CMMC 2.0, NIST 800-171, and Incident Response

Mature, tested cybersecurity incident response programs dictated for commercial companies and government agencies by US Department of Defense

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In an era marked by relentless cyber threats, incident response has become a paramount concern for organizations across the board. The ability to swiftly detect and respond to security incidents is not just a best practice; it’s a fundamental requirement for safeguarding sensitive information and maintaining trust with stakeholders. To that end, the US Department of Defense has established multiple guidelines and certifications to ensure its ecosystem of military units, supporting organizations and departments, and the defense industrial base (DIB) of suppliers and contractors are maximally secure.

Two of these cybersecurity frameworks, NIST 800-171 revision 2 and the Cybersecurity Maturity Model Certification 2.0 (CMMC 2.0), are pivotal in protecting critical unclassified information from the ever-evolving landscape of cyber threats, particularly from the growing set of nation-state attackers. These frameworks aren’t just for the government and their contractors; they’re practical, battle-tested tools that can help any commercial organization prepare, respond, and recover in the face of cyber adversity.

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Commercial companies are equally vulnerable to the relentless tide of cyber threats. Whether you’re a multinational corporation or a small business, the question isn’t if a cyberattack will happen, but when. That’s where incident response comes into play, and it’s a concern that should be front and center for all commercial enterprises. It’s your strategy for not only surviving but thriving in an era where cyber threats are ever-evolving and increasingly sophisticated. And these two frameworks—NIST 800-171 Rev 2 and CMMC 2.0—can serve as invaluable guidelines to bolster your incident response program. 

NIST 800-171 Rev 2: Protecting Controlled Unclassified Information

Picture this: a highly sophisticated adversary targeting, compromising, and exfiltrating sensitive information across the U.S. defense industrial base. This is an all-too-real and far too common scenario, and the collective impact can lead to the compromise of critical military technologies and national strategic advantage. This is where the NIST 800-171 Revision 2 steps in as a beacon of defense. It aims to provide federal agencies with crucial security requirements for safeguarding the confidentiality of Controlled Unclassified Information, or CUI, which closely resembles the protection of proprietary information and trade secrets in the commercial sector. 

Just as companies fiercely guard their proprietary data, NIST 800-171 aims to ensure that vital government information remains secure. The framework underscores the seriousness of the task at hand. It’s not just about incident handling; it’s about building a fortress around CUI. Among its requirements for improving cybersecurity defenses and operations, it demands the establishment of an operational incident-handling capability that covers everything—from detecting threats to analyzing them, containing the damage, orchestrating recovery, and ensuring that users are not left in the dark. 

NIST 800-171 Rev 2 also insists that incidents remain not just internal matters; it requires notification, documentation, and reporting of events both inside and outside the organization. This not only makes other officials aware to be able to step in for added oversight as needed; it enhances awareness around the government of new attacks and enables collective cyber defense strategies against them.

To ensure that an incident response program goes beyond a paper plan that is unlikely to be updated or effective, NIST calls for rigorous incident response testing to protect sensitive information and assess the organization’s effectiveness at responding to compromises. This can take various forms, from walkthroughs of structured checklists and tabletop exercises to adrenaline-pumping simulations that mimic real-world chaos. However, these must not be merely technical exercises; they must be a comprehensive evaluation that delves into how incidents impact the organization, from its mission capabilities and assets to the individuals who keep operations running smoothly.

Much like a national treasure, CUI’s protection is not negotiable, and NIST 800-171 ensures that protection is proactive, tested, and unwavering. It’s a call to arms in the realm of cybersecurity, where information is not just data; it’s the lifeblood of national security.

CMMC 2.0: A Robust Defense Against Cyberattacks

Similarly, the Cybersecurity Maturity Model Certification 2.0 is another pivotal framework crafted by the U.S. Department of Defense to simplify its approach from the earlier iteration. CMMC 2.0 stands as a comprehensive certification framework to bolster the defense industrial base against frequent and increasingly sophisticated cyberattacks. Within CMMC 2.0, requirements are addressed through several practices and are tiered into three levels by complexity. Each increasing level increases the readiness and resiliency required to attain certification. Organizations must achieve at least Level 2 to handle “critical national security information” and demonstrate what the government identifies as “good” security efforts.

