For contractors working in supply chains tied to government contracts, the work they do for the federal government, the Department of Defense, or other government agencies comes with the expectation that information they’re entrusted with will be protected to clearly defined standards. National Institute of Standards and Technology (NIST) Special Publication 800-171, first published in June 2015, provides the guidance to ensure that sensitive federal data remains secure when it is processed, stored, and used in information systems outside of the federal government.

In 2010, Executive Order 13556 “establishe[d] an open and uniform program for managing information that requires safeguarding or dissemination controls pursuant to and consistent with law, regulations, and Government-wide policies,” replacing a confusing patchwork of agency-specific policies and procedures that had governed it before. It defined this information, which is specifically not classified under Executive Order 13526 or the Atomic Energy Act, as controlled unclassified information (CUI). NIST SP 800-171 lays out the complex security requirements that vendors are expected to meet to keep this data secure.

What It Means for You

If your company is undertaking a federal contract, either as a primary or a sub, the CUI shared with you requires that you comply with NIST SP 800-171 Revision 2, the most recently updated version of the special publication. Vendors must ensure both that their controls for processing and storing data received from a federal agency meet the requirements and that their employees receive adequate training to understand the rules. Project managers, developers, risk management personnel, your internal security team, and individuals or teams involved with the handling of CUI will all need to be familiar and in compliance with the framework.

The Requirements of NIST SP 800-171

The special publication defines 110 security requirements grouped into 14 families: Access Control, Awareness and Training, Audit and Accountability, Configuration Management, Identification and Authentication, Incident Response, Maintenance, Media Protection, Personnel Security, Physical Protection, Risk Assessment, Security Assessment, System and Communications Protection, and System and Information Integrity. These aren’t just a set of passive measures—as part of meeting the framework’s standards, organizations must take active measures to find and remediate potential holes in security, including vulnerability scans and penetration testing.

Where Vulnerability Scans and Penetration Testing Come In

Vulnerability scans and penetration testing are, frankly, an essential part of any effective cybersecurity strategy. But for federal contractors, they’re also key for achieving NIST compliance. Certain requirements spell it out:

Requirement 3.11.2: “Scan for vulnerabilities in organizational systems and applications periodically and when new vulnerabilities affecting those systems and applications are identified.” Organizations are expected to periodically run vulnerability scans on all system components (including all networked devices), looking both for identified vulnerabilities and using advanced scanning techniques as necessary to ensure custom software applications are also secure. This provision also notes that “[s]ecurity assessments, such as red team exercises [penetration tests], provide additional sources of potential vulnerabilities for which to scan.” Requirement 3.11.3 mandates the remediation of vulnerabilities discovered through the processes outlined in 3.11.2.

Requirement 3.12.1: “Periodically assess the security controls in organizational systems to determine if the controls are effective in their application.” Putting cybersecurity protections in place isn’t enough. Vendors are expected to run security assessments—penetration tests—to ensure that the controls they’ve implemented are really working the way they’re expected to. Requirement 3.12.2 follows up by requiring that the deficiencies identified are corrected to reduce or eliminate vulnerabilities.

Requirement 3.12.3: “Monitor security controls on an ongoing basis to ensure the continued effectiveness of the controls.” Running a vulnerability scan or penetration test isn’t a one-time thing. The government expects you to have an ongoing monitoring program to stay ahead of emerging threats.

Requirement 3.14.1: “Identify, report, and correct system flaws in a timely manner.” Your organization is expected to quickly act to remedy vulnerabilities found during scans, penetration tests, incident response activities, and system error handling.

Your Compliance Solution

If meeting NIST compliance sounds daunting—well, it’s complex, but it’s not impossible. Petronella Technology Group (PTG) are experts in what your organization needs to satisfy security requirements and achieve compliance. We start by getting a baseline on your existing cybersecurity practices with our free NIST self-assessment. Once we know where your organization stands, we can develop a plan to help you meet and maintain compliance. To find out more about how PTG can take the stress out of NIST compliance, contact us here.

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