Every company is struggling to implement security measures in order to stay ahead of hackers seeking unauthorized access to sensitive user data, personal information, health records, intellectual property, control unclassified information (CUI), and credit card data. One constant is the need for businesses of all sizes to implement a comprehensive cybersecurity program to combat these threats. Regulators have developed standards that must be followed in order to help ensure a better security posture for their industries, but doing so on its own becomes a check-box exercise with no real strategy. This is not a long-term solution and will not reduce the number of data breaches. When it comes to addressing CMMC, NIST 800-171 or any other framework (ISO, SOC, HIPAA, HITRUST) implementing a programmatic approach to your cybersecurity practices is paramount to your future business success.
When the latest cybersecurity regulation or executive order is issued, organizations typically do not act until an event occurs or are forced to act. Take the latest industry to be hit with new cybersecurity regulations, the Defense Industrial Base or DIB. When this new requirement to become certified was released (CMMC) which required organizations to first submit a self-assessment against NIST 800-171 and provide a score against the gaps (SPRS), there was a tremendous panic industry-wide to get it completed in the required 60-day window. This caused a lot of organizations to rush and potentially exaggerate their true SPRS Score. This wait-and-see approach carries significant risks for the organization and may expose it to additional problems in the future. Instead, organizations should view cybersecurity as a program that must be implemented. Like any other department in your organization, you must follow a systematic approach. Thus helping you to address new regulations, policy changes, and potential threats to your organization. Cybersecurity has many moving parts, not just data security, and you must bring all stakeholders to the table to develop an actionable plan to achieve the desired business outcomes.
Assessments are a great place to start because they provide a yardstick against standards such as CMMC and NIST 800-171. Beyond the assessment, there is much more work to be done, and demonstrating that you are addressing deficiencies within your organization is what the DoD is looking for. If you want your organization to continue to grow and prosper in the future, as well as win new government contracts, you must begin thinking about how to improve your security and take a systematic approach. Assessments are only a part of the process; they are not the end of the road. This is already a standard for other industry verticals, performing an assessment, then re-certifying year over year as the environment evolves and new changes are adopted to the security framework.
Let's think about how a cybersecurity program should be implemented based on how the NIST (National Institute of Standards and Technology) describes the Cybersecurity Lifecycle. NIST CSF (Cybersecurity Framework) is a widely used approach to help identify and address the highest priority risks within your business. The NIST framework outlines you these five high-level steps for creating a comprehensive cybersecurity program; Identify, Protect, Detect, Respond, and Recover.
Compliance is often viewed as an IT problem rather than a business problem, and this is where everything goes wrong. Consider who needs to be involved in order to address this complex issue. To begin, you must have an assessor who is familiar with the frameworks, how to put the controls into practice, and how you might have those implemented within your organization. There is also a remediator, which is the engineering team responsible for deploying new solutions to address deficient controls or performing the weekly, monthly, or yearly tasks required to maintain your level of compliance. The auditor is someone who isn't affiliated with the organization but needs some level of access to perform their duties to grant the certification or approval to operate. From start to finish, a great deal of coordination is required. We now need to include corporate stakeholders, end users, and the management team. They typically want to know the current status, where we are in relation to the framework (CMMC, NIST, HIPPA, SOC, HITRUST), what plans are in place to close the gaps, and the budget of resources and costs to get the organization to the finish line. In addition, how will the changes impact the organization's operations, and how disruptive will they be?
As you can see, this is more than an IT issue and requires collaboration from all siloed parties to achieve the goal. These four areas (assessor, remediator, auditor, and organizational stakeholders) have previously operated in silos, with no real system in place to keep everyone informed. Implementing a holistic approach will aid in the integration of these silos, resulting in a collaborative cybersecurity program that provides effective business change.
After reviewing the cybersecurity program model, one might wonder what tools are needed to keep track of everything. Most governance, risk, and compliance (GRC) platforms end at the assessment or assessment phase, with little to no planning, project management, contouring monitoring, or access to all stakeholders. Furthermore, they do not offer suggestions on how to close the gaps identified in the assessment, which is a significant roadblock in the process. Finally, there is no roadmap for completing the process, which includes resources, time, a budget, and a scorecard to track progress along the way. As a result, you are limited to separate systems, offline processes, and Excel spreadsheets. All of these offline processes take time and are difficult to track.
To manage a comprehensive cybersecurity program, GRC solutions with traditional features as well as the ability to incorporate PMO functionalities are required. CentrumCyber, for example, combines all of these stages into a single, simple-to-use comprehensive SaaS platform. Centrum Cyber is a comprehensive SaaS platform that gives you a single point of contact to manage and run your cybersecurity program. It adheres to the methodology described above, allowing for predictable results and the establishment of a cybersecurity program for your organization.