Sorry to tell many of you, your System Security Plan (#SSP) sucks. As the start of CMMC draws nearer, we are now seeing more SSPs by other companies and, well, they miss the mark and are not effective.
Unfortunately, many organizations are grabbing the NIST SSP template for NIST SP 800-171 Rev 2, and well, if OFFICIALLY SUCKS. (Hint Hint, wink wink, nudge nudge Ron Ross and Victoria Yan Pillitteri… new version for Rev 3???).
In this As the CMMC Churns, we walk you through how to write an effective SSP that explains your plan at the Assessment Objective level and show you how to use the same SSP to link your correlated evidentiary artifacts for each Security Requirement.
We will also walk through a simple example, 3.1.9, Provide privacy and security notices consistent with applicable CUI rules, to show how we documented the requirement for Peak InfoSec. This is done using our free templates available at https://lnkd.in/eDATiGuY.
Now a couple key rules to pull out of the video:
1. Don’t use the NIST SP 800-171 Template provided by NIST.
2. Draft SSPs don’t count during an assessment and technically your score is now a -203 if this is your first draft.
3. Explain your network diagrams. Dumping diagrams in your SSP or as supporting artifacts is useless and will cause your assessor to wander around and misinterpret things.
Lastly, your SSP is the foundation of how you tell the 3rd party assessor your story of how you meet the NIST SP 800-171 Security Requirements. We get it sucks to write one, but an effective SSP will streamline your 3rd party assessment process.
Key CMMC Organizations
- National Archives & Records Administration Controlled Unclassified Information (CUI) Homepage
- DoD CIO’s Cybersecurity Maturity Model Certification (CMMC) Home Page
- Cyber Accreditation Body (Cyber-AB)
- Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) Contractor Resource Page
- Defense Industrial Base (DIB) Cybersecurity Portal
Key Regulations
Key Acquisition References
- 48 CFR § 52.204-21 – Basic Safeguarding of Covered Contractor Information Systems
- DFARS Clause 252.204-7008 Compliance with Safeguarding Covered Defense Information Controls.
- DFARS Clause 252.204-7012 Safeguarding Covered Defense Information and Cyber Incident Reporting.
- DFARS Clause 252.204-7019 Notice of NIST SP 800-171 DoD Assessment Requirements
- DFARS Clause 252.204-7020 NIST SP 800-171 DoD Assessment Requirements.
- DFARS Clause 252.204-7021 Compliance with the Cybersecurity Maturity Model Certification Level Requirements.