The expert's guide to NIST SP 800-171

NIST 800-171 is a set of guidelines established by the US National Institute of Standards and Technology (NIST) for the protection of Controlled Unclassified Information (CUI). The guidelines apply to any non-federal organization that processes, stores or transmits CUI, including organizations that handle such information on behalf of the government.

What is CUI?

CUI is defined by the US government as any information that requires safeguarding or dissemination controls, but is not classified under Executive Order 13526, “Classified National Security Information,” or the Atomic Energy Act, as amended. This means that CUI is sensitive but unclassified information that the government deems necessary to protect. Examples include financial, proprietary, medical, and other types of sensitive data.

Why is NIST 800-171 important?

NIST 800-171 is essential for organizations that handle CUI because it provides a set of baseline security requirements that must be met. Compliance with NIST 800-171 is also often required as a contractual obligation by the government or other organizations.

What are the requirements of NIST 800-171?

The requirements of NIST 800-171 are divided into 14 categories, each with its own set of controls. These categories include access control, audit and accountability, awareness and training, configuration management, identification and authentication, incident response, maintenance, media protection, personnel security, physical protection, risk assessment, security assessment, system and communications protection, and system and information integrity.

Some of the specific controls required by NIST 800-171 include implementing access controls for systems and data, regularly monitoring and analyzing audit logs, providing awareness training to employees, ensuring the secure configuration of systems, conducting regular risk assessments, and implementing incident response procedures.

How can organizations implement NIST 800-171?

Organizations can implement NIST 800-171 by conducting a thorough assessment of their systems and processes to identify any gaps in security controls. They can then implement the necessary controls to meet the requirements of the standard. This may involve upgrading existing systems and software, implementing new security solutions, and training employees on security best practices.

Organizations may also seek third-party validation of their compliance with NIST 800-171. This may involve undergoing a security assessment by a certified third-party assessor or submitting a self-assessment to the government.

In conclusion, NIST 800-171 is a critical standard for any organization that handles CUI, whether as a contractor or subcontractor to the US government or otherwise. Compliance with NIST 800-171 not only protects sensitive data but also helps organizations avoid legal and financial penalties for non-compliance. By implementing the controls required by NIST 800-171, organizations can enhance their overall security posture and reduce their risk of data breaches and cyber attacks.

NIST 800-171 is a publication that outlines cybersecurity requirements for government contractors and subcontractors who process, store, or transmit Controlled Unclassified Information (CUI) on their networks. The cybersecurity requirements set by NIST 800-171 are designed to safeguard sensitive government information and protect it from cyber threats.

1. Enhance Cybersecurity Resilience: The primary purpose of NIST 800-171 is to enhance cybersecurity resilience for the federal government supply chain. Government contractors and subcontractors must follow specific cybersecurity requirements to ensure that sensitive information is secure, as well as prevent potential cyber-attacks that could compromise national security. By setting these cybersecurity standards, NIST 800-171 helps contractors and subcontractors strengthen their security posture.
2. Protect Controlled Unclassified Information: NIST 800-171 is designed to protect Controlled Unclassified Information (CUI) from unauthorized access and exfiltration. CUI refers to information that is not classified but is sensitive and requires protection. This information may include financial information, medical information, or other information that, if compromised, could harm national security or public safety. NIST 800-171 provides contractors and subcontractors with a standardized approach to safeguard CUI throughout their IT networks.
3. Ensure Compliance with DFARS: NIST 800-171 is a requirement for government contractors and subcontractors to comply with the Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.204-7012. The DFARS requires contractors and subcontractors to implement cybersecurity controls to safeguard CUI on their IT networks. By complying with NIST 800-171, contractors and subcontractors can meet the requirements of the DFARS and ensure they are eligible for government contracts.
4. Create a Unified Baseline Standard: NIST 800-171 creates a unified baseline standard for cybersecurity across the federal government supply chain. All contractors and subcontractors who have access to CUI must adhere to the same cybersecurity requirements, ensuring consistency across the supply chain. This unified baseline standard simplifies the compliance process for contractors and subcontractors and helps the government assess the security posture of its contractors.

In summary, the primary purpose of NIST 800-171 is to safeguard Controlled Unclassified Information (CUI) and enhance cybersecurity resilience across the federal government supply chain. By setting specific cybersecurity requirements for government contractors and subcontractors, NIST 800-171 ensures that sensitive government information is secure and protected from cyber threats. It also helps contractors and subcontractors comply with the DFARS and creates a unified baseline standard for cybersecurity.

Controlled Unclassified Information (CUI) is a term used to describe unclassified information that is sensitive and requires safeguarding or dissemination controls. CUI is information that is sensitive but not classified. This type of information can be found in various forms, including reports, technical information, and drawings. The information may be produced by the government or its contractors, or it may be given to the government by a non-federal entity.

