Last Updated on April 23, 2024 by Ossian Muscad
Every organization dealing with the Department of Defense must comply with DFARS cybersecurity regulations. The DFARS compliance checklist is a comprehensive guide to understanding and implementing DFARS requirements. Preserving data integrity is important to protect your company from cyber threats and maintain good standing with the DoD. This article will discuss what DFARS compliance is and how you can create a DFARS compliance checklist for your business.
What is DFARS?
The Department of Defense Federal Acquisition Regulation Supplement (DFARS) is a set of standards that organizations must follow to protect Controlled Unclassified Information (CUI). CUI refers to any information that needs safeguarding or distribution restrictions in accordance with and consistent with applicable laws, regulations, and government-wide standards.
Who Needs DFARS Compliance
DFARS compliance is compulsory for all contractors and subcontractors working directly or indirectly with the Department of Defense (DoD). This broad category includes manufacturers, universities, IT providers, consultants, and any business that is part of the supply chain for a DoD contract. To be considered DFARS compliant, these entities must adhere to the standards set by the National Institute of Standards and Technology (NIST) in Special Publication (SP) 800-171. These standards are designed to provide guidelines for protecting Controlled Unclassified Information (CUI) on non-federal information systems and organizations.
Failure to comply with the cyber DFARS clause 252.204-7012 can lead to serious consequences for a contractor or subcontractor, including suspension, financial penalties, termination of contracts, and even debarment from working with the Department of Defense in the future.
Therefore, maintaining DFARS compliance is not just about safeguarding information; it’s a critical requirement for continuing business relationships with the DoD. Compliance ensures that all members of the defense supply chain are taking the necessary steps to protect sensitive data from cyber threats, thereby preserving national security.
What is a DFARS Compliance Checklist?
A DFARS Compliance Checklist is a structured tool designed to assist companies in conducting self-assessments to determine their compliance with the Department of Defense Federal Acquisition Regulation Supplement (DFARS) requirements, particularly the clause 252.204-7012, “Safeguarding Covered Defense Information and Cyber Incident Reporting.”
The checklist is crucial for organizations with DoD contracts to evaluate whether they are correctly implementing the security standards outlined in the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171. These standards focus on protecting Controlled Unclassified Information (CUI) in non-federal information systems and organizations.
Using a DFARS compliance checklist, a company can methodically assess its cybersecurity policies, controls, and procedures against each requirement in NIST SP 800-171 to ensure it is taking appropriate measures to safeguard sensitive defense information and report cyber incidents accurately and promptly. This self-assessment process is essential for maintaining compliance, preserving data integrity, and continuing a business relationship with the DoD.
What to Include in a DFARS Compliance Checklist?
Creating a DFARS Compliance Checklist is fundamental to a company’s cybersecurity strategy when working with the Department of Defense. It not only aids in safeguarding Controlled Unclassified Information (CUI) but also ensures that the company can meet the stringent requirements set forth by the DoD. Below is an outline of the critical items to include in a DFARS Compliance Checklist, with detailed information for each to guide your compliance efforts.
- Access Control: Incorporate mechanisms to limit access to CUI to authorized users. This includes employing multi-factor authentication, maintaining robust access logs, and ensuring that permissions are granted based on the least privilege principle.
- Awareness and Training: Implement a comprehensive cybersecurity awareness and training program for all employees. This program should cover the importance of protecting CUI, recognizing phishing attempts, and secure handling of information.
- Audit and Accountability: Establish procedures to create, store, and review audit logs of system and network activities. Ensure these logs can track user actions that could affect CUI or the system’s integrity and safeguard the logs against unauthorized access.
- Configuration Management: Develop and maintain baseline configurations and inventory of organizational systems. Ensure that software patches are promptly applied and that unauthorized software is not installed on systems handling CUI.
- Identification and Authentication: Deploy mechanisms to uniquely identify and authenticate users or processes accessing organizational systems. This often includes the use of secure passwords, digital certificates, or biometric verification.
- Incident Response: Create an incident response plan that includes preparation, detection, analysis, containment, recovery, and post-incident procedures. The plan should also specify reporting incidents to relevant authorities, including the DoD.
