C-suite cybersecurity responsibilities include promoting a security culture, aligning cyber and business strategies, and provision of resources. This requires involvement by all executives not the Chief Information Security Officer (CISO). The prevention of a cybersecurity incident should be a key element in business strategy because of loss of operations, financial loss, and damage to organizational reputation. Additionally, executives should address contractual obligations or regulatory requirements for the handling of customer data.
Executive Requirements for NIST SP 800-171
NIST SP 800-171 is a set of guidelines designed to protect Controlled Unclassified Information (CUI) in non-federal systems and organizations. It provides recommended security requirements to ensure the confidentiality of CUI, particularly for contractors and subcontractors working with the federal government.
The Cybersecurity Maturity Model Certification (CMMC) is a program developed by the U.S. Department of Defense (DoD) to ensure that contractors in the Defense Industrial Base (DIB) adequately protect sensitive information. This includes Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). CMMC is built on the requirements of NIST 800-171, but it includes a third-party assessment process for certification.
CMMC requires that a senior executive certify compliance with the cybersecurity standards in the Supplier Performance Risk System (SPRS). Executives are accountable for ensuring that the organization meets and maintains cybersecurity requirements.
C-suite leaders should allocate budget resources for compliance initiatives. This includes costs associated with implementing security controls and ongoing maintenance. Executives must understand the risks of non-compliance, which can jeopardize contracts and revenue opportunities especially when securing government contracts.
A Call to Action
Fundamental Responsibilities
The importance of C-suite cybersecurity responsibilities in a viable information security management system are not fully appreciated by many businesses today. Unfortunately, the notion that cybersecurity responsibilities can be delegated to the IT department still hangs on. Cybersecurity requirements must be addressed by top management to address regulatory and contractual requirements. They must also address business continuity and financial risks associated with potential cyber incidents.
Defining the Scope of the Cybersecurity Program
Defining the scope of a program prioritizes efforts and ensures that all critical areas are addressed systematically. Typically this involves identifying objectives, determining which systems and assets need protection, engaging stakeholders, and understanding applicable regulatory requirements.
Perhaps the most daunting task, especially for older organization is determining which assets are to be protected. Information in various forms is shared in various departments throughout an organization. Positively identifying and labeling large amounts that data can be challenging. In many cases automated tools can be used to perform these tasks but this can sometimes hamper productivity by creating excessive access rights.
Establishing a Compliance Culture
Cybersecurity is a responsibility for every person in an organization. Establishing a culture that prioritizes cybersecurity helps mitigate risks and enhances overall security posture. This can be accomplished by establishing policies that outline how an organization protects its digital assets and sensitive information. This should include defining roles and responsibilities to ensure compliance and security.
Requirements for employee awareness and training should be ascertained and addressed. Role specific training requirements should also be considered for key positions within the program.
Monitoring and Maintaining a Cybersecurity Program
It is essential that a cybersecurity program is regularly assessed to identify vulnerabilities and determine program effectiveness in a changing risk environment. This includes assessing the organization’s current cybersecurity posture, discussing potential risks, and evaluating the effectiveness of existing measures. Organizations should conduct internal audits at least annually. However, more frequent audits may be necessary based on changes in systems, processes, or regulations.
CVG Strategy Information Security Management System Consultants
CVG Strategy can assist your organization meet the challenges in developing a cohesive information security management system. We are dedicated to helping small businesses navigate federal regulations and contract requirements for Quality Management, Cybersecurity, Export Compliance, and Test and Evaluation. We can help you meet your information security management system goals. CVG Strategy QMS experts can provide the training required to understand and engage in a ISMS and make it meet desired objectives.
Identify CUI Areas with CVG Strategy Signs
CVG Strategy provides signs to identify areas containing CUI and export controlled items. These signs should be posted at all facility entrances where products are being produced or services are being performed that are under the control of the U.S. Department of State Directorate of Defense Trade Controls (DDTC) and are subject to the International Traffic in Arms Regulations per title 22, Code of Federal Regulations (CFR), Parts 120-130.