Understanding the difference between Classified and Unclassified Information

Partnerships with the US Department of Defense may be enormously beneficial either as a supplier or vendor. After all, the Defense Industrial Base is a large market composed of around 200,000 enterprises.

Obviously, the Department of Defense is careful about who it partners with. After all, state-sponsored malicious hackers are becoming more common, and the Department of Defense is a favored target.

In the interest of national security, the Department of Defense should do everything necessary to mitigate these threats. As a result, they set tight requirements for data protection, security, and confidentiality. Before receiving requests for proposals, any organization that wants to partner with the DoD should be cybersecurity compliant and consult CMMC consulting firms.

The DFARS 252.204-7012 provision mandates that any entity that handles ‘controlled unclassified information,’ or CUI, follow the NIST 800-171 requirements. This is a worldwide recognized administrative system that defines 110 controls spread over 14 areas, such as authentication, access control, and physical protection. By complying with these regulations, your company can participate in, and perhaps win, DoD RFPs.

DFARS adherence extends to any company that collects, maintains, or distributes CUI on account of the Department of Defense. However, it is not always obvious what information is classified as CUI.

Classified and Unclassified Information

In the mass press, classified material receives more spotlight and attention. CUI is not synonymous with classified information. Whereas classified information refers to things like state secret information, CUI can alternatively be regarded as critical but unregulated or for authorized use only. In other words, the material is not highly classified, but it must still be kept secure against unwanted access or use.

Federal agencies, such as the Department of Defense, frequently create, utilize, and exchange sensitive data that does not explicitly relate to national security or nuclear technology.

This might contain personally identifiable information (PII) about government personnel, technical knowledge about development and engineering, and information about data system vulnerabilities. The Department of Defense, like private enterprises and other government agencies, frequently delegates the care and maintenance of this data to vendors, who may communicate it with subordinates if their contracts permit it.

For example, if your company is an accounting firm that interacts with government agencies, you will be dealing with CUI such as financial and personal information on federal workers. This information must also be secured per other industry requirements. DFARS aims to harmonize controls and match them with other federal and state requirements. As a result, if you already have a high degree of cybersecurity maturity, you should be able to pass a DFARS internal audit with ease.

Why is an organization-wide vulnerability analysis required?

If you have any agreements with government agencies, you are most certainly already required to follow the NIST 800-171 rules. You may validate this by reviewing your deals for the CMMC compliance DFARS 252.204-7012 provision. Even though you do not have a legal need to comply, doing so is highly recommended. Whether or whether you wish to compete on DoD RFPs, becoming certified will allow you to attain and show a better level of information security.

If your company is a private contractor to a DoD vendor, it may not be immediately evident if or not your equipment manages CUI. Likewise, your agreements with the DoD do not indicate your systems can manage CUI. However, because every federal contracting party will have contracts referencing the DFARS 7012 language, it makes no difference in compliance.

These are just a few additional reasons to assess your current information ecosystem thoroughly. A thorough examination of your current environment will disclose the data you manage, the technologies you employ, and the security policies in place to secure them.

How to effectively Implement Cybersecurity Maturity Model Certification for Cybersecurity?

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.

What are CMMC Framework and NIST Cybersecurity Framework and How to Comply?

The Cybersecurity Maturity Model Certification (CMMC) is a uniform cybersecurity benchmark designed to improve the security preparedness of government supply chain enterprises.

The Defense Department is gradually shifting from the NIST 800-171 standard to the CMMC requirement. By 2026, all new DoD agreements must be CMMC compliant.

The CMMC qualification applies to DoD contractors and subcontractors at any level of subcontracting.

The CMMC framework has three degrees of maturity.

  • Level 1 – Fundamentals
  • Level 2 – Advanced 
  • Level 3 – Expert 

DoD contracts specify the level (one, two, or three) a defense contractor must fulfill to propose or operate under an agreement. A supplier operating for a primary contractor may not have to satisfy the same standards as the prime. For instance, a prime may need to be at Level 2 to win a contract, while a supplier to a prime may just need to be at Level 1 if that vendor never gets or touches data that must be secured.

The distinction between NIST SP 800-171 and CMMC

Consider NIST 800-171 to be the cornerstone for CMMC. NIST 800-171 has 14 families of requirements, with a total of 110 distinct criteria spread among the 14 families. The CMMC model is made up of 14 domains that correspond to the families stated in NIST SP 800-171.

There is a clear association between NIST 800-171 criteria and CMMC Level 2. 

How Does a Company Know If It Needs to Meet CMMC?

You must be qualified to CMMC at the agreement award period for projects that require subcontractors to fulfill CMMC. Before that, a contractor can demand you to be licensed at the bid time.

If a contract needs CMMC, it will be specified in sections C and L of the RFP.

How to Meet the CMMC Requirements?

Your approach to CMMC compliance will differ depending on whether you are safeguarding FCI or CUI, as well as the relevance of the project in which you are partaking.

DoD companies at the Level 1 CMMC level can self-attest to CMMC.

Some Level 2 CMMCs can self-attest, while others will require an independent examination.

A government-led evaluation will be required for all Level 3 CMMC organizations.

Level 2 enterprises that require an external evaluation must collaborate with a “CMMC Third Party Assessment Organization,” or C3PAO, which is an authorized and impartial third-party institution.

A list of accredited C3PAOs competent to undertake CMMC assessments may be found on the CMMC Accreditation Body’s website (CMMC-AB).

The following is the procedure for achieving CMMC compliance:

  • Determine the CMMC level you intend to achieve.
  • Internally, prepare to meet the chosen standard.
  • Choose a C3PAO from the Marketplace of CMMC Accreditation Bodies (CMMC-AB).
  • Hire a C3PAO to do the evaluation.
  • The C3PAO sends the assessment to the CMMC-AB for consideration.
  • Your firm has received certification.

How to become CMMC compliant?

Follow these steps to prepare your organization to bid on future federal contracts with CMMC criteria.

Examine any present government agreements under which you are operating to establish the level of qualification required in a future contract. Your federal agent, prime contractor, or supplier may be able to help you with this.

At the very least, you must meet CMMC Level 1.

Look for strategies to minimize the quantity of CUI you get in executing a contract if you handle CUI. Try to limit the CUI you acquire to only the information you need to execute your job. The fewer CUI you have, the easier it is to keep it safe.