  • Does NIST 800-171 apply to cloud computing?
  • How long will it take to achieve compliance?

No matter where you are in your journey towards NIST 800-171 compliance, this webinar is guaranteed to better equip you in understanding, implementing and maintaining compliance!

Achieving NIST SP 800-171 Rev. 1 compliance isn’t easy but the process doesn’t have to be complicated. If you need help staying competitive with this DoD mandate, contact us at sales@cybersheath.com.

 

It’s more important than ever to make sure your applications are secure. What tools are available to help in this effort – and what are the pros, cons, features, and benefits of these enablement tools?

In our previous post we set the stage for this discussion by covering the challenge application developers and their security teams face securing code in an efficient manner. Read about the impact securing (or not securing) application credentials can have on your organization and what you can do about it.

To continue our discussion, apps typically run in one of three network zone configurations. These include:

  • On-Prem – Apps that run in this space are your traditional applications, which usually run on physical machines or dedicated VMs. These apps have a long lifecycle.
  • Internal Cloud – Apps in this zone run on semi-elastic machines. Their lifecycle is much shorter than traditional servers and they are deployed much quicker than on-prem apps.
  • “The Cloud” – This zone exists outside the organization’s firewall. Apps in the cloud run on a very short-lived infrastructure, which is hosted by an outside vendor. These apps are deployed and destroyed auto-magically based on the application’s needs.

Whether you’re trying to meet DFARS, MAS, HIPPA, or NERC compliance, you have choices on where your apps run. Whichever environment meets your needs, CyberSheath has the resources to help keep your applications secure.

What you needHow CyberSheath can help
On-PremYour on-premise applications need to be just as secure as apps in the cloud.Depending on the way your application functions (homegrown code, services, scheduled tasks, IIS services), the CyberArk Enterprise Password Vault (EPV) has a feature for you. EPV is designed for:

  • Managing secrets.
  • Rotating passwords and keys.
  • Allowing humans and applications to fetch them for authorized tasks.
Your on-prem apps are developed on a platform like Java or C++.CyberArk’s Application Identity Manager can help. An agent, which serves as a credential provider, is installed on the local host. It:

  • Communicates between the application and the Vault, serving up the password each time it’s needed.
  • Is designed for high transaction volumes, and high availability.
  • Allows for seamless credential rotation with zero downtime.
  • Challenge: Agent workflow and management can be cumbersome.
Your on-prem applications rely on less hardcore code, but more scripting and basic Windows functions.The built-in remote management features of the Central Policy Manager are a good alternative.

  • Scheduled tasks, services, and IISAppPools running under a specific user can have that user’s password rotated automatically.
  • Challenge: Configuring the workflow for this is where most app teams get hung up.
Internal CloudYour apps running on an internal or private cloud tend to be less risk-oriented. These apps generally require faster deployment, have shorter return to operations (RTO) requirements, and need to be semi-elastic.CyberArk’s Central Credential Provider (CCP) is one recommended approach.

  • It allows app teams to make simple code changes.
  • Instead of an agent installed on a semi-elastic device, a web service call is made to retrieve the credential.
  • Identity can be established with a number of machine characteristics, in addition to client certificates.
  • Challenge: It can be difficult to define a clear and repeatable process to register applications and issue certificates to them.
“The Cloud”Your applications running on cloud infrastructure (a.k.a. the public cloud) generally require extremely high availability and elastic growth on demand.

Provisioning applications’ access to secrets at such quick speeds is challenging, which is why many organizations are hesitant to put apps in the cloud.

CyberArk’s Conjur, which is a DevOps security platform designed for cloud computing, can help.

  • As a cloud application itself, it conforms to the highly elastic nature of cloud applications.
  • It uses the concept of machine identity to establish trust that your app is who it says it is.
  • Using web calls (similar to CCP), Conjur serves up secrets to authorized applications.
  • No configuration is required for a new app instance. It’s built, has its authorizations, and it’s on its way.
  • Challenge: It’s not easy to create a system to import secrets or to build a methodology for developers to code in Conjur during their build process.

Contact CyberSheath to learn how we can help your organization secure your applications.

Are you a U.S. manufacturers who supply products within supply chains for the DOD? If you are it’s likely that you are required to ensure adequate security by implementing NIST SP 800-171 as part ensuring compliance with DFARS clause 252.204-7012, “Safeguarding Covered Defense Information and Cyber Incident Reporting,” available at:

http://www.acq.osd.mil/dpap/dars/dfars/html/current/252204.htm#252.204-7012

Manufacturing environments can pose unique challenges when implementing the 110 controls required by NIST 800-171 Rev. 1 and applying the controls to a production line can be daunting with the risk of business interruption often a click away. To de-risk the implementation of the NIST 800-171 Rev. 1 controls it’s recommended that you start with an assessment of your current operations (people, process, technology) against the NIST 800-171 Rev. 1 requirements. Finding a trusted third party with applicable manufacturing environment experience to execute your assessment can be a great way to jump start your compliance efforts. If you choose to so the assessment in-house one of the best resources, targeted to small manufacturers, is NIST Handbook 162 NIST MEP Cybersecurity Self-Assessment Handbook for Assessing NIST SP 800-171 Security Requirements in Response to DFARS Cybersecurity Requirements. Found here:

http://nvlpubs.nist.gov/nistpubs/hb/2017/NIST.HB.162.pdf

NIST SP 800-171 Rev. 1 assumes that small manufacturers currently have IT infrastructures in place, and it is not necessary to develop or acquire new systems to handle Controlled Unclassified Information (CUI). Small manufacturers likely have some security measures to protect their information which satisfy some of the 800-171 security requirements. For controls that are not currently satisfied there are many potential security solutions that can be implemented to satisfy the security requirements. There is no single security technology or solution that will meet all requirements. Manufacturers will need to understand their operating environment and apply the security requirements to meet their unique operations which should be reflected in their System Security Plan (SSP). Manufacturers often have unique operational requirements that run counter to some required controls and will have to implement alternative, but equally effective, security measures to satisfy a control requirements.