- Maintenance: Ensure that systems are properly maintained, with regular security inspections, timely vulnerability repair, and secure disposal or sanitization of hardware and software.
- Media Protection: Secure all media containing CUI, both digital and physical. Implement procedures for access, marking, distribution, storage, transport, and destruction of media.
- Physical Protection: Provide physical security measures to protect facilities and resources that house CUI. This includes controlled access to facilities, visitor logs, and protection against environmental hazards.
- Risk Assessment: Conduct regular risk assessments to identify vulnerabilities and threats to organizational systems. These assessments should guide the prioritization of remediation efforts and enhance security measures.
- Security Assessment: Perform continuous security assessments to evaluate the effectiveness of security controls. This involves periodic reviews, testing, and audits to ensure compliance with DFARS requirements.
- System and Communications Protection: Implement network and system protections to defend against unauthorized access and cyber threats. This includes firewalls, intrusion detection systems, and secure communication channels.
- System and Information Integrity: Adopt practices to identify and protect against malicious software, monitor security alerts, and promptly address vulnerabilities. This ensures the integrity and availability of systems processing CUI.
Each of these items is a critical piece of the DFARS Compliance Checklist puzzle, ensuring not only compliance with regulations but also the security and integrity of sensitive information crucial to national defense.
How to Create a DFARS Compliance Checklist
Creating a DFARS Compliance Checklist requires careful consideration and a strategic approach to effectively meet the Department of Defense’s stringent requirements. It serves as a comprehensive guide for organizations to ensure they implement and maintain the necessary cybersecurity measures to protect Controlled Unclassified Information (CUI). To create a DFARS compliance checklist, you will need to:
- Identify the specific systems and data within your organization that fall under the Defense Federal Acquisition Regulation Supplement (DFARS) purview, including any sensitive or controlled unclassified information.
- Thoroughly review the DFARS requirements to understand the necessary cybersecurity controls and protection measures that must be in place. This involves a detailed examination of clauses such as 252.204-7012, which mandates safeguarding of covered defense information and cyber incident reporting.
- Develop a comprehensive plan for testing and verifying each required control for effectiveness. This includes determining the methods and tools you will use to conduct these verifications and establishing a schedule for regular testing.
- Implement the identified controls within your systems and processes. This step may involve configuring software settings, establishing secure data handling procedures, or training employees on cybersecurity best practices. Once controls are in place, conduct thorough testing to ensure they function as intended and effectively mitigate potential risks.
- Review and update the compliance checklist regularly to reflect any changes in DFARS regulations or adjustments in your organization’s systems and processes. This ensures that the checklist remains a current and accurate tool for guiding compliance efforts.
- Utilize the updated checklist as a foundational tool for conducting compliance self-assessments. This should involve a systematic review of your cybersecurity posture against the checklist’s criteria to identify any gaps or areas needing improvement, ensuring ongoing adherence to DFARS mandates.
How to Use DFARS Compliance Checklist
Now that you know how to create a DFARS compliance checklist, the next thing you’ll need to know is how to use it. Since DFARS primarily aims to ensure that DoD contractors and subcontractors comply with their set requirements, it’s important to conduct self-assessments using a digital DFARS self-assessment checklist to gain a deeper understanding of how an organization can maintain compliance.
Digital DFARS compliance checklists can help identify vulnerabilities and risks, as well as how to mitigate them. By conducting regular self-assessments, you can ensure that your organization complies with DFARS and takes the necessary steps to protect CUI. For an efficient and effective DFARS compliance tracking, follow the steps outlined below:
Ask the Right Questions
Review your DFARS compliance checklist to ensure it corresponds to the DFARS compliance requirements. Some of the areas include the following:
- Access control
- Training and Awareness
- Audit and accountability
- Configuration management
- Identification and authentication
Check Each Item in Detail
As you go through each item in the checklist, ask questions that will help you understand what is required for compliance. Doing so will help prevent missing critical items that could negatively impact the organization’s cybersecurity health. That way, you can take the necessary steps to mitigate risks and vulnerabilities.