CUI Categories and Definitions

The CUI framework includes 23 categories of information, which are defined and described by federal agencies. These categories include financial information, controlled technology, privacy, law enforcement, and intelligence. The categories of CUI are listed in the CUI Registry, which is maintained by the National Archives and Records Administration (NARA). The CUI Registry is a central repository of all CUI categories and subcategories.

Each category of CUI has specific requirements for how it should be marked, handled, and protected. This includes who is authorized to access it and the types of controls that need to be in place. Federal agencies are responsible for implementing their own policies and procedures to protect CUI, including training employees on how to handle and safeguard CUI.

Protecting CUI

The NIST 800-171 framework provides a set of security controls that must be implemented by government contractors and their subcontractors that handle CUI. The controls are designed to ensure the confidentiality, integrity, and availability of CUI. These controls cover a range of security measures, including access control, incident response, and risk assessment.

Organizations that handle CUI are required to implement and maintain an Information Security Management System (ISMS) to manage the security of their networks and systems. The ISMS should include policies, procedures, and standards for protecting CUI. The system should also include regular risk assessments and audits to identify vulnerabilities and ensure that security controls are effective.

Consequences of Non-Compliance with NIST 800-171

Non-compliance with NIST 800-171 can have serious consequences for government contractors and subcontractors. Failure to implement the required security controls can lead to data breaches, which can result in loss of contracts, lawsuits, fines, and reputational damage. Furthermore, the government may withhold payments to contractors that are not in compliance with the regulations.

In conclusion, CUI is sensitive but unclassified information that requires safeguarding or dissemination controls. The protection of CUI is vital to maintaining national security and ensuring the confidentiality, integrity, and availability of sensitive information. Compliance with NIST 800-171 is essential for government contractors and subcontractors who handle CUI to ensure the safety and security of this information.

NIST 800-171 requirements were introduced to safeguard Controlled Unclassified Information (CUI) in the networks of government contractors and subcontractors. There are 110 requirements outlined in NIST 800-171, each covering different areas of an organization’s IT technology, policy, and practices. In this article, we will provide an overview of the requirements used to protect CUI.

1. Access Control: The access control requirements mandate that organizations limit system access to authorized users, processes, and devices. They must also assign unique user identification credentials and provide additional authentication factors, such as multi-factor authentication. User accounts must also be disabled after a defined period of inactivity.
2. Awareness and Training: The awareness and training requirements dictate that organizations provide employees with cybersecurity awareness training that covers a wide range of topics, including recognizing phishing attacks and maintaining good password hygiene. Employees who handle CUI should receive additional training on handling, protecting, and securing CUI.
3. Audit and Accountability: The audit and accountability requirements necessitate that organizations implement audit mechanisms to record and monitor system activity. They must also conduct periodic reviews of audit logs, report audit log review results to appropriate personnel, and take action on any identified issues.
4. Configuration Management: The configuration management requirements state that organizations must establish and maintain baseline configurations and inventories of authorized devices, software, and firmware. They must also regularly review and update these configurations, and use the latest versions of all software and firmware.
5. Identification and Authentication: The identification and authentication requirements mandate that organizations use multifactor authentication for local and network access to systems handling CUI. Passwords must meet specific complexity and length requirements and must be changed frequently. The organization must also disable account access for individuals who have left the organization.
6. Incident Response
7. The incident response requirements dictate that organizations must establish an incident response team and plan. They must also train personnel on their roles and responsibilities during a cybersecurity incident and conduct periodic incident response exercises.
8. Media Protection: The media protection requirements mandate that organizations implement procedures to protect and handle CUI during all stages of media use, including transport, storage, and destruction. Organizations must also sanitize or destroy CUI on media before disposal or release for reuse.
9. Physical Protection: The physical protection requirements state that organizations must control physical access to their facilities and equipment containing CUI. They must also implement procedures to protect and monitor equipment and media containing CUI.
10. Risk Assessment: The risk assessment requirements mandate that organizations conduct risk assessments to identify risks and vulnerabilities to CUI. They must also document and mitigate risks and vulnerabilities identified through the assessment process.
11. Security Assessment: The security assessment requirements dictate that organizations perform periodic assessments of the security controls implemented to protect CUI. They must also document and track any deficiencies and remediation actions taken.
12. System and Communications Protection: The system and communications protection requirements mandate that organizations implement procedures to protect and monitor information systems and the communications channels that transmit CUI. They must also employ encryption to protect CUI during transmission and at rest.
13. System and Information Integrity: The system and information integrity requirements state that organizations must implement measures to detect and prevent unauthorized changes to CUI, including tamper-evident technologies, intrusion detection systems, and antivirus software. They must also employ mechanisms to prevent the execution of unauthorized software on their systems.

