Department of Defense contractors and their subcontractors have until December 31 to obtain DFARS compliance
Third-party data breaches are a serious problem, especially when highly sensitive data is involved – and our nation’s infrastructure, including our defense systems, are built and maintained by third-party government contractors. Recognizing this, the U.S. Department of Defense is requiring that all of its contractors, as well as their subcontractors, comply with the security controls specified in NIST Special Publication 800-171r1, also known as DFARS (Defense Federal Acquisition Regulation Supplement). The deadline for DFARS compliance is December 31, 2017.
As expected, DFARS compliance mandates that DoD contractors and subcontractors adhere to rigorous protocols to protect sensitive data and promptly report cyber incidents. However, DFARS also goes a step further by additionally mandating the protection of “Unclassified Controlled Technical Information (UCTI).” UTCI is defined as “information that requires safeguarding or dissemination controls pursuant to and consistent with applicable law, regulations, and government-wide policies.”
This rather broad definition means that any organization that is handling DoD data, whether as a direct (prime) contractor or a subcontractor, must comply with DFARS.
Understanding DFARS Compliance
DFARS compliance was originally based on NIST Special Publication 800-53, which contains 18 control families and 303 requirements. However, after many contractors found the rules to be overly complex, NIST released Special Publication 800-171, which condensed the protocols down to 14 control families and 109 requirements. This was later updated to NIST Special Publication SP800-171r1.
While DoD contractors are accustomed to adhering to comprehensive security controls, since DFARS addresses the security of unclassified systems, many contractors will have to extend their controls to cover additional systems.
Noncompliance with DFARS is not an option for contractors and subcontractors who wish to continue working with the DoD after the December 31 deadline. There is no reason to believe that the DoD will extend this deadline and every reason to believe it will abruptly cut off any contractors who are not compliant. The agency recently held an Information Industry Day emphasizing the importance of DFARS compliance and reminding attendees of the approaching deadline.
In addition to enabling an organization to continue working on DoD contracts, there is inherent strategic value in DFARS compliance. Other public and private-sector organizations know how rigorous DFARS compliance standards are and recognize that service providers who are compliant are serious not only about their own cyber security but that of their own third-party vendors. It also demonstrates due diligence in the event of legal action or matters of business insurability.
Is your organization ready to meet the December 31 deadline? DFARS compliance is complex, and time is running out, which is why it’s best to enlist the help of a professional IT audit and cyber security firm so that you achieve compliance on budget and on schedule.
Michael Peters is the CEO of Lazarus Alliance, Inc., the Proactive Cyber Security™ firm, and Continuum GRC. He has served as an independent information security consultant, executive, researcher, and author. He is an internationally recognized and awarded security expert with years of IT and business leadership experience and many previous executive leadership positions.
He has contributed significantly to curriculum development for graduate degree programs in information security, advanced technology, cyberspace law, and privacy, and to industry standard professional certifications. He has been featured in many publications and broadcast media outlets as the “Go-to Guy” for executive leadership, information security, cyberspace law, and governance.