Key Steps To Becoming NIST Compliant

Companies seeking to obtain the elusive Department of Defense (DoD) contracts understand the need to meet Defense Federal Acquisition Regulation Supplement (DFARS) minimum cybersecurity standards controlling the processing, storing, and transmitting of Controlled Unclassified Information (CUI). Companies operating outside DoD research and development may want to look to the National Institute of Standards and Technology (NIST) frameworks as government officials and the public look for accountability over information systems and organizations’ data protection.

What is NIST and What Does It Do?

The National Institute of Standards and Technology (NIST), an agency of the U.S. Department of Commerce, plays a pivotal role in setting industry standards, advancing measurement science, and developing technology to enhance productivity, facilitate trade, and improve the quality of life. Founded in 1901, NIST‘s primary mission with the NIST cybersecurity framework (NIST CSF) is to promote U.S. innovation and industrial competitiveness by advancing measurement science, standards, and technology in ways that enhance economic security and improve our quality of life.

NIST‘s influence spans multiple sectors, including cybersecurity, manufacturing, and technology. It collaborates with industry and academia to develop more reliable and robust standards and guidelines that help organizations manage their cybersecurity risks. These efforts are critical in today’s digital landscape, where cybersecurity threats are increasingly sophisticated and pervasive – especially for government agencies and anyone working with government agencies.

What is NIST Special Publication 800-53?

NIST Special Publication 800-53, titled “Security and Privacy Controls for Federal Information Systems and Organizations,” is a comprehensive set of information security controls and guidelines designed to protect federal information systems. This publication is a part of NIST‘s broader efforts to provide federal agencies with the necessary tools and guidelines to maintain a robust cybersecurity posture.

The 800-53 publication outlines standards for implementing effective security measures to safeguard information systems against threats and vulnerabilities. It covers areas such as access control, incident response, business continuity, and risk assessment. These guidelines are continually updated to address emerging threats and technological advancements, making them relevant and applicable in the rapidly evolving cybersecurity landscape.

What is NIST Special Publication 800-171?

NIST Special Publication 800-171, “Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations,” is a critical document for private sector organizations, particularly those working with the federal government. This publication provides guidelines on how to secure sensitive but unclassified information, commonly referred to as Controlled Unclassified Information (CUI), when it is stored, processed, or used outside federal systems.

The document emphasizes the importance of protecting CUI in nonfederal information systems and organizations to mitigate the risk of data breaches and unauthorized access. NIST 800-171 is particularly relevant for contractors and suppliers to the federal government, as it outlines the expected security standards for handling information that, while not classified, is still sensitive and requires protection. Compliance with these guidelines is often a prerequisite for doing business with the federal government, ensuring a baseline level of security across all involved parties.

Requirements of NIST Compliance

Step 1: Create a NIST Compliance Risk Management Assessment

The foundation of NIST compliance lies in establishing a comprehensive risk management assessment. This process involves understanding and applying the guidelines set forth in NIST Special Publications 800-53 and 800-171 to your cybersecurity program as well as data security and data protection policies.

Delineating Risk Assessment in NIST 800-171

NIST 800-171 provides a concise overview of the risk assessment process. It mandates periodic evaluations of organizational risks, focusing on operational aspects, assets, and personnel who could potentially compromise the security of Controlled Unclassified Information (CUI) within information systems. To comply with these requirements, the publication advises conducting vulnerability scans and addressing identified vulnerabilities. However, NIST 800-171 offers limited details on the intricacies of the risk assessment process, prompting companies to refer to 800-53 for a more comprehensive understanding.

In-Depth Guidance from NIST 800-53

In contrast, NIST 800-53 offers a detailed framework for risk assessment. It encompasses a broad spectrum of considerations, including the purpose and scope of the assessment, roles and responsibilities, management commitment, coordination among organizational stakeholders, and adherence to relevant laws, executive orders, directives, policies, and guidelines. Furthermore, 800-53 outlines specific procedures to effectively implement risk assessment policies and controls. This publication not only details control baselines for the risk assessment process but also identifies which controls require rigorous assurance.

One significant aspect where NIST 800-53 goes beyond 800-171 is in the explicit inclusion of supply chain risk assessment and the assurance over risks posed by privileged access. It also delineates requirements for the frequency of vulnerability scanning and the use of automated trend analysis, offering a more granular approach to managing risk.

Bridging the Gap Between 800-171 and 800-53

While NIST 800-171 aligns its requirements with those in 800-53, it does not incorporate the same level of detail. Therefore, companies seeking to comply with NIST 800-171 can greatly benefit from the comprehensive guidance offered by 800-53. This is particularly true for organizations working with the Department of Defense (DoD) or those handling more sensitive data, where a deeper dive into risk assessment processes is essential.

For smaller companies dealing with CUI, the detailed approach of 800-53 may seem daunting, yet it provides invaluable direction for achieving compliance with 800-171. The key is to tailor the implementation of these guidelines to fit the company’s specific context and compliance objectives, ensuring a robust and effective risk management framework that aligns with NIST standards.

