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Happily-Ever-After might work in fairy tales, but in the world of cybersecurity compliance, there’s no magical ending. Achieving CMMC certification is a significant milestone, but it’s not the finish line—it’s the starting point. Just as newlyweds must navigate life’s ongoing adventures and challenges, organizations must continuously adapt and strengthen their security posture to maintain compliance and protect sensitive data. Certification is merely the beginning of your company’s long-term commitment to cybersecurity excellence.
Start Planning for Ongoing Security and Maintenance Now
CMMC compliance is a continuous cycle. In between the formal C3PAO assessment every three years, you are required to affirm your compliance annually. Ongoing compliance will go more smoothly if you set yourself up for the long term now, even as you prepare your company for the initial certification, by implementing the following strategies.
- Compliance culture. Keep your employees engaged with security efforts and aware of potential threats, and encourage them to report any suspicious activity.
- Configuration management and continuous improvement. Keep your software up to date, enforce change control processes, and regularly review your security controls to ensure they address emerging threats.
- Security audits. Schedule and conduct regular security audits to quickly identify and remediate any compliance gaps. Pay particular attention to user access controls and privileges, and make sure these are updated or removed as soon as employees change roles or leave the company.
- Incident response planning and testing. Engage your incident response team to implement a robust incident response plan and test it regularly using drills and simulations.
- Third party risk management. Take time to understand the cybersecurity practices of your third-party vendors, and if they handle sensitive government data for you, verify that they maintain the necessary level of CMMC compliance.
- Continuous monitoring. Make sure your monitoring systems are robust enough to identify threats and breaches in real time, so that you can quickly respond when an incident occurs. (See more below and in a future post.)
Keep up with Evolving Standards
Because cyber threats are constantly evolving, you can expect that CMMC standards will also evolve. Following these best practices can help you stay on top of the continuous cycle of change.
- Stay informed. First and foremost, make sure your company stays up to date on CMMC changes. Your compliance team should actively monitor updates to CMMC so that you can adapt your practices to meet the new requirements.
- Partner with a C3PAO or RPO. Organizations with CMMC expertise, such as CyberNINES, make it their business to stay on top of the changing cyber landscape, including changes in CMMC standards. Working with one of these organizations can give your company an edge in adapting quickly when requirements change.
- Continue self-assessing and self-improving. Conduct regular periodic self-assessments comparing your current compliance posture against evolving standards. As the standards change, be aware of new gaps that open up and then formulate and implement plans to remediate those gaps.
- Keep your eye on your CUI. Know where your sensitive government data is stored and keep it isolated from other data as much as possible. This will keep you more agile in protecting this data in the face of new or changing requirements.
- Keep your documentation up to date. Thoroughly document your company’s security policies and procedures and how they are implemented. As the policies themselves change in response to new requirements, make sure the documentation is also updated.
- Keep your employees in the loop. As new threats evolve and standards change, use strategic communication and training to keep your employees aware of and knowledgeable about new developments and requirements.
Never Underestimate the Power of Continuous Monitoring
Continuous monitoring is vital both for maintaining compliance and for responding to evolving threats. Proactive monitoring allows you to detect incidents as soon as they occur, enabling quick response and remediation and reducing the damage such breaches can cause. It also provides you with the data you need to prove ongoing compliance. Continuous monitoring involves some key activities, which can be enhanced using automated tools.
- Analyze system logs for suspicious activity.
- Scan systems regularly to identify any vulnerabilities or weaknesses.
- Aggregate and analyze data from all areas of your organization using security information and event management (SEIM) tools.
- Conduct regular assessments of your security controls to confirm they are working effectively.
We will take a more in-depth look at continuous monitoring in a future post.
CyberNINES keeps up with evolving CMMC standards, and we’re in it with you for the long term. Contact us at this link and see how we can help you maintain compliance after certification.
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