NIST Handbook 162 was developed by the National Institute of Standards and Technology (NIST) and Manufacturing Extension Partnership (MEP) collaboration committed to strengthening U.S. manufacturing. The Handbook provides a step-by-step guide to assessing a small manufacturer’s information systems against the security requirements in NIST SP 800-171 Rev 1, “Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations.” The handbook is intended for use by a small manufacturer and essentially walks manufacturers through conducting a self-assessment answering Yes, No, Partially, Does Not Apply or Alternative Approach to each control.

The Handbook includes an excellent section titled “Using this Handbook to Conduct an Assessment” which details the preparation and expectation setting before, during, and after an assessment. Often this is an overlooked step in the process as the desire to “just get compliant” informs most activities. While understandable, it’s a mistake to set compliance as the only outcome of a your NIST 800-171 Rev. 1 self-assessment.  When preparing for your self-assessment take the time to think about educating executives and business stakeholders on the compliance requirements and how you are going to earn their long-term support for this initiative.  There is no end state to NIST 800-171 Rev. 1 compliance and you should answer the following questions in soliciting executive support and sponsorship:

Does the business even know about this requirement for doing business with the Department of Defense (DoD)?

They might not. Now is your opportunity to educate them on the long-term implications of the requirements and help them begin to think about building the cost of compliance into the business plan.

Does the business understand the NIST 800-171 Rev. 1 impact on Acquisition? (for a detailed explanation see this blog post: http://www.cybersheath.com/understanding-nist-800-171-impact-acquisition/

At some point, you will need to demonstrate compliance in order to be competitive for future acquisition. Engaging the business now and getting ahead of that inevitability will pay dividends in the future.

How will you measure and communicate your self-assessment and overall compliance to the business?

Don’t make the mistake of only communicating the fact that you are undertaking a self-assessment. This is your opportunity to communicate your long-term approach to managing a NIST 800-171 Rev. 1 compliance program. Take the time to develop a strategy that includes:

  • Executing an Annual Assessment
  • Documenting your System Security Plan (SSP) and Plans of Action & Milestones (POA&M’s)
  • Implementing the required controls
  • Maintaining Compliance

Developing this strategy up front presents the opportunity to transform security from” order takers” to a business enabling function, don’t pass that up!

When you are ready to start your self-assessment using NIST Handbook 162 you will find descriptions of each control and importantly practical recommendations on how to assess your compliance with each control. The guidance included suggestions around who to talk to, where to look and what tests to perform when assessing control compliance. The recommendations should help you and your team work your way through each control and ultimately complete a thorough self-assessment.

Achieving NIST SP 800-171 Rev. 1 compliance for a manufacturing  business has its own unique challenges, most of which CyberSheath has already solved.  If you need help staying competitive with this DoD mandate, contact us at sales@cybersheath.com.

 

The December 31, 2017 deadline for creating a System Security Plan (SSP) and associated Plans of Action & Milestones (POA&Ms) aligned with NIST special publication 800-171 requirements has passed. If you are a DoD prime contractor, now it’s time to focus subcontractor compliance.

Subcontractor Compliance and CDI

DFARS 252.204-7012 (“the DFARS cyber clause”) compelled you to validate your own compliance status and address any cybersecurity gaps. As a prime, you have satisfied your in-house compliance obligations. Now it’s time to turn your attention to your subcontractors since the DFARS cyber clause must be flowed down to all suppliers or subcontractors that store, process and/or generate Covered Defense Information (“CDI”) as part of contract performance.

Keep in mind that CDI is defined as “unclassified controlled technical information or other information, as described in the Controlled Unclassified Information (CUI) Registry at http://www.archives.gov/cui/registry/category-list.html, that requires safeguarding or dissemination controls pursuant to and consistent with law, regulations, and Governmentwide policies, and is:

  1. Marked or otherwise identified in the contract, task order, or delivery order and provided to the contractor by or on behalf of DoD in support of the performance of the contract; or
  2. Collected, developed, received, transmitted, used, or stored by or on behalf of the contractor in support of the performance of the contract.

Controlled technical information is technical information with military or space application that is subject to controls on the access, use, reproduction, modification, performance, display, release, disclosure, or dissemination.”

How to Ensure Subcontractor Compliance

Subcontractors can achieve compliance with the NIST 800-171 Rev. 1 requirements in a variety of ways including flow down of the 252.204-7012 clause in subcontract documents that contain detailed communication with the specific requirements of the DFARS cyber clause. This includes the mandate for subcontractors to:

  • Create an SSP and associated POA&Ms.
  • Fully implement the requirements outlined in the clause and NIST 800-171.
  • Report non-compliance to the DoD CIOs office within 30 days after contract award.
  • Report cyber incidents within 72 hours.
  • Formally flow down the DFARS cyber clause to all lower-tier suppliers/subcontractors storing, processing, and/or generating CDI.
  • Be in full compliance with the DFARS cyber clause.

Remember that as a prime contractor, you are ultimately liable for the compliance of your suppliers and subcontractors. Make sure the flow down of requirements and the validation of compliance is a formal, documented, and repeatable process.

Also, if you are using an existing Governance, Risk, and Compliance (GRC) technology for other regulatory compliance requirements, you should be able to extend its use to cover DFARS 252.204-7012 subcontractor compliance. If you don’t have an existing GRC solution consider these alternatives:

  • Partner with a Managed Security Services Partner (MSSP) that offers a compliance and reporting capability specific to NIST 800-171. Many of the required controls can be mapped back to managed service offerings to produce automated compliance reporting.
  • Work with your contracting organization to create and implement a process that can be incorporated into the existing contracting business cycle. Contracts staff already play a key role related to subcontractor compliance for other contract clauses and adding DFARS 252.204-7012 requirements should be a logical fit.

Bottom line: It’s the prime contractor’s obligation to flow down DFARS 252.204-7012 requirements to all suppliers or subcontractors. Planning for success now is imperative.

If you need help complying with NIST SP 800-171, contact us at sales@cybersheath.com

 

As an owner of a small or mid-sized business, you have endless options available as you partner with a Managed Security Services Provider (MSSP) to better secure your business. The array of choices, industry jargon, and configurable service options can leave you wondering if you left something on the table that you will later regret. Without a team of security experts to vet vendor service offerings, the selection process is even more daunting.

How can you simplify the process and ensure that you are getting everything you need to be secure and compliant?

