Becoming a Department of Defense (DoD) contractor is no easy task.
While your organization may be great at what it does, there are
hundreds, if not thousands of other organizations vying for the same
contracts. Thankfully, the DoD has developed a simple strategy for
pruning the number of viable contractors to a reasonable number. That
strategy is called DFARS.
DFARS stands for Defense Federal Acquisition Regulation Supplement.
To put it simply, DFARS is a government regulation that requires DoD
government officials and their associated contractors to follow
Department of Defense specific acquisition regulations when engaging in
the procurement process for goods and services.
While DFARS is lengthy on its own, the driving force causing so many
contractors to scramble is the National Institute of Standards and
Technology (NIST) Special Publication (SP) 800-171 standard. This
standard provides guidance on protecting Controlled Unclassified
Information (CUI) in nonfederal information systems and organizations.
By December 31, 2017, any DoD contractors forced to adhere to DFARS must
also comply with the security requirements outlined in the NIST SP
800-171 standard.
As DoD contractors rush to implement NIST’s standard and submit any
necessary paperwork to the DoD before the end of 2017, other industries
should be taking notice. While the NIST SP 800-171 standard was
developed for nonfederal information systems, it serves as a
well-structured, fundamental framework for securing information systems
across most, if not all industries.
The SP 800-171 standard requires organizations to implement basic
security controls, such as password and automatic screen-lock policies,
as well as more advanced controls, such as multi-factor authentication
for network and local access to information systems. While some security
requirements may be overkill and unnecessary for most organizations,
much of the SP 800-171 standard should serve as a guiding light for any
organization that values the confidentiality, integrity, and
availability of their information systems, their data, and their
clients’ data.
Since most regulatory standards fail to require organizations to
implement the necessary administrative, physical, and technical controls
that comprise a solid information technology and cybersecurity
foundation, we often base our assessments off the SP 800-171 security
requirements, in addition to the requirements of whichever regulatory
standard we are conducting an assessment for. This allows us to ensure
we are providing our clients with the necessary information, guidance,
and skills required to ensure their overall security posture remains
strong, despite the constantly in flux threat landscape.
To all the DoD contractors out there, I know it is no easy task to
comply with everything the government can throw at you. To all other
organizations, especially those who have never conducted an assessment, I
recommend reviewing the SP 800-171 standard, and conducting a risk
assessment. A well conducted risk assessment can be an eye-opening
experience and will allow you to further enhance your overall security
posture, thus helping to ensure continued regulatory compliance.
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