We Can Help You Minimize Risk With NIST 800-171 Compliance
NIST 800-171 Compliance Starts With Cybersecurity Documentation
In terms of cybersecurity compliance, it is important to understand that if it is not documented then it does not exist. That is the reality of how audits work and that can lead to non-compliance. Non-compliance can lead to contract termination, False Claims Act violations and lawsuits, so NIST 800-171 is a topic to take seriously.
ComplianceForge.com specializes in cybersecurity compliance-related documentation and is an industry-leading provider NIST 800-171 compliance documentation.
From the Fortune 500 all the way down to small businesses, ComplianceForge serves businesses of all sizes, since its NIST 800-171 compliance products are designed to scale for organizations of any size or level of complexity. These affordable options can provide nearly "turn key" documentation solutions to address policies, standards, procedures, SSP, POA&M and incident response requirements from DFARS and NIST 800-171.
As a quick summary of your requirements to comply with NIST 800-171, you are expected to have several different "documentation artifacts" to prove that your cybersecurity program exists. The reality with compliance assessments is that if something is not documented, you cannot prove it exists. Given that reality, you need to ensure your company has the proper cybersecurity documentation in place:
Cybersecurity policies, standards & procedures
System Security Plan (SSP) (requirement #3.12.4)
Plan of Action & Milestones (POA&M) (requirements #3.12.1, 3.12.2, 3.12.3 & 3.12.4)
Our solutions cover both DFARS and FAR requirements for protecting Controlled Unclassified Information (CUI) by addressing NIST 800-171 and its corresponding NIST 800-53 controls.
Not Sure Where To Start With NIST 800-171?
NIST 800-171 is intended to force contractors to adhere with reasonably-expected security requirements that have been in use by the US government for years.
NIST 800-171 establishes a basic set of expectations and maps these requirements to NIST 800-53, which is the de facto standard for US government cybersecurity controls. In some ways, this is a good thing since the US government is not reinventing the wheel with new requirements. Instead, the DoD selected moderate-level controls from an existing set of recognized best practices, commonly used throughout the DoD and Federal agencies. In the long run, this will help both the US government and private businesses speak the same language for cybersecurity.
The bottom line is NIST 800-171 creates a standardized and uniform set of requirements for all Controlled Unclassified Information (CUI) security needs. This is designed to address common deficiencies in managing and protecting unclassified information by that is being stored, transmitted or processed by private businesses.
If you want to learn more about NIST 800-171 requirements and how to minimize scoping, we recommend pouring yourself a cup of coffee and watch the videos we put together.
EASY TO IMPLEMENT
DFARS 252.204-7012 vs FAR 52.204-21
Many of our clients who need to address DFARS 252.204-7012 (NIST 800-171) also have to address FAR 52.204-21. One common question we receive from clients pertains to aligning with the correct security framework to ensure they have the proper coverage for compliance. This generally revolves around aligning with ISO 27001/27002 or NIST 800-53, since those are the two most common security frameworks.
The bottom line is that utilizing ISO 27001/27002 as a security framework does not meet the requirements of NIST 800-171. In fact, NIST 800-171 (Appendix D) maps out how the CUI security requirements of NIST 800-171 relate to NIST 800-53 and ISO 27001/27002 security controls. This includes callouts where the ISO 27001/27002 framework does not fully satisfy the requirements of NIST 800-171. Therefore, policies and standards based on NIST 800-53 are what is needed to comply with NIST 800-171.
End Goal = Demonstrate Secure Practices
A central tenant to NIST 800-171 is a need to focus on secure engineering. However, it is important to keep in mind that this expectation for operationalizing security and privacy principles is not limited to NIST 800-171:
NIST 800-53 - SA-8
NIST Cybersecurity Framework - PR.IP-2
ISO 27002 - 14.2.5 & 18.1.4
Federal Acquisition Regulations (FAR) 52.204-21 - 4
National Industrial Security Program Operating Manual (NISPOM) - 8-302 & 8-311
SOC2 - CC3.2
Generally Accepted Privacy Principles (GAPP) - 4.2.3, 6.2.2, 7.2.2 & 7.2.3
New York State Department of Financial Service (DFS) - 23 NYCRR 500.08
Payment Card Industry Data Protection Standard (PCI DSS) - 2.2
Center for Internet Security Critical Security Controls (CIS CSC) - 1.2, 5.9, 6.2, 6.3, 6.4, 6.5, 7.1, 7.2, 7.3, 7.4, 7.5, 7.6, 7.7, 7.8, 8.6, 9.1, 9.2, 9.3, 9.4, 9.5, 9.6, 11.4, 11.5, 11.6, 11.7, 13.4, 13.5 & 16.5
European Union General Data Protection Regulation (EU GDPR) - 5 & 25
Level of Effort = NIST 800-53 Moderate Baseline Controls
At the heart of the matter, complying with NIST 800-171 requirements means adopting MODERATE baseline controls from NIST 800-53 rev4.
NIST 800-171 compliance includes fourteen (14) families of security requirements for protecting the confidentiality of CUI. The families are aligned with the minimum security requirements for federal information and information systems described in Federal Information Processing Standard (FIPS) 200, with exceptions for contingency planning, system, and services acquisition and planning requirements.
Appendix D of NIST 800-171 maps requirements to both NIST 800-53 rev4 and ISO 27002:2013 best practices. Only NIST 800-53 offers complete coverage for NIST 800-171 compliance requirements. The good news is our NIST 800-53 based Written Information Security Program (WISP) has the documentation you need to comply with MODERATE baseline controls (Appendix D of NIST 800-53).
US Federal agencies require NIST 800-171 compliance for protecting the confidentiality of Controlled Unclassified Information (CUI).
The CUI requirements for NIST 800-171 compliance are directly linked to NIST 800-53 MODERATE baseline controls and are intended for use by federal agencies in contracts or other agreements established between those agencies and nonfederal organizations (e.g., government contractors), as it applies to:
When CUI is resident in nonfederal information systems and organizations;
When information systems where CUI resides are not used or operated by contractors of federal agencies or other organizations on behalf of those agencies; and
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.
The NIST 800-171 compliance requirements apply to all non-federal organizations that process, store, or transmit CUI. The good news is that ComplianceForge can help you with your compliance needs!