People are seeking a CMMC compliance guideline that advises them on what they must do or acquire to achieve compliance because of the deployment of CMMC criteria that began in November 2020. There is no “set it once” approach to CMMC compliance. Instead, tackling the work from the top down, defining your obedience at the highest level of the business, beginning with official policy, is what makes CMMC initiative successful. Since CMMC compliance is complex, DoD contractors should rely on MSSP for IT services for government contractors.
As the Department of Defense (DoD) transitions from the NIST 800-171 mandate to CMMC, there is increased interest in discovering compliant IT solutions that will make it simple for Organizations Seeking Compliance (OSC) to fulfill CMMC.
Some systems can meet the most stringent cybersecurity needs. However, there is no readymade CMMC-compatible solution in particular. To be CMMC certified, an IT system must use the appropriate technology in conjunction with the appropriate processes for controlling FCI and CUI. The DoD contract under which you operate will define the degree of CMMC you must fulfill and whether you must safeguard FCI or CUI.
FCI (Federal Contract Information) is information provided by or generated for the Police under a contract to develop or produce a good or service for the Government but does not encompass data provided by the Government to the general public or simple transaction data, such as that needed to process disbursements. This data has not been declared as public or for public dissemination.
CUI (Controlled Unclassified Information) is described as information generated by the administration or an institution acting on its behest that is unclassified but requires protection. CUI is sensitive and vital information to the objectives of the United States and perhaps its national security, although the federal govt does not rigidly control it. This is data stored on your company’s private systems.
Email, electronic files, plans, drawings, private corporate or contractor details (such as sales invoices and agreements), and physical documents are all types of CUI. It is critical to realize that CUI security rules do not apply just to digital data; CUI can also relate to printed copies that are “produced from an information network that analyzes or saves electronic documents transferred or saved in the database, workstations, notebooks, mobile devices, etc.”
A Lifecycle Approach to Security Controls
You should adopt a lifecycle strategy for security with any IT platform, defining your rules and specifying authorized methods to control CUI inside the platform. Moving ahead, ensure that you evaluate and verify the systems and conduct a management review regularly.
Consider compliance as a lifecycle rather than just another instrument to be acquired.
Two Critical Factors That Make an IT System CMMC Compliant
A system must meet two criteria to be CMMC compliant:
- FIPS-validated cryptography is used.
- Correct procedures for dealing with CUI.
Compliance is Not a Product.
It’s enticing to imagine that you can acquire the ideal software to achieve compliance. Instead, IT solutions and services companies propose that their clients adopt a staged approach.
To understand your current environment, do an evaluation (either yourself or with the assistance of a third party).
Create a System Security Plan (SSP) and an Action Plan with Milestones (POA&M).
As required by DFARS 252.204-7019, submit your SSP and POA&M to the DoD Supplier Performance Risk System (SPRS).
Work to close any security vulnerabilities, beginning with the most significant risk and working your way down.
A plan based on the security lifecycle is required for the optimum cost-effective manner to satisfy compliance. You must comprehend the implications for revenue and company operations.