Protecting information is not limited to any particular industry, however, some sectors deal with more sensitive types of information, like the government. For this reason, the U.S Department of Defense (DoD) has issued new guidance that demonstrates both its insistence on strong cybersecurity practices from its third party providers and its intent to cut ties with those who do not.  

This mandate came in the form of Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.204-7012. This regulation is interpreted in conjunction with the National Institute of Standards Special Publication (NIST SP) 800-171.

NIST 800-171 outlines “basic” security standards and controls designed to provide guidance for the protection and safeguarding of Controlled Unclassified Information (CUI) by federal contractors and subcontractors who process, store, or transmit information as part of their “routine” business operations. The deadline to comply was December 31, 2017. Any organization that fails to have “adequate security” risks losing business with the DoD.

The new guidance, titled “DoD Guidance for Reviewing System Security Plans and the NIST SP 800-171 Security Requirements Not Yet Implemented” can be viewed here. The document should be used as a tool to help the DoD and contractors assess their System Security Plans (SSPs) and Plans of Action (POAs) and to prioritize what steps must be taken to satisfy the DFARS 252.204-7012 mandate for “adequate security”.

The security requirements outlined in NIST SP 800-171 “Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations” should be complementary to your organization's existing IT strategy. 800-171 is very descriptive and requires the understanding of 110 controls across 14 categories which helps define “what” needs to be accomplished. These controls are used to measure whether a contractor has established an adequate cybersecurity program to meet the requirements of the new Defense Department regulation.

A benefit of the new DoD guidance is that it will better enable DoD and other organizations to prioritize and address any pitfalls in their cybersecurity program in the context of NIST 800-171 and to deploy these controls in an efficient and timely manner before their business is impacted.


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