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Compliance isn't just a Box to Check—it's a Strategic Necessity in Today's Cybersecurity Landscape. In today's ever-evolving cybersecurity landscape, compliance is more than just a regulatory requirement—it's a strategic imperative.
Welcome to the final installment of our series, A Practical Compliance Guide: NIST SP 800-171 Rev. 2 & CMMC 2.0.
In this concluding part, we focus on the critical steps your organization must take to achieve and maintain compliance successfully.
In previous articles, we discussed the foundations of NIST SP 800-171 and CMMC 2.0, practical approaches to implementing security controls, and ways to ensure compliance is deeply embedded into your company’s operations. Now, it’s time to wrap things up by providing actionable steps for creating a compliance team, conducting a gap analysis, and implementing a robust action plan. Additionally, we’ll share real-world examples from organizations of all sizes that have successfully navigated this process.
This final part serves as your blueprint to operationalize compliance, ensuring your journey doesn’t just stop at certification but leads to sustainable cybersecurity practices. Whether you're a small business or a large enterprise, these insights will guide you through building a compliance framework that works. Plus, learn how Bluestreak Compliance™, a CMMC Registered Practitioner Organization (RPO), can support your team in achieving your compliance goals affordably and effectively. Let’s dive into these essential final steps!
Practical Implementation Guide
Developing a Compliance Team
You must consult a CMMC-RPO (Registered Practitioner Organization) staffed with CMMC-RPs (Registered Practitioners) and CMMC-RPAs (Registered Practitioner Advanced) for the success of your project. This organization will provide expertise in all areas of NIST SP 800-171 and CMMC 2.0 and can help you implement the necessary security controls.
Form a dedicated compliance team with roles and responsibilities, including:
• Compliance Manager: Oversees the compliance program.
• IT Security Team: Implements technical controls.
• Legal Advisor: Ensures legal compliance.
• Training Coordinator: Manages employee training programs.
Conducting Gap Analyses
Perform a comprehensive gap analysis by:
• Reviewing Current Practices: Assess current cybersecurity practices and controls.
• Identifying Gaps: Identify gaps between current practices and framework requirements.
• Prioritizing Actions: Prioritize actions based on risk and impact.
Creating an Action Plan
Develop an action plan with specific steps to address identified gaps, including:
• Detailed Tasks: Break down tasks into manageable steps.
• Assigned Responsibilities: Assign responsibilities to team members.
• Timelines: Set realistic timelines for each task.
Implementing Controls and Practices
Execute the action plan by:
• Deploying Controls: Implement necessary technical and administrative controls.
• Conducting Training: Provide training to employees on new controls and practices.
• Testing and Validation: Test controls to ensure they are effective.
Documentation and Evidence Collection
Maintain thorough documentation of all compliance activities, including:
• Policies and Procedures: Document security policies and procedures.
• Implementation Records: Keep records of control implementations and changes.
• Audit Logs: Maintain logs of security events and incidents.
Case Studies
The high-level Case Studies below give examples of some key compliance steps involved with their compliance and implementation of remediation controls. If you want more information, please see my contact data at the end of this blog.
Small Business Implementation
A small defense contractor successfully achieved compliance by:
• Leveraging Cloud Solutions: Using cloud-based security solutions to reduce costs.
• Outsourcing IT Security: Partnering with an MSSP (managed security service provider) for technical expertise.
• Focused Training: Conducting focused training sessions for all employees.
Medium-Sized Enterprise Implementation
A medium-sized manufacturing company transitioned to CMMC by:
• Dedicated Compliance Team: Forming a dedicated compliance team.
• Comprehensive Gap Analysis: Conduct a thorough gap analysis and systematically address gaps.
• Regular Audits: Implementing regular internal and external audits.
Large Organization Implementation
A large defense contractor ensures ongoing compliance by:
• Automated Tools: Automated tools are used for continuous monitoring and reporting.
• Integration with Existing Systems: Integrating compliance requirements with existing security systems.
• Employee Engagement: Engaging employees at all levels in the compliance process.
Resources and Further Reading
Official Documents and Guidelines
• DFARS: DFARS Official Website
• NIST SP 800-171: NIST SP 800-171 Official Document
• CMMC: CMMC Official Website
Tools and Templates
• Compliance Checklists: These can be provided by Bluestreak Compliance™.
• Policy Templates: Bluestreak Compliance™ has template packages available.
• Assessment Tools: Tools for conducting self-assessments and gap analyses.
Training Programs and Workshops
• NIST Training: NIST offers various training programs and workshops.
• CMMC Training: Certification training programs and workshops for CMMC.
• Industry Conferences: Cybersecurity conferences and events focused on DFARS, NIST
SP 800-171, and CMMC.
Conclusion
Compliance with DFARS, NIST SP 800-171, and CMMC are essential for companies handling Department of Defense (DoD) information. It requires:
• A comprehensive understanding of the requirements of each framework.
• Documented Policies & Procedures
• A structured implementation plan to meet those requirements.
• Employee Awareness and Training
• Ongoing monitoring and continuous improvement efforts to maintain compliance.
Final Thoughts
Navigating compliance with DFARS, NIST SP 800-171, and CMMC can be challenging yet
crucial for protecting sensitive information and sustaining business relationships with DoD
contractors. By following the guidelines and best practices outlined in this guide, companies
can successfully manage the complexities of compliance.
Contact Bluestreak Compliance™ for a free consultation:
• Discuss your specific requirements and gain insight into your company’s processes.
• Receive a comprehensive overview of DFARS, NIST SP 800-171, and CMMC.
• Address any questions you have and propose the next steps for compliance.
• Gap Analysis
• Readiness Assessment
• Remediation Planning
• Implementation Support
• Policy & Procedure Development
• Training & Awareness
• Mock Assessments
• Continuous Monitoring & Improvement
• Documentation Assistance
• Advisory Services
• Collaboration with C3PAOs (CMMC Third Party Assessment Organizations)
Begin your compliance journey confidently and ensure your organization meets the stringent cybersecurity standards required by the DoD.
About the Author
Joe Coleman is the Cyber Security Officer for Bluestreak Compliance™, a division of Throughput | Bluestreak | Bright AM™. Joe is a Certified CMMC-RPA (Registered Practitioner Advanced).
About Bluestreak™:
Bluestreak™ is a fully integrated Quality Management System (QMS), a powerful Manufacturing Execution System (MES) designed for the manufacturing environment and service-based manufacturing companies ( metal-treating/powder-coating, plating, heat-treating, forging, and metal-finishing), businesses that receive customers’ parts, perform a process (service) on them, and send those parts back to the customer). Companies need MES software tailored to specific functionality and workflow needs, such as industry-specific specifications management, intuitive scheduling control for staff and machinery maintenance, and the ability to manage work orders and track real-time data. If different work centers on the production floor aren’t “speaking” to each other via the MES, the data loses value and becomes disjointed or lost in disparate silos.
Bluestreak | Bright AM™ is an MES + QMS software solution specifically designed to manage and optimize the unique requirements of Additive Manufacturing’s production of parts and powder inventory usage.
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