Maximize Your Chance of Success When Selecting an MSSP

  1. Document your requirements
    • Increase your likelihood of getting what you need by taking the time to compile this list. It will make you a smarter buyer and tremendously help you find the right resource for your needs.
    • Note that this doesn’t have to be a detailed spreadsheet of operational capabilities and Service Level Agreements (SLAs). You may opt to start with compliance issues as most businesses have specific regulatory requirements that they must satisfy including DFARS NIST 800-171, Payment Card Industry Data Security Standard (PCI DSS), Health Insurance Portability and Accountability Act (HIPAA), General Data Protection Regulation (GDPR), and many others.
    • Ask potential MSSP vendors how they can help your business to measure, satisfy, or simplify compliance with any of the above compliance requirements. MSSPs should possess in-depth knowledge of the requirements, use cases from existing customers, and references.
  2. Be ready to answer questions
    • Have a technical person and someone who understands your business available to answer questions around current security tools in place including how they are used, which users need what level of access, and existing business processes. A good MSSP will want to understand your business both in terms of your existing on-premise and cloud-based infrastructure and your actual business.
    • Trust your instincts and steer clear of sales pitches that focus on technology rather than your business requirements. Know that MSSPs who don’t ask the right questions and who push technology won’t be good long-term partners. There isn’t a tool on the planet that can make you secure. Ideally, your conversations will be with the MSSP operational staff rather than salespeople as operational folks will have the experience that can be applied to your business requirements.
  3. Make sure your MSSP enables security and compliance
    • Remember that operational security enables compliance. Drive your MSSP to explain how their proposed solution to your requirements can make your business both secure and compliant. Chances are you don’t have the time or resources to manage compliance as a separate activity from securing the company. Whatever you contract for should enable both operational security and compliance and the alignment between the two should be documented.
      • Example: If an MSSP is offering a Security Incident Event Management (SIEM) and log management capability, there should be a documented alignment of the capability delivered and your specific compliance requirements. You intuitively understand why you need a firewall and anti-virus protection, but make the MSSP demonstrate how that operational need maps to your compliance requirements to become a force multiplier.
    • Keep in mind that other examples of operational technologies that your MSSP should easily be able to map to your compliance requirements include:
      • Asset Discovery and Inventory
      • Vulnerability Assessment
      • Intrusion Detection
      • Behavioral Monitoring
      • SIEM and Log Management
  4. Vet your MSSP to ensure service delivery
    • Spend time examining your MSSP to be sure that you are they are going to deliver on the “service” part of being an MSSP. SLAs should be a part of your contract but there is an undocumented level of service that you should be getting from your MSSP that can’t be captured in an SLA.
    • Consider these things:
      • Are you comfortable with their technical expertise?
      • When you call, do you know if you’ll get a knowledgeable expert who goes the extra mile to solve your problems or a tier-one analyst who just opens a ticket?
      • When compliance questions relating to a business issue arise, will you find your MSSP to be a partner working with you to solve to problems?
      • Does the MSSP have clear value-added services that go beyond “management dashboards” that only demonstrate tools are being deployed?
    • Narrow your selection to responsive, service-oriented vendors during your procurement process. Many customers has been sold MSSP “services” that do little more than collect logs and monitor.
  5. Be diligent in checking references
    • Ask for references and take the time to call these contacts. Inquire about the reference’s experience during onboarding and delivery of services months after the sale was made. Is the MSSP still engaged and delivering value or do they only surface at contract renewal time?
    • See if your chosen MSSP has delivered any remediation or implementation projects as they are indicators of hands-on experience that will benefit your business. Ideally, references will be in the same business or industry as yours, but if everything else checks out this isn’t a necessity.

Partnering with an MSSP is a great way to secure your business infrastructure. To find out how quickly CyberSheath can enable 24/7 operational security and compliance reporting for your business, contact us at sales@cybersheath.com.

 

It’s time to demonstrate compliance with DFARS Clause 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting, which requires contractors to implement National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 Rev. 1 (NIST 800-171), “Protecting Controlled Unclassified Information in Nonfederal Information Systems and Organizations”.

There is No Excuse for Non-compliance

Originally Department of Defense (DoD) primes and subcontractors had until December 31, 2017, to demonstrate compliance with NIST 800-171. Recently, however, Ellen Lord, the defense undersecretary for acquisition, technology, and logistics told the Senate Armed Services Committee offered a bit of conflicting information. “We said that clearly, the only requirement for this year is to lay out what your plan is,” she said at the December 7th hearing. “That can be a very simple plan. We can help you with that plan. We can give you a template for that plan. Then just report your compliance with it.”

Bear in mind that those words are not an indication of all prevailing thoughts on the matter. Indeed, that guidance was contradicted by a Pentagon spokesman who said the change should not be considered a delay in the deadline since contractors must still document by December 31st how they will implement the new rules.

The clear takeaway is: This requirement for doing business with the DoD isn’t going away. Given the years of delays and widely available information regarding the requirements, there will be no excuse for non-compliance. The Director, Defense Pricing/Defense Procurement and Acquisition Policy issued guidance which articulates how compliance will be factored into acquisition which we explain here: http://www.cybersheath.com/understanding-nist-800-171-impact-acquisition/

4 Steps to Compliance with NIST 800-171

Note that these steps are not simple – you’ve got to put in the work to get the results. Another tip: Ignore vendors who are trying to sell you a product to easily achieve compliance, as such a solution does not exist. Many of the 110 controls of the NIST standard deal with the process – and how you implement the controls will be unique to your business.

