Is your small business at risk of cyber threats that could cost you your next Department of Defense contract? As DoD suppliers gear up for new Cybersecurity Maturity Model Certification (CMMC) standards, many small enterprises may feel like they are navigating uncertain waters.
For small businesses that want to qualify for Defense contracts, achieving CMMC compliance will be mandatory. This introduces significant changes to operations, systems, and policies to prove satisfactory cybersecurity risk management. Developing formal CMMC-aligned policies is a foundation for building more mature processes.
This article outlines 5 policy templates that small businesses should prioritize having in place.
1. Access Control Policy
Access control tops CMMC priorities. Policies centralize permissions management for networks, systems, and data. CMMC policy templates establish baseline expectations around access controls for small businesses seeking certification.
Require multi-factor authentication for all network access. Additional factors like biometric checks or one-time numeric tokens heighten protection. Data classifications frame access decisions. Categories determined by sensitivity level dictate authorized user access. Classifications apply encryption, monitoring, and sharing rules.
Enforce least-privilege permissions models only to grant essential access for specific roles. Separation of duties further limits abilities based on business needs. Complex password policies enforce length, character sets, expiration timelines, and prohibition of repeats. Rotation frequency increases for elevated privilege accounts.
Formal access review processes approve, track, and revoke permissions regularly. Checkpoints include new hire assignments, employee changes, offboarding, and third-party affiliations.
The policy sets the expectation for identity and permission oversight by centralizing control of logical and physical access. As small businesses mature security postures under CMMC, automated user provisioning and access reviews manifest policy aspirations.
2. Asset Management Policy
Asset management is a central CMMC component. Companies must track and secure all hardware and software. Comprehensive policies aid accountability across IT environments.
The formal policy mandates tools to inventory assets continuously. Details like device types, owners, locations, and purposes log within centralized databases. Standards categorize criticality designations based on business function and data access.
Regular unscheduled audits ensure completeness and accuracy. Gaps highlight policy and process adjustment needs visibility, enabling certification and operational security.
Guidance for asset reassignment, disposal, or offboarding outlines risk treatment procedures. Examples include secure wipe protocols, equipment destruction methods, and revocation of access credentials. Stringency increases for end-of-life activities on hardware storing sensitive data.
The policy sets configurations and hardening standards for new assets. Security teams approve purchases and then configure devices and software to comply before production deployment. Enforced mechanisms manage changes through maintenance windows and patch management.
3. Media Protection Policy
A core tenet of CMMC is safeguarding sensitive data. Companies must institute media protection policies governing information storage, transmission, and destruction.
Central to a media policy is establishing data classifications. These categories tier information according to sensitivity levels. Classifications dictate authorized access, sharing rules, backup regimes, and destruction requirements.
The policy specifies permitted media formats for each data type. Approvals depend on the security capabilities of platforms like cloud storage, email, removable media, and legacy systems. Stipulations aim to prevent unauthorized exposure.
Mandatory encryption applies for both data at rest and in transit. Examples include encrypting file shares, databases, and network communications using protocols like SSL/TLS. This prevents data loss from stolen or misplaced devices.
Strict procedures govern media handling by personnel. Secure storage tactics reduce exposure, while transport guidance protects data in motion. Controlled backup processes adhere to the CIA triad, ensuring confidentiality, integrity, and availability.
The policy sets required destruction techniques when repurposing or disposing of IT assets. It tailors erase and destroy methods to the highest data classification equipment ever stored or transmitted.
For third parties, the policy extends oversight through legal contracts and security reviews. Providers supporting services like cloud or backup operate under similar protection regimes meeting CMMC demands.
4. Incident Response Plan
A mature incident response plan is fundamental for small businesses to fulfill CMMC requirements for cybersecurity events. The incident response policy necessitates explicitly defined procedures that activate organizational resources after detecting compromises like data leaks, malware, lost devices, or insider threats.
This entails designating personnel roles across technical, legal, communications, and executive domains alongside response workflows for each party. Policy elements also outline communication timings and methods to internal stakeholders plus external entities if obligations arise around breach notification laws or customer agreements.
Furthermore, the policy contains expectations around securing systems and evidence for forensic activities while initiating containment and remediation actions to minimize business disruption. Documentation takes priority during the response process, as activities, damage assessments, and decision rationale all need capturing within ticketing systems and reports.
Once the incident is stabilized, mandatory procedures for comprehensive analysis take effect to determine root causes, identify gaps that require improvement, and extract metrics that inform leadership.
By instituting robust incident response policies aligned to known threats, small businesses ready themselves for certification while improving their chances of success in navigating real-world events. The policy then evolves into playbooks, trained teams, and tested detection capabilities as organizations climb CMMC maturity levels.
5. Audit and Accountability Policy
A core requirement of CMMC is demonstrating policy adherence through auditing and accountability measures. Small businesses must institute formal audit policies and procedures that facilitate necessary visibility into their security controls.
An audit policy first sets expectations for routine vulnerability scanning and penetration tests that reveal flaws in networks, applications, or devices. Any critical vulnerabilities uncovered then feed into documented remediation processes. Secondly, the policy mandates enabling activity logging capabilities across servers, endpoints, databases, and other systems handling sensitive information. These event logs are centralized in a secured log management program for monitoring and retrospective analysis.
Another critical area covered under the audit policy requires recurring access control reviews that check for authorization rights like unused accounts, overprovisioned privileges, or violations of least privilege principles. The policy furthermore institutes requirements for conducting quarterly cybersecurity audits, inspections, and spot checks to reveal policy gaps. Documentation and evidence like completed audit reports, logs, metrics, and remediation tickets help satisfy CMMC proof demands.
A well-constructed audit policy and associated accountability mechanisms give small businesses the foundations to achieve essential CMMC compliance and evolve evidence of intermediate process maturity as they aim for higher certification tiers. Managed services can then build on these policies to manifest and automate security activities that might overwhelm small internal teams.
Conclusion
Achieving CMMC compliance introduces significant transitions for DoD’s supply chain members regardless of company size. Implementing cybersecurity-focused policies across essential CMMC domains provides the groundwork for certification eligibility and building long-term risk management maturity.
The policy templates outlined serve as a starting point for small businesses to demonstrate the underlying rigor necessary for basic CMMC certification and opportunities to support Defense contracts moving forward.
