Cybersecurity threats have been the biggest concern for businesses in recent times. Government agencies are also at risk, and it is perhaps even more daunting for them. Since the U.S. Defense Department works with thousands of contractors, there is a need to go the extra mile to ensure their end security. A cyber incident with these providers can put the sensitive DoD information at stake, leading to a threat to national security.
The Department has taken a tangible step to safeguard itself from such risks by rolling out the Cybersecurity Maturity Model Certification in 2020. Defense contractors dealing with the department will have to enforce this model across their operations to ensure safety. The DoD aims to make CMMC a standard for its contracts by 2026, although all contractors have to obtain it to be eligible for a DoD contract right now. It means they need to be ready for compliance. Here are the steps you need to follow to gear up as a contractor.
Understand that security is your responsibility
Before the release of CMMC, contractors already had to implement, monitor, and certify the security of their IT systems and the sensitive DoD data on them. They could self-attest that they were compliant with DoD security requirements. The responsibility continues under CMMC requirements. However, contractors’ compliance will now be assessed by a Certified 3rd Party Assessor Organization (CP3AO). Every contractor within the defense supply chain will have to comply with CMMC requirements. Whether you offer lawn care services, provide training and research services as a higher education institution or supply satellites, compliance is non-negotiable.
Know the compliance levels and journey
Essentially, the CMMC has five certification levels that cover the best cybersecurity practices for each contract. These include-
- Level 1- Basic cyber hygiene practices and sensitive data management
- Level 2- Protection of Controlled Unclassified Information (CUI)
- Level 3- Practices to safeguard CUI, which include the NIST 800-171
- Level 4- Practices for advanced persistent threats (APT) procedures and techniques
- Level 5- Implementation of sophisticated capabilities to identify and respond to APTs
A Maturity Level 1 certification includes 17 requirements, while Maturity Level 2 includes additional 110 practices. The numbers increase as you move to the higher levels, although the choice of the level differs for different contractors. The length of the journey depends on your starting point and the maturity level you seek to reach. Typically, you can expect the entire process to take 12 to 18 months, so ensure you have as much time to invest.
Find a compliance partner
Since much is included in each maturity level of CMMC, you cannot expect to look after the technical details on your own. Things can get even more daunting if you run a small business with limited technical expertise. The last thing you want is to lose a DoD contract just because you are not ready for compliance. Thankfully, you can rely on a CMMC compliance partner to help. Even better, look for a provider that covers you with hardware and software solutions, managed services, and cybersecurity. With an expert taking care of your technology and security, you need not worry about getting through the third-party audit by C3PAO. You can schedule an assessment confidently with a reliable partner mitigating the risks to your company and government information and data.
Assess your CUI
Finding a compliance partner gives you a good start with the process. But you must do your bit by identifying the data requiring protection. The model covers controlled unclassified information (CUI) residing in non-federal IT systems. It includes the following-
- Sensitive intelligence information
- Information related to law enforcement and legal actions
- Tax-related information
- Patents and other intellectual property
Besides these elements, you may need to protect much more. Ideally, you must engage in a holistic analysis of your systems to identify the data subject to CMMC. Only after picking the elements to be protected, it is possible to right-size your approach to bring it under full compliance for CMMC certification.
Identify internal stakeholders
Although you may rely on experts to implement the compliance requirements for your organization, someone from within must also take the onus. Small to mid-sized companies can identify the primary stakeholders to drive the initiative. An executive sponsor must provide oversight, allocate funding, and keep track of activities. You can manage cybersecurity without a dedicated in-house IT team by outsourcing compliance services. However, both teams should collaborate closely, and a few stakeholders must monitor the collaboration to ensure a seamless journey. This way, you can set up your company to breeze through the audit.
Perform a mock assessment
Having an expert partner working closely with your team gives you confidence about getting the contract after a CMMC assessment. But you should not take things for granted. Performing a mock assessment before going for a real one is a good idea. Consider having a trained professional looking at the documentation of gap analysis. You can test systems and conduct interviews to validate adherence to all requirements set by the certification assessment. Discuss the option with your technical partner and go ahead with it before the audit. It is equally important to include your subcontractors in the compliance and mock assessment test because CMMC requirements flow down the entire supply chain. Complying at your end does not guarantee a favorable result unless you include your subcontractors in the process.
Taking relevant measures to ensure CMMC compliance can help you stay ahead of the last-minute surprises. This way, you need not worry about missing out on crucial DoD contracts only because you go slack with cybersecurity. A good understanding of the requirements gives you a head start while finding the right technical partner takes you a step ahead. Having seasoned experts looking after the technical requirements keeps you stress-free because they cover you from start to end. The best part is that your team can focus on their core capabilities without looking into the compliance details. The sooner you get a partner on board, the better it is.
