Cybersecurity: System Security Plan Template
The Computer Security Resource Center portion of the NIST website has published a Security Safety Plan (SSP) template for controlled unclassified information (CUI). It can be found by clicking “CUI SSP template” on the right hand side under “Documentation” at https://csrc.nist.gov/publications/detail/sp/800-171/rev-1/final#pubs-topics.
This SSP template tracks verbatim the 110 security control requirements of NIST SP 800-171 and, for each one, requires contractors to respond whether the requirement has been “Implemented,” is “Planned to be Implemented,” or “Not Applicable.” If the response is N/A, the organization must provide an explanation for its rationale. The template comes with the following Planning Note: “There is no prescribed format or specified level of detail for SSPs. However, organizations ensure that the required information in [SP 800-171 Requirement] 3.12.4 is conveyed in those plans.” If certain security requirements are being met with an alternative security control measure that is as equally effective, the procedure set forth in DFARS 252.204-7012 explains further about submitting a variance request to your contracting officer.
Registration on DIBNet
PilieroMazza PLLC advises clients in the industry to register on DIBNet now—before you’re in the throes of a cyber security incident. But, please note: the URL for accessing the DIBNet portal has changed. If you use the old link, the following information will pop up: “Thank you for trying to access the Defense Industrial Base Network. Our site has recently undergone changes and has a new URL for enhanced security. Please access DIBNet at the new URL at https://dibnet.dod.mil.” And, just so you’re ready in the unfortunate event that you must “rapidly report” (within 72 hours) a cyber security breach, it is not too late to gather the 20 items of information that you’ll need to furnish to DoD, namely:
- Company name
- Company point of contact information (address, position, telephone, and email)
- Data Universal Numbering System (DUNS) Number
- Contract number(s) or other type of agreement affected or potentially affected
- Contracting Officer or other type of agreement point of contact (address, position, telephone, and email)
- USG Program Manager point of contact (address, position, telephone, and email)
- Contract or other type of agreement clearance level (unclassified, confidential, secret, top secret, or not applicable)
- Facility CAGE code
- Facility Clearance Level (unclassified, confidential, secret, top secret, or not applicable)
- Impact to Covered Defense Information
- Ability to provide operationally critical support
- Date incident discovered