Step 2: Create NIST Compliant Access Controls

When striving for compliance with NIST standards, developing NIST-compliant access controls is a critical step. NIST 800-171 offers a high-level framework, similar to its approach in risk assessment, guiding companies towards meeting compliance requirements. This framework is particularly user-friendly, providing a more streamlined tutorial for compliance. For organizations seeking additional depth and detail, NIST 800-53 serves as a comprehensive supplement. Although the risk assessment process may appear complex, the guidelines for access controls in both publications are designed to provide clear and sufficient detail for effective implementation.

Access Controls as Outlined in NIST 800-171

NIST 800-171 lays out specific access control measures, such as:

• 3.1.4 Separate Duties: This control involves segregating individual roles and responsibilities to minimize the risk of malicious activities that could arise from collusion.
• 3.1.5 Employ Least Privilege: This principle mandates limiting access rights for users to the bare minimum necessary to perform their duties, applying this standard to all security functions and privileged accounts.

For many smaller companies, these directives offer a clear and actionable goal: maintaining distinct roles to prevent collaborative data theft and implementing access controls based on the principle of minimal necessary access.

Enhanced Access Control in NIST 800-53

On the other hand, NIST 800-53 introduces more dynamic and sophisticated requirements, such as:

• (6) Account Management | Dynamic Privilege Management: This involves implementing dynamic privilege management capabilities, which contrast traditional static account systems. Dynamic approaches depend on runtime decisions and attribute-based access control (ABAC). These methods adapt user privileges in real time based on current operational needs, changes in job functions, or emergency situations. This control enhancement not only includes the process of adjusting privileges but also extends to the consequent changes, like modifications in encryption keys used for communications.

To distill this requirement, companies aiming for NIST 800-53 compliance should adopt flexible and dynamic access control management systems. This means moving beyond the static model of ‘least privilege’ to a more nuanced approach that factors in the user’s location, working hours, and other contextual elements. NIST 800-53 emphasizes monitoring user activities for irregular access patterns and restricting unusual access to safeguard sensitive information.

Step 3: Prepare to manage audit documentation

Managing audit documentation is a critical step in achieving compliance with NIST standards. Both NIST 800-53 and 800-171 outline requirements for audit programs, but they differ in their level of detail and complexity.

Audit Documentation in NIST 800-171

For organizations aiming to comply with NIST 800-171, the guidelines for audit documentation are clear and concise. The primary requirement is for companies to maintain audit records that demonstrate continuous monitoring, analysis, investigation, and reporting of any illegal, unauthorized, or inappropriate activities within their information systems. These records should be capable of attributing specific actions to individual users, ensuring traceability and accountability.

NIST 800-171 recommends seven additional steps for assembling effective audit documentation. These steps are intuitive and include measures such as implementing alerts for audit process failures, correlating audit reviews to identify suspicious activities, ensuring accurate time-stamping, and restricting audit-related functions to a limited group of privileged users.

For many smaller organizations, the guidelines provided in NIST 800-171 are sufficiently comprehensive to guide their audit documentation practices.

Enhanced Detail in NIST 800-53

In cases where additional detail is required, NIST 800-53 offers an expanded view. This publication delves into specifics, such as explaining that audit processing failures can encompass a range of issues, including software and hardware errors, failures in audit capture mechanisms, and exceeding audit storage capacity. NIST 800-53 encourages organizations to define their response to audit processing failures based on factors like the type, location, severity of the failure, and the specific audit data storage involved.

This detailed approach can be particularly beneficial for organizations seeking a deeper understanding of audit management. NIST 800-53 covers not just the what and the how of audit documentation but also delves into the why, providing a comprehensive framework for understanding the nuances of audit management.

While not all companies are required to adhere to the extensive requirements of NIST 800-53, those seeking to supplement their NIST 800-171 compliance will find valuable insights in 800-53. It offers an in-depth perspective that can clarify and enhance the audit documentation process, especially in complex or high-risk environments. Understanding and implementing these guidelines ensures a robust and effective approach to audit management, aligning with the best practices outlined by NIST.

How Long Does It Take to Get NIST Certified?

The timeline for achieving NIST certification can vary significantly depending on several factors, including the size and complexity of the organization, the current state of its information systems, and its existing compliance with relevant NIST standards. Generally, the process can take anywhere from a few months to over a year.

