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What DoD Contractors Need to Know About Controlled Unclassified Information (CUI) & Using a Technology Solutions Provider to Ensure Compliance with the DFARS and NIST.
Today, more than ever, the Department of Defense (DoD) relies on external contractors and suppliers to carry out a wide range of missions. Sensitive data is shared with these companies and must be protected. Inadequate safeguards for this sensitive data may threaten America’s National Security and put our military members at risk.
In response to this threat, the DoD has implemented a basic set of cybersecurity controls through DoD policies and the Defense Federal Acquisition Regulation Supplement (DFARS). The DFARS rules and clauses apply to the safeguarding of contractor/supplier information systems that process, store or transmit Controlled Unclassified Information (CUI). These security controls must be implemented at both the contractor and subcontractor levels based on information security guidelines developed by the National Institute of Standards and Technology (NIST) Special Publication 800-171 “Protecting Controlled Unclassified Information in Non-federal Information Systems and Organizations.”
As a U.S. DoD contractor who collects, stores, or transmits Covered Defense Information (CDI) or Controlled Unclassified Information (CUI) you must comply with NIST (The National Institute of Standards and Technology) regulations 800-171 and DFARS (Defense Federal Acquisition Regulation Supplement) 252.204-7012. Your subcontractors must comply as well and be able to maintain compliance. If you don’t, you can’t bid on DoD contracts, and you may lose the ones you have.
The Department of Defense enforces a specifically defined set of cybersecurity controls through the DFARS. The DFARS rules and clauses apply to the safeguarding of contractor/supplier information systems that process, store or transmit Controlled Unclassified Information (CUI). These security controls must be implemented by both you, the contractor, and your subcontractors according to levels based on information security guidance developed by the National Institute of Standards and Technology (NIST).
Finding everything you need to know about DFARS regulations and NIST cybersecurity guidance to ensure that your technology is compliant can be a daunting task. Using the services from a Technology Solutions Provider who has expertise in DFARS and NIST requirements is essential if you want to attain compliance and remain compliant.
Complying with DFARS and NIST requirements isn’t easy. You and your subcontractors must meet DFARS cybersecurity standards and NIST Guidelines, or you can’t apply for DoD contracts. To do this requires a complete scoping and readiness assessment to measure your compliance. You must then remediate any identified gaps in security.
To do this requires the support from a Technology Solutions Provider who specializes in providing compliance solutions. The right IT Provider will help you understand the risks of storing Controlled Unclassified Information in your IT system, and what you must do to comply. Your Provider should also be adept at conducting gap analyses services, vulnerability scans, and penetration testing to ensure your IT security.
Your Requirements as a DoD Contractor
Cyber attacks have reached epidemic proportions in the U.S. Even government agencies are at risk of breaches. This poses a real risk to National Security. It’s imperative that you, your personnel and your subcontractors safeguard classified information and Controlled Unclassified Information. The security of the U.S. Government depends upon the measures you take as a contractor, as well as those in your supply chain. Unfortunately, many businesses don’t have the right cybersecurity controls in places like firewalls, anti-virus and anti-malware, and identity-authentication processes. They also lack detection and response controls for IT exploits.
Until now, strict security processes, controls, and standards that applied to federal information systems weren’t required for CUI. The DFARS 225.204-7012 and NIST SP 800-171 regulations were developed to cover unclassified federal information for nonfederal organizations. You must implement the security controls outlined in the NIST SP 800-171 to be compliant with DFARS.
The U.S. Government provided a disciplined and structured process for contractors to follow. If you want to comply and be accepted for DoD projects, you must leverage the following IT solutions.
The Right Technology Solutions Provider Will:
What Specifically is Covered by the DFARS/NIST Regulations?
The DFARS 252.204-7012 | NIST SP 800-171 requirement for CUI includes any information related to a DoD performance contract, as well as anything that supports the contract. This is a very broad requirement and could have a dramatic impact on the number of systems that must be covered.
These systems are broken down into four categories:
The new rule also applies to your subcontractors. They must meet the same applicability definitions described above.
As a DoD Contractor, you must know what CUI you store, process, or transmit in the course of performing your duties. You and your subcontractors must be prepared to apply NIST SP 800-171 security controls to your information systems. You must create and sustain an environment for the proper storing, processing, or transmitting of CUI. This includes ensuring your employees or any individuals involved in the contract practice security and privacy when it comes to information systems.
As you can see, this broad scope of requirements demands the expertise of a Technology Solutions Provider who can develop, deploy and enhance a secure and compliant environment for your CUI processing needs. You need one who can engage with stakeholders to identify the key security objectives and critical requirements to develop a prioritized IT roadmap, information security architecture, security controls and operations that comply with the DFARS 225.204-7012 and NIST SP 800-171 Guidelines.
Minimum cybersecurity standards are described in NIST Special Publication 800-171 and broken down into fourteen areas:
Plus, there are specific security requirements comprising 110 individual controls that you and your subcontractors must implement in each of these areas.
Large enterprises probably have these security systems in place. Smaller businesses probably don’t–And this is a big undertaking. With the right experience in CUI requirements, your TSP can help by handling these responsibilities for you. They can:
As a DoD contractor, you and your authorized employees must fully understand what Covered Defense Information you store, process, or transmit in the course of doing business with the Department of Defense. You must also be ready to provide adequate security using controls outlined in the NIST SP 800-171, Security and Privacy Controls for Non-Federal Information Systems.
Your Technology Solutions Provider must be adept at integrating methodologies for incorporating security and privacy into business solutions. They should leverage the following services:
Meeting the SP 800-171 is not a one-time fix–Rather it’s a continuous assessment, monitoring and improvement process. Your TSP should periodically assess the security controls in your company’s systems to determine if the controls are effective in their application. They should develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in systems. They must monitor security controls on an ongoing basis to ensure the continued effectiveness of the controls that are in place. And, they should 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 connections to other systems.
If the Department of Defense determines that other measures are required to provide adequate protections and security, you and your subcontractors may also be required to implement additional precautions. It’s essential that you stay up to date on these requirements if you want to keep your standing with the DoD or to bid on future contracts. Again, your Technology Solutions Provider is your best friend where this is concerned.
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