NIST 800-171 requirements provide a comprehensive framework for organizations to protect CUI in their networks. The 110 requirements cover various areas of an organization's IT technology, policy, and practices, ensuring that each aspect of the network is appropriately secured. The requirements not only safeguard the CUI but also strengthen the overall cybersecurity resilience of the federal supply chain.

Anyone who handles CUI on behalf of federal agencies, including government contractors, subcontractors, and some state agencies, must comply with NIST 800-171. Compliance is critical to ensure the protection of sensitive government information and maintain relationships with federal agencies. Here is the list of entities that should comply with NIST 800-171:

Government Contractors: The primary group required to comply with NIST 800-171 is government contractors, including small businesses, universities, and non-profits, that handle Controlled Unclassified Information (CUI) on behalf of federal agencies. These contractors must comply with the 110 requirements set out in the standard to safeguard CUI, which is defined by the government as information that is sensitive but not classified.

Subcontractors: In addition to government contractors, subcontractors that handle CUI for the federal government must also comply with NIST 800-171. The DoD, GSA, and NASA have included a clause in their contracts requiring contractors to ensure their subcontractors also comply with the standard. This means contractors must ensure that any third-party service providers who have access to CUI also comply with the requirements.

Federal Agencies: While federal agencies are not required to comply with NIST 800-171, they are responsible for ensuring that their contractors and subcontractors meet the standard's requirements. Federal agencies must implement contract language that requires contractors to comply with the standard and include audit provisions to ensure compliance.

State Agencies: While NIST 800-171 is a federal standard, some state agencies have also implemented the requirements as part of their cybersecurity frameworks. State agencies that handle CUI or contract with federal agencies must also ensure that they and their contractors comply with the standard's requirements.

Suppliers to Government Contractors: Companies that supply products or services to government contractors may also need to comply with NIST 800-171. If a supplier provides a product or service that directly involves CUI, the contractor may require the supplier to comply with the standard's requirements.

NIST 800-171 is a comprehensive set of cybersecurity requirements aimed at safeguarding controlled unclassified information (CUI) in the hands of government contractors and subcontractors. To comply with these requirements, organizations must take a methodical approach that addresses each of the 14 control families.

1. Access Control: Organizations must control access to systems and data, including implementing user identification and authentication, limiting access to authorized users, and monitoring access attempts.
2. Awareness and Training: Employees who handle CUI must receive cybersecurity awareness training to understand the importance of safeguarding sensitive data.
3. Audit and Accountability: Organizations must create, retain, and review system audit records to ensure the security of CUI.
4. Configuration Management: Organizations must establish and maintain an inventory of authorized software and hardware, and ensure that only authorized changes are made to the IT environment.
5. Identification and Authentication: Organizations must implement multifactor authentication for remote access to systems, and prevent unauthorized access to systems.
6. Incident Response: Organizations must have procedures in place for detecting, reporting, and responding to cybersecurity incidents.
7. Maintenance: Organizations must maintain the security of hardware and software, including patching vulnerabilities in a timely manner.
8. Media Protection: Organizations must protect CUI stored on media, such as laptops and USB drives, and securely destroy or dispose of media when no longer needed.
9. Personnel Security: Organizations must screen personnel who will have access to CUI, and have procedures in place for reporting security violations by personnel.
10. Physical Protection: Organizations must limit physical access to CUI, and have procedures in place for responding to physical security incidents.
11. Risk Assessment: Organizations must regularly assess the risk to CUI and implement appropriate security controls.
12. Security Assessment: Organizations must periodically assess the effectiveness of their security controls and address any identified weaknesses.
13. System and Communications Protection: Organizations must protect the confidentiality and integrity of CUI when it is transmitted over networks and stored on systems.
14. System and Information Integrity: Organizations must monitor and maintain the integrity of systems and data, and take steps to prevent unauthorized changes or deletions.

To comply with NIST 800-171, organizations must conduct a thorough assessment of their IT environment to identify areas where they are not meeting the requirements. They should then create a plan to address these gaps and implement the necessary controls. This process may include purchasing new hardware or software, creating new policies and procedures, and training employees.

Once the controls have been implemented, the organization must verify that they are working effectively and document their compliance with each of the 110 requirements. They may also need to provide evidence of compliance to government agencies and submit a security plan outlining how they will protect CUI.

In conclusion, complying with NIST 800-171 may require a significant investment of time and resources, but it is essential for any organization that handles CUI for government agencies. By taking a methodical approach and addressing each of the 14 control families, organizations can ensure that they are meeting the requirements and protecting sensitive information from cyber threats.