1. Initial Assessment and Gap Analysis: This initial phase involves understanding the specific NIST standards applicable (such as NIST SP 800-171 or 800-53) and conducting a gap analysis to determine the current state of compliance. This process can take several weeks to a couple of months, depending on the organization’s readiness and the resources available for the assessment.
2. Implementation of Controls: Implementing the necessary controls to meet NIST standards is often the most time-consuming part of the process. This phase includes setting up proper security measures, policies, and procedures. The duration of this phase largely depends on the complexity of the required changes and the organization’s operational capacity. It can range from a few months to several months.
3. Documentation and Policy Development: Concurrent with implementing controls, developing comprehensive documentation and policies is essential. This process includes creating or updating security policies, incident response plans, and other necessary documentation. This phase can overlap with the implementation of controls and may take a few weeks to a few months.
4. Training and Awareness: Educating staff about new policies and procedures is crucial for compliance. The time required for training can vary but is generally not overly time-consuming.
5. Audit and Certification: Once all controls are in place and documentation is ready, an external audit is required. The audit itself may take a few days to a few weeks, depending on the organization’s size and the audit’s scope. Following the audit, if there are no significant issues, certification can be achieved relatively quickly.

Overall, the process of getting NIST certified is not a quick one and requires thorough preparation, implementation, and review. Organizations should plan for a comprehensive process that, in most cases, will span several months to a year.

How to Upgrade Your Cyber Risk Management Program with NIST?

GET FREE GUIDE

How Much Does NIST Certification Cost?

The cost of NIST certification varies widely based on several factors, such as the size of the organization, the complexity of its information systems, and the specific NIST standards it needs to comply with.

1. Gap Analysis and Initial Assessment: Hiring a consultant to perform a gap analysis and initial assessment can range from a few thousand dollars for small companies to tens of thousands for larger organizations.
2. Implementation of Controls: The most significant cost typically comes from implementing the necessary controls to meet NIST standards. This can include hardware and software upgrades, additional security measures, and hiring or training staff. The costs can range from a few thousand dollars for minor adjustments to hundreds of thousands or even more for extensive overhauls.
3. Documentation and Policy Development: Developing the necessary documentation and policies may require additional resources, either in the form of external consultants or internal staff time. The costs can vary but are generally not as significant as the implementation of controls.
4. Training and Awareness Programs: Costs for training and awareness programs can vary. Online training programs may be more cost-effective, while in-person training sessions can be more expensive.
5. Audit and Certification Costs: The final audit for certification can be a significant expense, especially for larger organizations or more complex systems. Audit costs can range from a few thousand dollars to tens of thousands of dollars.
6. Ongoing Compliance Costs: Beyond the initial certification, maintaining compliance with NIST standards involves ongoing costs, including regular audits, continuous monitoring, and updates to policies and systems.

The total cost of NIST certification can range from a few thousand dollars for small organizations with minimal requirements to several hundred thousand dollars or more for large or complex organizations. It’s essential for organizations to conduct a thorough cost-benefit analysis to understand the investment required for achieving and maintaining NIST certification.

How automation eases the burden of NIST compliance

Achieving compliance with NIST standards can be a complex and time-consuming process. However, with the integration of automation tools like ZenGRC, organizations can streamline their compliance journey, reducing both the time and effort required.

ZenGRC’s Gap Analysis Tool

One of the key features of ZenGRC that aids in NIST compliance is its gap analysis tool. This functionality enables organizations to conduct a comprehensive review of their existing controls and identify any gaps in compliance. By using ZenGRC, companies can quickly ascertain which areas require attention and what specific controls need to be implemented or updated to achieve compliance with various standards, including NIST.

Streamlining Compliance Across Standards

ZenGRC’s platform is particularly beneficial for organizations that are already compliant with other standards, such as ISO 27001. The overlap between ISO 27001‘s Information Security Management System (ISMS) requirements and NIST SP 800-171 standards means that companies with ISO 27001 certification are likely to have a foundational structure in place for NIST 800-171 compliance. ZenGRC simplifies the process of aligning these standards by highlighting commonalities and helping organizations efficiently leverage their existing compliance efforts to meet NIST requirements.

Automation Benefits

The automation provided by ZenGRC offers several significant advantages:

1. Efficiency: Automation speeds up the process of compliance by quickly identifying gaps and recommending necessary controls, reducing the manual workload on staff.
2. Accuracy: Automated tools minimize human error, ensuring a more accurate assessment of compliance needs and the effectiveness of implemented controls.
3. Consistency: ZenGRC helps maintain consistent compliance practices across various standards and regulations, which is essential for organizations managing multiple compliance requirements.
4. Real-time Monitoring: The platform offers real-time insights into the compliance status, helping organizations to stay on top of their compliance posture and make timely adjustments as needed.
5. Documentation and Reporting: ZenGRC aids in creating and maintaining necessary documentation, streamlining audit preparation, and providing comprehensive reports for internal and external stakeholders.

By utilizing ZenGRC, companies can navigate the complexities of NIST compliance more effectively. The tool’s capacity to automate significant portions of the compliance process not only accelerates the journey to compliance but also ensures a more reliable and consistent adherence to the required standards. This is particularly advantageous for organizations looking to align their compliance efforts across various frameworks, such as NIST and ISO 27001.

To see how ZenGRC can help your organization meet both NIST and ISO requirements, schedule a demo.