To stay competitive in the DoD acquisition process and comply with NIST 800-171, you should (immediately):

  1. Assess current operations for compliance with NIST 800-171. – Starting with a gap assessment of your current people, process, and technology against compliance with NIST 800-171 is a useful step in achieving compliance. When done correctly an assessment will:
    • Directly link to Control 3.12.1 of NIST 800-171 which requires that you “periodically assess the security controls in organizational systems to determine if the controls are effective in their application.”
    • Give you a clear view of your current compliance with the remaining controls.
    • Generate a System Security Plan (SSP) and associated Plans of Action & Milestones (POA&Ms), both of which are NIST SP 800-171 requirements.
  1. Write your SSP & POA&Ms – NIST 800-171 was revised (Revision 1) in December 2016 to require a “system security plan (SSP)” and associated “plans of action (POA&Ms)”. Initially, your SSP will be an aspirational document as you will find that many of the required 110 NIST SP 800-171 controls are not fully implemented in your environment. Your POA&Ms will detail your plans to remediate deficiencies and achieve compliance. The requirements are:
    • Security Requirement 3.12.4 (System Security Plan, added by NIST 800-171), requires the contractor to develop, document, and periodically update, system security plans that describe system boundaries, system environments of operation, how security requirements are implemented, and the relationships with or connections to other systems.
    • Security Requirement 3.12.2 (Plans of Action), requires the contractor to develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in their systems.
    • Note that these plans can be documented in a variety of formats but at a minimum, they should detail:
      • The deficiency identified
      • The plan to correct the deficiency (people, process, and/or technology)
      • Dates by which you intend to be compliant against the specific deficiency
  2. Implement the required controls  – Execute your POA&M’s and achieve full compliance with NIST 800-171. This is probably going to be a full-time effort and if you are using only internal resources remember they all already have day jobs so set your expectations accordingly. If you work with a third party to implement the controls look for the following expertise:
    • Have they implemented the NIST 800-171 controls for similar-sized businesses?
    • Have they solved the unique challenges that come with implementing NIST 800-171 controls in manufacturing, lab, and engineering environments?
    • Ask for and check references.
  3. Maintain Compliance – If you have made it this far, congratulations! Now plan for ongoing compliance in a way that achieves the following:
    • Documented and automated compliance reporting
    • Support Request for Proposal (RFP) and other acquisition-related business development activities
    • Ongoing operational expense related to maintaining compliance

Compliance is a Journey – and Not a Destination

Your SSP will need to be updated as your business changes and specific control implementations need to be continually validated. If you have a Managed Security Services Partner (MSSP), have them map the work they do back to NIST 800-171 compliance for the appropriate controls and modify your contract to provide for periodic reporting. For the controls maintained by in-house staff, automate control validation and reporting so that you can demonstrate compliance on a real-time basis.

Achieving NIST 800-171 compliance isn’t easy but the process doesn’t have to be complicated. If you need help staying competitive with this DoD mandate, Contact Us at sales@cybersheath.com.

 

These days, it’s not easy to be in charge of your organization’s IT security. With cyberattacks increasing in frequency, severity, and reach, it’s more important than ever to develop a plan for achieving, managing, and documenting the security of all of your systems.

It’s Not Only Good Practice to Have a System Security Plan, but It’s Also a Requirement

NIST SP 800-17, Revision 1 recently added requirement 3.12.4 to the Security Assessment control family stating that organizations must “Develop, document, and periodically update system security plans that describe system boundaries, system environments of operation, how security requirements are implemented, and the relationships with or connections to other systems.”

This one-sentence requirement is based on NIST SP 800-18 – Guide for Developing Security Plans for Federal Information Systems.

Identify What Systems Need a System Security Plan

Now it’s time to figure out which systems in your organization require a System Security Plan (SSP). Each SSP should be focused on an information system, which is defined as “a discrete set of information resources organized for the collection, processing, maintenance, use, sharing, dissemination, or disposition of information.” An application, information or technology service, platform, and infrastructure are all considered systems, and their security must be formally planned according to the NIST SP 800-171 requirement for in-scope systems.

Compile your list of systems needing an SSP and start uncovering all the information you will need to write them. Each SSP will need two types of information, both of which can be a challenge to compile. These include:

  1. System details documenting how the system operates
  2. Details about how the NIST SP 800-171 Revision 1 controls requirements are met for that particular system. Note that the control statement responses are a granular system-specific response to the 110 control requirements.

Once you have your inventory of systems that store, process, or transmit Controlled Defense Information (CDI) or Controlled Unclassified Information (CUI), it’s time to start planning.

First, create a system security planning template. The appendix to NIST SP 800-18 – Guide for Developing Security Plans for Federal Information Systems has a template, which provides a great starting point for creating your organization’s SSPs.

Next, assemble your team for the planning process, making sure to include these roles:

  • System Owner – This role is critical to the system security planning process as this person has deep knowledge about the systems and understands what the system does, how it works, and how it is controlled. The system owner owns the security plan for the system and is responsible for providing diagrams and explanations that articulate where the sensitive data is stored at rest, where and how it is transmitted, and what system interfaces exist, especially those interfacing systems that transmit the sensitive (CDI and CUI) data.
  • IT/Security Support Staff – Depending on the size of your organization, your support team may provide a set of core IT services that provide control to the broader network and computing environment. Inheritable controls could include authentication services, firewalls, network segmentation, secure system baselining, access management, and change management. A system owner will work hand-in-hand with the support team to understand how and if the controls apply to his or her particular system.
  • Administrative/Business Operations Support Staff – Some controls that apply to systems may not be technical. Administrative and/or business operations staff will need to provide input into how non-technical controls, such as background screening processes, facility security mechanisms, training and awareness programs, and staff management controls, are addressed. The people who have ownership of these functional business capabilities will need to weigh in on the security planning effort so that controls are adequately defined.

Once you have the right people involved, it’s time to get to work and write the plan. It’s a laborious process, but the intent is to provide defensible information and responses as to how a system works and how security controls are applied. An auditor or contracting official will want to know how you safeguard their sensitive data, and the information you document along with control responses should provide assurance of that protection.

Create a Master SSP

Every system used for the storage, processing, and transmission of CDI/CUI should have a security plan. Think about the roles above and the functional areas they represent. If these roles exist as a core, corporate function that is applied consistently across the organization, then consider creating a master system security plan that documents a core set of controls meeting the NIST 800-171 requirements.

A Master SSP helps you define a standard across the enterprise for inheritable controls, which provides guidance to the system owners about how they may be consuming controls that are broadly applied to the organization. The effectiveness of using the master system security planning concept depends on how effective those broad controls are applied by mandate.

  • For those organizations who strictly apply their standards, the master system security planned controls would be thoroughly applied and relied on.
  • For those organizations looser about applying standards and mandates, a master system security plan makes a good reference, but system owners should pay close attention to whether they actually inherit the standard control offering, or if a system-specific control response is required.

