As a DoD contractor or subcontractor, you already have CMMC on your radar. You’re working toward certification and implementing the best practices that will help you meet CMMC requirements. Now you’re ready for the next step—building a dedicated compliance team.
Creating a team dedicated to achieving and maintaining compliance is one of the most important things your organization can do to speed you on your CMMC journey. While it’s certainly true that compliance is everyone’s responsibility, a dedicated team will get you there in the most efficient way possible.
Key Roles and Responsibilities
An effective compliance team includes several key roles. Depending on the size of your organization, there might be overlap. One or more roles might be played by the same person, a role might be shared by more than one person, or it might be cost-effective to fill some roles by bringing in a third party consultant on your team. However you choose to fill them, these are the essential roles and responsibilities for a compliance team:
- CMMC Program Champion and Sponsor: A high-level executive is the best fit for this role, as they work with your team’s leadership to develop the company’s overall compliance strategy and provide sponsorship and guidance.
- CMMC Program Lead. Ideally a person well-versed in managing programs and projects for the company, this person will have frequent communications with the entire team. They coordinate compliance efforts across all departments and oversee the gap analysis process, creating and managing the Plan of Action and Milestones (POA&M) to address any identified gaps. This person will be the chief contact with the C3PAO during the assessment process. They will require extensive knowledge of the NIST 800-171 and CMMC frameworks.
- Security Lead and Analysts: The security lead role is best filled by the company’s chief information security officer (CISO), who develops and manages security controls based on CMMC requirements. They oversee system security and incident response planning. They may work with one or more security analysts, who conduct vulnerability assessments and penetration testing, monitor network activity for potential security threats, and analyze security logs and incident reports. All security team members should have expertise in the NIST and CMMC cybersecurity frameworks, risk management, and mitigation planning.
- Systems Administrator(s): For each in-scope IT system, an IT administrator manages system configuration to ensure compliance with CMMC standards. They develop and implement access controls and user management policies, support secure data storage, and ensure system updates are kept current to address vulnerabilities. Team members in this role should have security expertise for the system(s) they support.
- Risk Analyst/Auditor(s): Team members in this role conduct gap assessments and internal audits, ensuring system documentation is up to date and meets CMMC requirements. They track and report on compliance status for the team and company leadership. This role requires knowledge of the NIST and CMMC frameworks, experience with audit processes and risk analysis, and strong documentation skills.
- Training Coordinator: An HR or training specialist is a good fit to develop role-based training materials as well as company-wide training on CMMC awareness and cybersecurity best practices for all employees. This role requires experience in employee training and cybersecurity awareness programs.
- Legal/Contracts Specialist and Policy Writers: They will review contracts for compliance with CMMC requirements, ensures that the company meets all regulatory requirements, and coordinates with legal counsel to mitigate compliance risks. In addition, they will support other departments to write the policies and procedures related to CMMC Compliance.
- External CMMC Consultant (optional): If you choose to engage the services of a CMMC Third Party Assessment Organization (C3PAO) or Registered Practitioner Organization (RPO) to help you prepare for assessment, their team members can provide valuable advice and assistance. Representatives from these organizations should be Certified CMMC Assessors (CCAs) or Certified CMMC Professionals (CCPs) with strong expertise in cybersecurity and CMMC.
Important Activities
The principal activities of your compliance team will include the following:
- Gap Analysis: Assess your current security against CMMC requirements to identify any areas that need to be improved prior to assessment, resulting in your POA&M.
- System Security Planning (SSP): Develop security controls and implementation strategies, policies and procedures, resulting in SSP.
- Incident Response Planning (IRP): Develop mitigation strategies in the event of an incident or breach, resulting in your IRP.
- Control Implementation: Deploy security controls that meet CMMC requirements for all in-scope systems and data.
- Continuous Monitoring: Monitor systems on an ongoing basis for potential vulnerabilities and security breaches, as well as ensuring you remain in compliance.
- Assessment Preparation: Prepare for the assessment by gathering all necessary documentation and evidence to prove each requirement is met.
- CMMC Audit: Undergo assessment for the level of certification needed:
- Level 1: Self-assessment
- Level 2: Assessment by a C3PAO (or self-assessment for select programs)
- Level 3: Assessment by DIBCAC (Level 2 certification is required prior to Level 3.)
Additional Considerations
As you assemble your compliance team, keep these considerations in mind:
- CMMC Level: Your compliance team’s specific responsibilities and activities will depend on whether your company handles Federal Contract Information (FCI), requiring CMMC Level 1, or Controlled Unclassified Information (CUI), requiring CMMC Level 2 or 3.
- Collaboration: Remember that cybersecurity is everyone’s responsibility and that effective CMMC compliance requires collaboration among all departments within your organization.
- Staying Updated: Be sure to stay current on evolving CMMC requirements and cyber risks, and keep your employees informed by continuous training.
CyberNINES is a certified C3PAO and is ready to partner with your CMMC compliance team! Send us a contact request at this link, and one of our cybersecurity experts will reach out to discuss how we can help you achieve and maintain CMMC compliance.
Next up: Building a cybersecurity incident response team
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