This article was published on washingtontechnology.com
While your calendar is flurried with holiday dates, you should already be aware of one deadline – Dec. 31, 2017. It’s the date by which anyone holding U.S. government data must comply with the security directives surrounding controlled unclassified information (CUI), known as National Institute of Standards (NIST) Special Publication (SP) 800-171, Revision 1.
NIST is responsible for developing information security standards, and provides federal agencies with recommended requirements for protecting the confidentiality of CUI in the following circumstances:
- When the CUI is resident in nonfederal information systems and organizations
- When the information systems where the CUI resides are not used or operated by contractors of federal agencies or other organizations on behalf of those agencies
- Where there are no specific safeguarding requirements for protecting the confidentiality of CUI prescribed by the authorizing law, regulation, or government wide policy for the CUI category or subcategory listed in the CUI Registry
As you begin to understand the efforts involved in implementing the security controls, you might not have adequate resources, time or energy to start the process of complying. To help you along the way, the following insight and recommendations will help you on your way to compliance.
Leadership and Project Management
It’s important to start from the top down. Get buy in from your executive and leadership teams, as their understanding and commitment will be necessary to justify the expense and resource commitment. Sharing perspective and the facts around the December deadline will help your case for gaining support to get the job done.
Determine the scope of the project. As you work towards compliance, you will want to establish benchmarks and goals that can be met by a trained project team that has been brought up to speed on the regulation standards. NIST recently released the NIST Handbook 162 NIST MEP Cybersecurity Self-Assessment Handbook for Assessing NIST SP 800-171 Security Requirements in Response to DFARS Cybersecurity Requirements. This guide can be used to answer any unknowns and provide a consistent understanding of expectations for the project team.
Data Classification. Identify contracts that need to comply with NIST. Segment those contracts into your core “Controlled” groups to determine the Controlled Technical Information associated with the contracts.
Define the boundary and scope. The boundary and scope of the project can be divided into physical, networking, and applications. Examples of each are those are as follows:
- Shop floor: specifications, molds, products
- Engineering: drawings, models, printers
- What can be segmented and isolated
- Where on the network is or isn’t CUI
- What tools are used for viewing, modifying, sharing, printing, and downloading CUI
Assess compliance. Now that the scope of the project has been determined, each item in scope needs to be assessed against the applicable 110 requirements. Have each owner interview the Subject Matter Expert (SME) for the requirements they are auditing, walking through the tools, applications and permissions to assess their current compliance.
Document findings in a template. Throughout this process, look at how the application or function, under audit, is compliant, partially compliant, or if the requirement is not applicable, extensively noting how it is compliant, what is missing, or if alternative measures are in place. A structured template will help establish consistency in the assessment process. Also, keep a knowledge base – or sounding board – for the team to check assumptions and get answers to questions.
Remediation. Once you have done the work of identifying and assessing the data, it should be correlated to generate Plan of Action and Milestones (POA&Ms). This plan of actions and milestones should specify each remediation needed and what systems the remediation impacts, which helps to streamline, prioritize, assign owners, and drive milestones and completion dates with additional backup plans.
Exceptions. Use this phase to also tag any possible exceptions, asking if there are any systems that cannot be compliant. An example of this could be that an application password cannot be complex, or a screen saver cannot be configured for a shop floor system. An exception needs to be mitigated by alternative measures to minimize the risk and provide layers of protection.
Audit the Auditors. Once remediation is nearing completion, create your System Security Plan (SSP). Utilizing the information gathered, Technical Project Manager (TPM) should now be able to draft the SSP that demonstrates how the site achieved compliance, the known exceptions with their mitigations and remediation still in progress. In addition, you could have a third party audit your SSP, evidence and overall project for gaps, while evaluating any new findings.
Start next steps. As you know, there is no finish line in compliance. Ask yourself a few of the following questions: How are you ensuring you are staying compliant, what improvements need to be made, and are new customer contracts in scope? These questions will help you identify what steps need to be taken to make new persons and systems being brought online in the future compliant, as well. This will also establish a pattern that you can use moving forward, as compliance continues into the tech-driven future.
By approaching compliance in the aforementioned manner, the process should be as painless as possible, ensuring consideration for future contracts, but also providing peace-of-mind that all is in order.