Assess Compliance Level
Once you have reviewed the checklist, it’s time to assess your organization’s compliance level. To do this, consider how well each control is implemented and whether it meets DFARS compliance requirements. After that, you can create a report that outlines the current state of DFARS compliance within your organization.
Attach Media Files
Sometimes, you may need to attach media files supporting your DFARS compliance checklist. These could be screenshots, diagrams, or other types of documentation. Save these files in a secure location so only authorized personnel can access them.
Complete with Relevant Signatures
Finalize and complete your DFARS compliance checklist by including all relevant signatures. This could be from the organization’s management, DFARS compliance officer, or other authorized personnel. Doing so can ensure that the checklist is accurate and valid.
A Comprehensive Overview of DFARS Compliance Standards
This section will provide example questions for your DFARS compliance self-assessment checklist. These items are based on the “Self-Assessment Handbook NIST– Handbook 162” from the NIST:
Access Control
- Does the company implement any form of authentication mechanism?
- Does the company employ access control lists (ACLs) to restrict access to applications and data according to role and/or identity?
- Are user privileges limited to what is necessary for them to perform their duties?
Training and Awareness
- Are all users, managers, and system administrators provided with initial and annual training that matches their specific roles and responsibilities?
- Is the security training designed to cover the communication of concerns related to potential insider threats by employees and management?
- Does the security awareness training incorporate practical exercises that mimic real cyberattacks?
Audit and Accountability
- Does the company conduct audits and evaluations?
- Is the company capable of uniquely tracing and holding individuals accountable for unauthorized actions?
- Does the company regularly review and update audit logs annually, following significant system changes or as necessary?
Configuration Management
- Are baseline configurations for each type of information system created, documented, and updated regularly?
- Are these baseline configurations established and approved in collaboration with the Chief Information Security Officer (CISO) or their equivalent, along with the owner of the information system?
- Does company management authorize and document any modifications to the system?
Identification and Authentication
- Does the system utilize accounts assigned by the company for individual access?
- Are the initial passwords randomly generated and distributed to employees through a password reset system?
- Is multi-factor authentication implemented to access the network with both privileged and non-privileged accounts?
Incident Response
- Does the company have an incident response policy that clearly defines the procedures for managing incidents involving Controlled Unclassified Information (CUI)?
- Does the company’s incident response policy detail the processes for tracking and reporting CUI-related incidents to the relevant authorities?
- Is the company’s incident response effectiveness regularly evaluated through tests, with subsequent reviews and enhancements?
Maintenance
- Is there a management system for IT maintenance tools, such as diagnostic, scanning, and patching utilities?
- Are there established controls that restrict the tools, methods, mechanisms, and personnel involved in maintaining information systems, devices, and their supporting infrastructure?
- Are the activities of maintenance staff, who typically do not have system access, under supervision?
Media Protection
- Are documented workflows, data access controls, and media policies strictly enforced to guarantee appropriate access management?
- Is access to media containing CUI restricted solely to authorized personnel? Does the firm ensure that only approved individuals have access to media from CUI systems?
- Are both digital and non-digital media from systems thoroughly sanitized before they are disposed of or repurposed?
Personnel Security
- Is there a screening process for individuals before they are granted access?
- Upon an employee’s termination or transfer, does the company promptly (e.g., within 24 hours) revoke their authentication credentials?
- Does the company ensure the retrieval of all company-owned information system-related property from employees who are terminated or transferred within a specified timeframe (e.g., 24 hours)?
Physical Protection
- Has the facility or building manager identified specific areas as “sensitive” and implemented physical security measures such as guards, locks, cameras, and card readers to restrict access solely to authorized personnel?
- Has the facility or building manager assessed the types and locations of physical security measures (including guards, locks, card readers, etc.) in place to ensure they meet the company’s requirements?
- Does an authorized employee consistently accompany visitors to sensitive areas at all times?
Risk Assessment
- Does the company implement a policy for managing risks?
- Are the systems regularly checked for both known and emerging vulnerabilities?
- Upon identifying a vulnerability, do system owners and company executives develop a strategy for remediation, acceptance, avoidance, or risk transference?