Build Proactive Measures into Your SSPs

Developing your System Security Plan(s) will provide a systems-focused macro-view of how your security controls are being applied. The process also helps identify non-compliance and uncover insecure practices, alerting you and helping you create a plan to resolve issues.

Consider building your Plan of Actions & Milestones (POAM) into your SSPs, and track compliance deficiencies to resolution. This helps you be proactive in your remediation and corrective action planning and moves you closer to a mature state in managing security controls.

The CyberSheath team is experienced at helping organizations like yours create System Security Plans. Contact us to learn how we can help you.

As a contractor, you need to safeguard covered defense information that is processed or stored on your internal information system or network.

To stay in the running for work from your primes, you need to comply with DFARS Clause 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting, which requires contractors to implement National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171, “Protecting Controlled Unclassified Information in Nonfederal Information Systems and Organizations”. You have until December 31, 20 I 7 to implement NIST SP 800-171.

How will non-compliance with NIST SP 800-171 impact contractors’ future acquisition?

On September 21, 2017, The Director, Defense Pricing/Defense Procurement and Acquisition Policy issued guidance for acquisition personnel in anticipation of the December 31, 2017 deadline, which:

  • Outlines how contractors might implement NIST SP 800-171.
  • Addresses how a contractor may use a system security plan to document the implementation of the NIST SP 800-171 security requirements.
  • Describes how DoD organizations might choose to leverage the contractor’s system security plan (SSP), and any associated plans of action, in the contract formation, administration, and source selection processes.

To not jeopardize future opportunities, contractors should focus on developing a well-written SSP and associated Plan of Action and Milestones (POA&M) to achieve compliance.

What are the SSP and POA&M requirements?

NIST SP 800-171 was revised (Revision 1) in December 2016 to require a “system security plan” and associated “plans of action.” Specifically:

  • Security requirement 3.12.4 (System Security Plan, added by NIST SP 800-171, Revision 1), requires the contractor to develop, document, and periodically update, system security plans that describe system boundaries, system environments of operation, how security requirements are implemented, and the relationships with or connections to other systems.
  • Security Requirement 3.12.2 (Plans of Action), requires the contractor to develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in their systems.

How do you write an SSP and POA&M?

Documenting implementation of the NIST SP 800-171 security requirements by the December 31, 2017, implementation deadline requires an SSP and associated plans of action which describe how and when you will meet unimplemented security requirements, how you will implement planned mitigations, and how and when you will correct deficiencies and reduce or eliminate vulnerabilities in the systems. System security plans and plans of action can be documented as separate or combined documents. You should choose a format that integrates with existing business processes and can be easily maintained year-over-year. Governance, Risk, and Compliance platforms can provide a technical, somewhat automated capability to meet this objective.

There is no prescribed methodology for contractors to implement the requirements of NIST SP 800-171, or even to assess your current compliance with the requirements -nor is there a prescribed format for SSPs or POA&Ms. A reasonable first step in creating an SSP and POA&M is to use company personnel or a qualified third party to execute a gap assessment against current operations compared to the NIST SP 800-171 requirements. The gap assessment will detail changes to policy and highlight areas where additional hardware or software are required to achieve compliance. A well-executed gap assessment will determine:

  1. Requirements that can be met using in-house IT personnel.
  2. Requirements that can be met using outside assistance.
  3. Plan of Action and Milestones for achieving compliance.

Which version of NIST 800-171 applies?

DFARS Clause 252.204-7012 requires the contractor to implement the version of the NIST SP 800-171 that is in effect at the time of the solicitation, or such other version that is authorized by the contracting officer.

How do you inform the Government of compliance with NIST SP 800-171 requirements?

You can inform the Government of your implementation of the NIST SP 800-171 requirements in a number of ways.

  • The solicitation provision DFARS 252.204-7008, “Compliance with Safeguarding Covered Defense Information Controls,” provides that by submitting the offer, the contractor is representing its compliance (and provides a procedure for the contractor to request the DoD Chief Information Officer (CIO) to authorize a variance from any of those requirements as being non-applicable, or because the contractor has a different but equally effective security measure).
  • Paragraph (c)(2)(ii)(A) of DFARS Clause 252.204-7012 requires the contractor that is performing a contract awarded prior to October 1, 2017, to notify the DoD CIO of any requirements of NIST SP 800-171 that are not implemented at the time of contract award.

Keep in mind, the solicitation may require or allow elements of the system security plan, which documents the implementation of NIST SP 800-171, to be included with your technical proposal, and may be incorporated as part of the contract (e.g., via a Section H special contract requirement).

What is the role of the SSP and POA&M in contract formulation, administration, and source selection?

Chapter 3 of NIST SP 800-171, Revision 1, states that Federal agencies may consider the contractor’s system security plan and plans of action as critical inputs to an overall risk management decision to process, store, or transmit CUI on a system hosted by a nonfederal organization, and whether or not it is advisable to pursue an agreement or contract with the nonfederal organization.

DFARS Clause 252.204-7012 is not structured to require contractor implementation of NIST SP 800-171 as a mandatory evaluation factor in the source selection process, but the requiring activity is not precluded from using a company’s SSP and associated POA&Ms to evaluate the overall risk introduced by the state of the contractor’s internal information system or network.

The Director, Defense Pricing/Defense Procurement and Acquisition Policy guidance for acquisition personnel provide the following examples of how the government may utilize the system security plan and associated plans of action:

  • Using proposal instructions and corresponding evaluation specifics (detailed in sections L and M of the solicitation as well as the Source Selection Plan) regarding how implementation of NIST SP 800-171 (and other applicable security measures) will be used by DoD to determine whether it is an acceptable or unacceptable risk to process, store, or transmit covered defense information on a system hosted by the offeror. The solicitation must notify the offeror whether and how its approach to protecting covered defense information and providing adequate security in accordance with DFARS 252.204-7012 will be evaluated in the solicitation.
  • Establishing compliance with DFARS 252.204-7012 as a separate technical evaluation factor and notifying the offeror that its approach to providing adequate security will be evaluated in the source selection process. The specifics of how the offeror’s implementation of NIST SP 800-171 will be evaluated must be detailed in Sections L and M of the solicitation as well as the Source Selection Plan.  If you are behind in implementing the required controls of NIST SP 800-171, are unsure of how to write your SSP and POA&M’s, or need expert help complying with the requirements, Contact CyberSheath at NIST800171@cybersheath.com for immediate assistance.