CMMC 2.0 incident response requirements align closely with those of NIST 800-171. To achieve level 2, organizations are required to establish a comprehensive incident handling capability that covers preparation, detection, analysis, containment, recovery, and user response. The framework also stresses the importance of rigorous testing of these incident response capabilities. Organizations must also track, document, and report incidents both internally and externally, maintaining records of each and every security incident with meticulous documentation. The types of incidents subject to reporting, and the content, timeliness requirements, and the designated authorities for reporting are determined by the laws, Executive Orders, directives, regulations, and policies pertinent to each organization.

Ultimately, CMMC goes beyond theory; it’s a call to action. It demands organizations forge a robust incident handling capability. Given that the government sees the Internet as a constant cyber battlefield, preparation and planning is key, and achieving and demonstrating CMMC practices ensures teams are ready for the unforeseen. It insists on tracking, documenting, and reporting incidents to designated officials, both within and beyond your organization. And CMMC doesn’t stop at just planning; it emphasizes testing—putting incident response capabilities to the ultimate trial. 

In this world of continuous cyber attacks, CMMC 2.0 stands as a steadfast shield, urging organizations to be proactive in the face of constant threat.

Why Align Incident Response with These Frameworks?

Imagine the fallout of a cyber breach: sensitive data is exposed, operations grind to a halt, trust erodes, and financial losses mount. The aftermath of such an event can be catastrophic, often leading to long-term damage that some organizations may never fully recover from. This is why every entity, regardless of whether they are government or commercial and size or industry, should care deeply about incident response.

To address the challenges, organizations must embrace a proactive and comprehensive approach to incident response that goes beyond conventional measures. By aligning your incident response plan with standards like CMMC 2.0 and NIST 800-171 Rev 2, you can reap several benefits:

  • Comprehensive Approach: these frameworks provide a structured, baseline approach to incident response planning, readiness, and execution
  • Effective Prioritization: they help organizations prioritize incident response efforts based on criticality, ensuring that the most pressing issues are addressed first
  • Continuous Improvement: regular testing and updates ensure that incident response plans evolve to meet the ever-changing threat landscape, and are demonstrably shown to reduce the cost and impact of every incident
  • Wider Regulatory Compliance: Aligning with these frameworks can also simplify compliance with other external regulations and compliance frameworks, such as FedRAMP, SOC 2, and ISO 27001, further demonstrating the organization’s overall cybersecurity posture

Overall, these frameworks not only aid in fortifying cybersecurity defenses, they enhance your capacity to respond swiftly and effectively to incidents, ultimately safeguarding your operations and business, your personnel and customers, and your reputation.

A Proactive Approach to Incident Response

In the face of an ever-evolving threat landscape, a proactive approach to incident response is vital. By aligning your incident response program with CMMC 2.0 and NIST 800-171 Rev 2, you not only improve your organization’s defenses but also demonstrate a commitment to cybersecurity best practices. Incident response shouldn’t just be a reactive measure; it’s a strategic imperative that can minimize the impact of cyberattacks and safeguard the organization’s sensitive information.

While many only see hurdles to overcome to implement an effective incident response program, current technology automation like the BreachRx incident management platform and Cyber RegScout™ enable cybersecurity teams to easily exceed these criteria and alleviate both operational and compliance challenges. The technologies simplify incident response strategy and evaluation, resulting in savings of $1.5 million or more during an incident while facilitating quicker alignment with other cybersecurity frameworks from around the world. Beyond the advantages in terms of regulations, these platforms streamline and foster team collaboration, reduce the consequences of incidents, and expedite the overall operational response process. Ultimately, automation empowers teams to decisively prioritize and address security incidents, bolstering cyber resilience throughout the organization.

Incorporate these frameworks into your incident response strategy to create a comprehensive plan. Engage with key stakeholders, gather input from customers, partners, government officials, and regulators, and tailor action plans for likely incident scenarios. Automation is increasingly essential in this process, as it streamlines tasks, meets higher audit standards, and enhances efficiency. Align with the NIST 800-171 and CMMC 2.0 and you’ll be better equipped to navigate the complex cybersecurity landscape and emerge stronger in the face of constant adversity.

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