Security Assessment
- Is a regular security assessment (for example, annual) conducted to verify the correct implementation of security controls and their alignment with security requirements?
- Are any identified deficiencies and weaknesses from security requirement assessments promptly addressed and incorporated into the action plan within a specific period (e.g., 30 days) after being reported?
- Is there a designated assessor or an assessment team responsible for continuously monitoring the system’s security requirements?
System and Communications Protection
- Does the system oversee and regulate communications at its perimeter and significant internal junctions?
- Are the company’s information security protocols, covering architectural design, software development, and system engineering fundamentals, structured to bolster information security?
- Does the system block remote devices (such as laptops) that have formed connections with it from interacting with resources on uncontrolled or unauthorized networks outside of that established communications pathway?
System and Information Integrity
- Are system vulnerabilities detected, documented, and rectified within the timelines defined by the company?
- Does the system autonomously refresh its malicious code protection features?
- Are security alerts, advisories, and directives issued internally?
Frequently Asked Questions (FAQs)
Q1: What is the primary purpose of the DFARS compliance checklist?
The primary purpose of the DFARS compliance checklist is to ensure that defense contractors and their subcontractors adhere to specific security protocols to protect Controlled Unclassified Information (CUI) within their network and information systems, thereby contributing to national defense security.
Q2: Can a company be considered DFARS compliant without implementing multi-factor authentication for system access?
No, implementing multi-factor authentication is a critical requirement for accessing the network with both privileged and non-privileged accounts. Without it, a company cannot be considered DFARS compliant as it compromises the security of the information system.
Q3: How frequently should security assessments be conducted to remain DFARS compliant?
Security assessments should be conducted at least annually to verify the correct implementation of security controls and ensure alignment with security requirements. Additionally, assessments should be triggered following significant system changes or when new vulnerabilities are identified.
Q4: What steps should be taken if a vulnerability is detected in the system?
Upon detecting a vulnerability, it’s imperative to document it and rectify it within the timelines defined by the company. System owners and company executives must also develop a strategic approach for remediation, acceptance, avoidance, or risk transference.
Q5: Is it necessary for maintenance staff without system access to be supervised?
Yes, it is crucial that the activities of maintenance staff, especially those who typically do not have system access, are monitored under supervision. This ensures that any maintenance work does not inadvertently compromise system security or integrity.
Q6: What is the protocol for dealing with media containing CUI upon disposal?
Media containing CUI must be thoroughly sanitized before they are disposed of or repurposed. This involves using approved procedures to ensure that CUI cannot be recovered or accessed once the media is out of the company’s possession, thereby safeguarding sensitive information.
Streamline DFARS Compliance with DATAMYTE
DATAMYTE is a quality management platform with low-code capabilities. Our Digital Clipboard, in particular, is a low-code workflow automation software that features a workflow, checklist, and smart form builder. This tool lets you automate DFARS compliance with ease by creating tailored workflows that assist in completing and managing mandatory security measures.
DATAMYTE also lets you conduct layered process audits (LPA), a high-frequency evaluation of critical process steps, focusing on areas with the highest failure risk or non-compliance. Conducting LPA with DATAMYTE lets you effectively identify and correct potential defects before they become major quality issues.
With DATAMYTE, you have an all-in-one solution for DFARS compliance and quality management. Book a demo now to learn more about how we can help streamline your compliance processes.
Conclusion
Now that you know how to create and use a DFARS compliance checklist, you can take the necessary steps to ensure compliance within your organization. Following these tips can preserve data integrity and keep your organization’s cybersecurity health in check. Establishing stringent security measures and adhering to the necessary protocols will not only secure the Controlled Unclassified Information (CUI) but also fortify your company’s defenses against potential cyber threats.
Regular assessments and updates to your security systems and protocols are crucial in staying ahead of emerging vulnerabilities. By incorporating these practices, your organization can demonstrate a solid commitment to security standards, potentially leading to stronger business opportunities and partnerships in the defense sector. Remember, DFARS compliance is an ongoing process that requires vigilance and a proactive approach to cybersecurity and information protection.