As a subcontractor on a Department of Defense contract, you have likely had flow down requirements from your primes related to DFARS clause 252.204-7012, commonly referred to as NIST 800-171. Many subcontractors, as they scramble to secure their infrastructure to be in compliance before the December 2017 DFARS deadline, are also asking, “When should DFARS clause 252.204-7012 flow down to our subcontractors?”

To help you answer that question, here are some basics related to DFARS clause 252.204-7012: Safeguarding Covered Defense Information and Cyber Incident Reporting (effective October 21, 2016) and NIST 800-171.

The Basics of DFARS Clause 252.204-7012

This clause is required in all contracts except for those contracts solely for the acquisition of COTS items. It requires contractors and subcontractors to:

  1. Safeguard covered defense information (CDI) that is resident on or transiting through a contractor’s internal information system or network.
  2. Report cyber incidents that affect covered defense information or that impact the contractor’s ability to perform requirements designated as operationally critical support.
  3. Submit malicious software discovered and isolated in connection with a reported cyber incident to the DoD Cyber Crime Center.
  4. If requested, submit media and additional information for damage assessment.

What is Covered Defense Information (CDI)?

This term is used to identify information that requires protection under DFARS Clause 252.204-7012. Covered defense information is unclassified controlled technical information (CTI) or other information as described in the controlled unclassified information (CUI) Registry that requires safeguarding or dissemination controls*, and is either:

  • Marked or otherwise identified in the contract, task order, or delivery order and provided to the contractor by or on behalf of DoD, in support of the performance of the contract or
  • Collected, developed, received, transmitted, used, or stored by or on behalf of the contractor, in support of the performance of the contract.

* Pursuant to and consistent with law, regulations, and Government-wide policies

Does DFARS clause 252.204-7012 flow down to subcontractors?

The clause impacts subcontractors when performance will involve operationally critical support or CDI. You should determine in consultation with your contracting officer if necessary if the information required for subcontractor performance is or retains its identify as CDI, and requires safeguarding or dissemination controls. Flowdown is to be enforced by the prime contractor. If a subcontractor does not agree to comply with the clause, CDI should not be on that subcontractor’s information system.

What does DFARS Clause 252.204-7012 require?

Simply stated, this DFARS clause mandates adequate security. The contractor shall provide sufficient security on all covered contractor information systems. To provide satisfactory security for covered contractor information systems that are not part of an IT service or system operated on behalf of the Government, at a minimum, the contractor must implement NIST SP 800-171, as soon as practical, but no later than December 31, 2017.

What is NIST SP 800-171?

This standard:

  • Enables contractors to comply using systems and practices likely already in place.
  • Significantly reduces unnecessary specificity, as requirements are performance-based, and more easily applied to existing systems.
  • Provides a standardized, uniform set of requirements for all CUI security needs.
  • Allows non-federal organizations to consistently implement safeguards for the protection of CUI (i.e., one CUI solution for all customers).
  • Allows contractors to implement alternative, but equally effective, security measures to satisfy CUI security requirements.

If you are struggling with interpreting these requirements or need help implementing the security controls, CyberSheath can help you determine a path forward for achieving compliance ahead of the December deadline by conducting a gap assessment of your compliance with NIST 800-171, writing the required System Security Plan (SSP) and leading your remediation efforts.

There are less than 100 days left until the mandatory compliance deadline for implementing the DFARS required controls of NIST 800-171. Is your organization ready?

If you have been focusing on other strategic business initiatives and have not yet dedicated resources to NIST 800-171 compliance, you still have time. It will take a lot of work, but your organization can have a documented plan in place to guide your efforts and make material gains towards compliance this quarter.


Month-by-Month DFARS Compliance Guide

To remain competitive in your pursuit of new contracts with the Department of Defense, you should:

  1. Assess your current state and create an implementation plan for your needed controls.
  2. Formulate a DFARS-required System Security Plan (SSP).
  3. Achieve DFARS compliance.

Here’s how to accomplish that by the end of 2017.

October

  • Conduct security assessment – You might be tempted to save time and skip this step – but don’t assume that you already know what work needs to be done. Execute an internally or externally-led gap assessment against the fourteen families of controls in NIST 800-171. Document your compliance with each family of controls. Be sure to record the people, processes, technologies, and related artifacts involved and demonstrate that your security program is implementing the required controls as a part of your day-to-day operations.
  • Unsure of how to proceed? Work with a vendor – If you are struggling with the interpretation of the controls, enlist the help of a skilled outside party to execute the gap assessment.
    • Find a vendor – Look for a services provider with specific NIST 800-171 experience, both assessing compliance and implementing remediation programs to achieve compliance. Get references and make the vendor provide proof of past success in helping defense contractors achieve compliance. Query the vendor about the deliverable from the assessment and be clear that you are looking for more than best practice recommendations – you require information specific to your internal operations.
    • Leverage the third-party vendor to engage your executive team – Have your vendor work with your executives and get answers to the inevitable questions around DFARS compliance. You probably have already had a talented team that has been briefing NIST 800-171 internally for some time. Often the same message from a trusted third party with past experience can jumpstart the conversation at the executive level and secure the support your team needs.

November and December

  • Create a project plan and start implementing controls – Using the results of your gap assessment, create a project plan and start implementing controls that don’t currently exist in your organization and remediating the ones that fall short of meeting the requirements.
  • Be proactive in engaging procurement – If you have to purchase tools or engage a third party to assist in remediation, make sure that your purchasing is streamlined. With less than 100 days left there is little time for delays related to procurement processing. Ideally, you will have already spent time to get executive buy-in on this effort and have created the required sense of urgency around meeting the December compliance deadline.
  • Start writing your SSP – In parallel to your remediation efforts, start writing your SSP. It’s a requirement of compliance – and it will force you to be strategic about long-term compliance and not get lost in the tactical details of getting specific controls implemented before December. Your SSP should be a true reflection of your NIST 800-171 compliance program. You should plan to review and update this document annually.

