For many years, companies working with the US Department of Defense (DoD) treated regulatory mandates including the Cybersecurity Maturity Model Certification (CMMC) as a matter best left to the IT department. The prevailing belief was that installing the right software and patching vulnerabilities would suffice. Yet, reality tells a different story.
Increasingly, audits and assessments reveal that when compliance is seen narrowly as an IT responsibility, significant gaps emerge. In today’s business environment, managing controlled unclassified information (CUI) and federal contract information (FCI) is a shared responsibility across various departments – from human resources and manufacturing to legal and finance.
This realization sets the stage for a more comprehensive approach that begins with reassessing not just digital defenses, but the entire organizational risk management framework.
Bridging Digital and Physical Security
While digital security is a significant part of overall CMMC compliance, it is vital to ensure strong physical security measures are in place. Sensitive paper documents are kept in filing cabinets and on desks, so any lapse in physical security can undermine even the best digital protocols. Organizations should therefore focus on a few key practices:
- Restricted access: Limit entry to premises and secure areas so that only authorized personnel can access sensitive materials
- Secure storage: Protect physical documents containing CUI or FCI by using locked storage facilities and controlled access systems
- Visitor procedures: Put clear processes in place for site visitors to ensure access is only ever granted to the right people
Integrating the Human Element
Once physical and digital controls are in place, the next step is to train the people who use them. The most advanced systems on the planet can be rendered insufficient by human error, so helping each person be aware of security measures – and the reasons they are needed – is an essential part of CMMC compliance.
Training should focus on handling confidential documents correctly, identifying scamming attempts such as phishing and creating everyday routines that reinforce security, for example, locking laptops when leaving them unattended.
Turning training into impact can be done with a formal Plan of Action & Milestones (PoA&M), drawn from the results of a gap analysis. With the results, shortfalls can be identified and training put in place to mitigate them, helping those within the organization make security second nature.
Establishing measures such as these not only reduces the likelihood of being found non-compliant but also provides practical actions that help people understand clearly how to put policy into action. This need for proactivity is also the underlying principle of the next step.
Staying Up to Date
While clear policies are vital to CMMC compliance, they are no good if they have fallen out of date. As threats evolve, so must security. Continuously updating internal policies is how companies can highlight new requirements, and this process will most likely require a team effort between the legal and human resources departments.
Revising policies to embed security in all operations means that businesses can be certain that their team understand how to properly safeguard sensitive information. For example, guidelines on handling CUI and FCI should be explicitly detailed in employee handbooks, while cybersecurity responsibilities should be integrated into job descriptions and performance reviews.
The regular updating of policies keeps a company’s security position dynamic and adaptable; a key strength as new threats and regulations emerge.
However, even with updated policies in place and a well-trained workforce supporting both digital and physical security measures, the journey to compliance must be seen as an ongoing practice rather than an end destination.
Embracing Continuous Assurance
For CMMC compliance, there needs to be continuous assurance involving regularly monitoring systems, testing controls and adapting security protocols whenever necessary. In practice, continuous assurance means:
- Regular gap analyses to identify shortcomings early
- Ongoing security assessments to ensure controls remain effective
- Creating strategies with adaptability built in
For a gap analysis to be effective, it must be carried out by a team that understands the processes and regulations in place, as well as the importance of accuracy. In the previous iteration of CMMC, companies could self-attest and score themselves from -203 (‘significant concern’) to +110 (‘highly secure’).
Several hundred companies reviewed their processes and gave themselves a perfect score. However, when the DoD performed spot checks on these companies, their marks differed wildly, with some as low as -130.
The primary focus of any strategy should be on creating a security-aware culture within the company. Organizations Seeking Certification (OSC’s) can embed continuous assurance into everyday operations with assistance from third-part assurance providers such as LRQA, and ensure that compliance is not a static milestone, but an evolving journey that anticipates future challenges.
A Forward-Thinking Approach
Businesses are having to rethink much of their approach to security because of CMMC requirements. Rather than treating it as something to be handed off to the IT department, organizations must now commit to a comprehensive, company-wide strategy.
Integrating thorough physical security, ongoing training, updated internal policies and steps for continuous assurance mean companies can build a resilient framework that meets today’s regulatory demands and prepares them to rise to challenges on the horizon.
In an era where data breaches and cyber threats are a constant reality, adopting a holistic approach to cybersecurity is essential. This strategy ensures that every department plays a part in safeguarding the organization’s future, transforming compliance from a narrow technical task into a full-scale cultural commitment.