In this series—Building a CMMC Solution—we’ll be exploring the different steps and factors it takes to build a CMMC and NIST cybersecurity strategy for businesses from the ground up. From getting started to testing and auditing, we’ll be walking through each step to help you as you prepare for your own CMMC audit process.
In the previous blog—Building a CMMC Solution: 3 Steps to Start Your CMMC Plan—we discussed three key steps that companies need to take to start their journey towards compliance with the requirements of the Cybersecurity Maturity Model Certification (CMMC). For companies that have determined their CMMC obligations and started the process towards meeting them, the next step is developing a comprehensive CMMC strategy.
Hyper Vigilance offers compliance management services designed to help companies quickly and sustainably achieve CMMC compliance. Here are some of the main considerations that we keep in mind while helping your organization build a CMMC and NIST cybersecurity strategy.
Our CMMC Cybersecurity Assessment Baseline
Regulatory compliance strategies should be designed to meet an organization’s unique needs and to support the business. When preparing for a CMMC cybersecurity assessment, Hyper Vigilance looks at three key factors: what you have, why you have it, and what you do.
What You Have
Many CMMC compliance requirements are focused on deploying security controls for sensitive data entrusted to an organization. A company’s existing IT infrastructure has a significant impact on the scope and difficulty of achieving compliance.
Some questions our team asks when developing a baseline for CMMC compliance include:
- What devices do you have?
- Can those devices meet CMMC security requirements?
- Does existing infrastructure need to be migrated to or integrated into Hyper Vigilance’s cloud-based platform?
Why You Have It
A company’s existing IT infrastructure is designed to meet certain business needs. To help identify these needs and determine how IT infrastructure can help achieve them, we ask:
- What business needs is the infrastructure fulfilling?
- Why not use something else?
What You Do
Hyper Vigilance is committed to the success of your organization and tailors our platform to help ensure this success. To help with this process, we’ll seek out the following information:
- What is the company mission and function?
- Does Hyper Vigilance’s platform fit it out of the box or will changes be necessary?
- What features are most important to the company and need to be priorities during deployment?
CMMC Factors to Consider
When preparing a CMMC cybersecurity assessment and eventual policy for an organization, Hyper Vigilance considers a number of different elements. To ease the compliance process, we offer a basic framework for CMMC and NIST compliance that allows organizations to easily achieve compliance and scale as necessary.
However, every company has its own unique needs, and this framework is designed to adapt to meet these needs. Examples of some of the factors that we look for and consider when tailoring a CMMC compliance strategy to an organization include:
- Data Storage and Access: Some companies regularly process large datasets and require rapid, frequent access to this data. A CMMC compliance strategy should design IT infrastructure to accommodate these needs while meeting regulatory requirements.
- International Considerations: Multinational corporations may be subject to a range of data protection regulations, including CMMC or GDPR. Corporate IT architecture and compliance strategies must be designed to ensure that the various compliance requirements are met for the data under their jurisdiction.
- Procedural Issues: Companies have existing policies and procedures for how they conduct business and secure their IT infrastructure. These policies may conflict with CMMC requirements, and these conflicts must be identified and addressed within a compliance strategy.
- Endpoint Management vs. Usability: Some security settings adopted for compliance may impair the usability of corporate systems. For example, disabling notifications regarding the last user who logged into a system can impact the usability of accessibility functions such as Windows Hello.
- Applications: Every company has a set of applications that it uses on a regular basis, but these might not map directly to security baselines and policies. Compliance policies should be designed to balance business needs and regulatory compliance.
In addition to these core considerations, each company undergoing a cybersecurity assessment is unique and has its own compliance considerations. For example, companies may have existing IT management processes and development pipelines that may break when Hyper Vigilance’s CMMC compliance framework is applied to the corporate environment.
In these cases, existing processes and the framework may both need to be tweaked to make the system work while enabling the company to achieve and maintain a successful CMMC and NIST cybersecurity strategy.
Hyper Vigilance has assisted many companies with designing IT infrastructure and policies that meet compliance requirements. In many cases, the biggest roadblocks that companies faced when seeking compliance turned into opportunities to improve how the business operates.
Scientific research company
A company focused on photonics research needed to achieve CMMC compliance for future government contracts. The company regularly collects large amounts of experimental data and performs simulations as part of its core research.
When transitioning to Hyper Vigilance’s cloud-based platform for CMMC compliance, the company was concerned about its ability to access its datasets for performing simulations. With data sizes in the terabytes, transfers can take hours over a slow network connection.
Hyper Vigilance suggested that—rather than keeping both data storage and simulation tools on-site—the company move both to the cloud. The company could then spin up virtual machines as needed to perform its simulation and modeling tasks.
By making the move to the cloud, the company was able to run simulations on faster computers than it had access to on-site. Simulations that the company used to only run over the weekend could now be completed in an afternoon. The need to achieve CMMC compliance drove an infrastructure upgrade that made the business run better.
An international conglomerate with companies all over the world was planning to bid on US defense contracts. However, these DoD contracts mandate that all of the company’s work on the project remain within the US.
For a multinational organization, meeting CMMC requirements across the entire organization is difficult or impossible. International companies are subject to many different compliance requirements, often with mutually contradictory requirements. For example, CMMC requires that all data related to defense contracts remain within the US, while the EU’s GDPR restricts transfers of EU citizens’ data outside of certain countries.
Hyper Vigilance’s solution was to strictly define the set of devices needed for DoD contracts and achieve CMMC compliance only for this enclave. This more focused approach enabled the corporation to meet CMMC compliance requirements without unnecessary additional effort or jeopardizing its compliance with other applicable regulations.
Get Started with Cybersecurity Assessment from Hyper Vigilance
Achieving CMMC compliance can seem like a daunting task, but you don’t have to do it alone. Hyper Vigilance has extensive experience in helping companies to develop and implement CMMC and NIST cybersecurity strategies.
In many cases, our clients find that the CMMC compliance process turns into an opportunity to reimagine and modernize their IT infrastructure. Contact us to get started with the process of achieving your CMMC certification.
Read the next blog in this series: Building a CMMC Solution: Building and Testing.