CyberSheath is skilled at performing security assessments, creating remediation plans, writing SSPs, and most importantly actually implementing the required controls. If you need assistance achieving DFARS compliance before the deadline, Contact Us today.

In less than five months your organization needs to be DFARS NIST 800-171 compliant. If you have already formulated a remediation plan to help you address your deficiencies, continue working through your prioritized roadmap to meet the compliance deadline. If you haven’t yet begun planning, get started today. Don’t jeopardize your ability to secure and execute DoD contracts by being non-compliant.

Three Areas to Focus on as You Craft Your Compliance Roadmap

After you’ve assessed your organization against the 110 security controls in NIST 800-171, you’ll need to build a plan to address your compliance gaps. An effective plan will have components that address these three areas.

  1. Multi-Factor authentication
    • What it is: Multi-Factor authentication (MFA) is a security measure where more than one method of authentication from independent categories of credentials is required to verify the user’s identity for a login or other transaction. It is an important component of any security plan as increasing authentication from a single factor greatly improves the security of your systems.
    • What you need to do: Procure an identification and authentication service that complies with the DFARS security requirements. Make sure the MFA solution is scoped and implemented to address the unique requirements of your environment. Also, work with stakeholders and end-users to conduct use-case and validity testing. Integrate with your authentication management processes to administer the user lifecycle. Make sure you have access to training, maintenance, and support of your solution.
  1. Privileged Account Management
    • What it is: Privileged account management (PAM) is managing and auditing account and data access by privileged users, who are individuals with administrative access to critical systems. Better managing access to privileged accounts can help prevent cyber adversaries and rogue insiders from going after privileged credentials as a way to gain broad and undetected access to your information systems.
    • What you need to do: Ensure your PAM solution provides automated, monitored, and controlled privileged access. Elevate administrative access to avoid granting excessive access to privileged accounts. Require the verification of a ticket or an approval to ensure administrative access is only granted when it is required for a specific activity. Work with engineers who are well versed in fine-tuning the configuration of the PAM suite and who can provide technical expertise and customization for your unique project.
  1. Vulnerability Management
    • What it is: Vulnerability management is the cyclical practice of identifying, classifying, remediating, and mitigating vulnerabilities in your security infrastructure. It is important that your organization continually be monitoring for vulnerabilities to ensure you stay ahead of potential threats.
    • What you need to do: A DFARS compliant vulnerability management program will continuously assess your environment for vulnerabilities and patch compliance. Make sure your solution performs monthly vulnerability scans, as well as scans after any significant changes are made, of all your internal and public-facing systems. Also, ensure you receive a monthly report detailing new findings and findings from the previous month(s) which have yet to be remediated. Verify implementation of patches or workarounds for each fix with follow-up scans as needed.

Plan, Provision, and Outsource if Needed to Meet the December 31, 2017 Deadline

Determine what you can reasonably accomplish with your internal resources and what you need to outsource to meet the December deadline. Also, as part of your roadmap, make sure you plan for a post-compliance world where you need to maintain the controls you’ve implemented.

Regardless of where you are in your DFARS compliance process, time is of the essence. Continue your efforts or get started now – five months is not much time to affect the change mandated by NIST 800-171 compliance.

If you need support, contact us for a FREE consultation.

Achieving compliance with NIST 800-171 before the mandatory December 2017 deadline can look like a daunting task. With only 6 months left in the year, time is running out to understand, evaluate, and implement the more than 100 DFARS controls. Where do you start – and how do you efficiently deploy resources to ensure success?

Here are 4 Simple Steps to Assess, Implement, Measure, and Maintain Compliance

  1. Conduct a gap assessment of your current security program. Using a trusted third party or internal resources, perform a binary, pass/fail assessment and make sure results are supported by artifacts and technical validation. Taking a pass or fail approach to each required control ensures an honest assessment and efficient process. Countless vendors have “proprietary” assessment methodologies that are ultimately subjective marketing documents. The NIST 800-171 controls are either implemented or they aren’t. This approach saves you time and endless debate that doesn’t move the needle on compliance.
  2. Turn your gap analysis into a remediation plan. Review your assessment results and start the process of remediating non-compliant controls. The project plan should identify the people, processes, and products required for control implementation. Your plan should be a “project management 101” kind of document that gives you a realistic view of cost, schedule, and performance. If you have budget constraints, look for opportunities to implement manual processes until you can automate with tools. Be sure to account for the documentation of your policies and processes as part of the plan.
  3. Execute your plan. Run your implementation of NIST 800-171 like a project with dedicated internal or third party resources if the workload requires them. Track project progress weekly and keep management informed. Be sure that after a control is fully implemented you have a way to continuously measure compliance. Like any other regulatory mandate, DFARS compliance is an ongoing requirement and not a one-time effort. This monitoring can be done manually or with a GRC (Governance, Risk, and Compliance) tool like RSA Archer or TraceCSO. If you are budget-constrained, use Excel or SharePoint to get the job done.
  4. Maintain compliance across your enterprise. Implement dashboard views of near real-time compliance and a process for on-boarding new contracts with CUI/CDI (Controlled Unclassified Information/Covered Defense Information). Budget for and perform an annual assessment to validate your compliance.

The Bottom Line

NIST 800-171 is an effective cybersecurity hygiene guide for DoD contractors. Controls like multi-factor authentication and encryption are heavy lifts initially but relatively easy to maintain after implementation. The interpretation of the controls may seem intimidating, but the pragmatic approach laid out above will go a long way in helping you meet the December 2017 deadline.

Get started! It’s likely your team is already overburdened with other work and adding this to their plate with only 6 months of the year remaining won’t be easy. That’s why CyberSheath exists. We’ve helped dozens of global companies achieve compliance – and we can help your organization too. Contact CyberSheath today for a FREE consultation.

There’s a lot at stake right now with your company’s DFARS / NIST 800-171 compliance. What you do – or don’t do – in the next six months could impact your ability to secure and execute DoD contracts.

Is your company compliant with all 110 security controls in NIST 800-171?

As a supplier, chances are you’ve received a letter from one of your Prime’s asking if you are compliant with the DFARS mandate and reminding you of the compliance deadline of December 31, 2017. If your Prime uses Exostar as their sourcing and collaboration tool as the major Defense Contractors do, you will have to fill out a DFARS questionnaire before a PO can be issued for your part of the contract.

There are three ways to handle the situation:

  • Misrepresent the truth about your organization’s infrastructure security and answer the questionnaire in a knowingly untruthful way and claim compliance in the hopes that the truth is never discovered and that your firm is never flagged for a security audit.
  • Determine where you are non-compliant and develop a plan to become compliant by year’s end.
  • Write a letter to the DoD explaining where you are not compliant, and why.

Of these options, I think we can agree that the first is ill-advised, and the third is not a way to build trust and foster confidence in your firm. That leaves the second option – becoming compliant. How do you proceed?

What exactly is the DFARS mandate and why it’s important?

NIST Special Publication 800-171 Protecting Covered Defense Information in Nonfederal Systems and Organizations, otherwise known as DFARS (Defense Federal Acquisition Regulation Supplement), details the fourteen families of security requirements for protecting the confidentiality of Covered Defense Information (CDI). This document outlines each of the controls your firm needs to meet in order to be able to continue providing services and products to your Prime and ultimately to the DoD.

The fact is, the controls outlined in DFARS are security measures that your firm should already be implementing as part of maintaining good security hygiene. Each item on the checklist helps your firm safeguard important information and, ultimately, helps your firm protect the confidentiality of CDI.

What should you do to keep your current contracts?

Right now your firm is probably compliant with about half of the 110 controls within NIST 800-171. Chances are the areas your company is deficient in include:

  • SIEM (security information and event management)
  • Multi-factor authentication
  • Applied encryption, both at rest and in-transit
  • Policies and written authentication for your security procedures and protocol

While addressing these deficiencies may seem onerous, it’s important to remember that becoming compliant is good for your company – and good for your bottom line. Perhaps you think you don’t have the resources, budget, or buy-in needed to move forward. Keep in mind that the path to compliance is the only viable option you have. Here is a plan on how to address and achieve DFARS compliance:

  • Get a security assessment to help you interpret what is required and if your company is in compliance with each of the 110 controls.
  • Create a plan to achieve compliance on all the items identified as deficient in your security assessment. Your remediation plan should solve for operational issues as well as protect covered defense information in a manner that demonstrably shows compliance. Note that remediation typically takes about 6 months – so you need to get started now.
  • Partner with a trusted, experienced company that:
    • Has truly walked a mile in your shoes and has experience implementing the controls required for DFARS compliance.
    • Tailors the control implementations to fit your reality and achieve compliance.
    • Understands the practical realities of implementing controls like multi-factor authentication in an operational environment on a limited budget.

CyberSheath uniquely understands the DFARS security requirements and can assist you with assessing compliance with these DoD mandated security requirements and creating a road map of how you can become compliant by December 31, 2017.

The clock is ticking. Get started on your DFARS compliance today.

Don’t scramble to do research to address your security shortcomings. Get your current security state assessed now and formulate a plan to become compliant – before your Primes come to hold you accountable to this new mandate.

Contact us today for a FREE consultation and we’ll make sure you have a strong cybersecurity defense strategy!

In December of 2016 the National Institute of Standards and Technology (NIST) finalized the first revision to it’s Special Publication 800-171, Protecting Controlled Unclassified Information (CUI) in Systems and Organizations. The updated document, NIST SP 800-171 Revision 1 is the new standard for which government contractors who store, transmit or process CUI, are required to comply with by the December 2017 deadline for compliance.

While many of the updates are verbiage changes to clarify the defined scope of the current controls, there are two major changes that need to be noted by those who are required to adhere to the regulation.

In the original 800-171 release, Control 3.1.19 specified the requirement to encrypt CUI on mobile devices. In the updated revision, the control is amended with the additional stipulation to include mobile computing platforms. Further, mobile devices and mobile platforms are more clearly defined to include smartphones, tablets, E-readers, and notebook computers. This additional specification is intended to remove any doubt as to the scope of the control. Encryption of mobile devices and mobile computing platforms is an instrumental step to help limit a data breach as these devices are often lost or stolen. If you are interested in additional information I have covered the importance and scope of the encryption of data at rest requirements required by the 800-171 in a previous blog post.

At the time of the original release, in June of 2015, NIST SP 800-171 was published with 14 Control Families which contained 109 security controls in total. The newly released revision publication has added just one control bringing the total number to 110. This added requirement is contained in the Security Assessment Control Family (3.12) and is defined as follows:

3.12.4-  Develop, document, and periodically update system security plans that describe system boundaries, system environments of operation, how security requirements are implemented, and the relationships with or connections to other systems.

Additionally, SP 800-171 Rev 1 notes there is no prescribed format or a specified level of detail for ‘system security plans’. However, organizations must ensure the required information in Control 3.12.4 is appropriately conveyed in the plans that are developed.

Aside from the requirement being imposed to have a formally documented security plan, having such a plan is a good indicator of the maturity of your organization’s overall security program. No matter how large or small your company is, it is important to have a plan to define the security of your information assets. The plan development process will help make you think more holistically about your organization’s security and will bring the many elements of your security model to one place. This will help provide the framework for keeping your company at the desired security level required by the 800-171.

It is important to understand the new control requires the following components in a security plan:

  • Documentation of its systems and environments of operation, including boundaries
  • Description of how security measures are implemented to satisfy the controls of the regulation
  • Definition of relationships with, and/or connections to other integrated systems

While these elements meet the minimum requirements for the new control, it is imperative to recognize this is only a baseline. A security program plan is never ‘done’ per se and should be a living document. The new control further reinforces that thought by requiring organizations to ‘periodically update’ the plan. This concept is also true for the 800-171 regulation itself, shown with the release of the current revision we are discussing. The ever-changing nature of the document ensures your organization is continuously adapting to the dynamic IT environment and the associated threats that we are faced with every day.

Does your organization need assistance becoming compliant with NIST SP 800-171 before the December 2017 DFARS compliance deadline? CyberSheath has the expertise to provide you with the specialized guidance you need and deliver industry-leading solutions. We have a specialized team of Cybersecurity Professionals with proven experience to guide and assist your business in achieving compliance.

Contact us today for a FREE consultation and we’ll make sure you have a strong cybersecurity defense strategy!

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