The Ultimate Manual to NIST Compliance

Cybersecurity threats persist despite the advanced countermeasures and network security tools available today. Furthermore, organizations of all sizes struggle with creating a clear and comprehensive security framework to protect mission-critical assets. The National Institute of Standards and Technology (NIST) attempts to solve this challenge with publicly available frameworks and standards for improving your organization’s security posture.

What is NIST Compliance Anyway?

The National Institute of Standards and Technology (NIST) is a non-regulatory government agency operating under the US Department of Commerce. The agency’s primary goal is to develop standards businesses can apply across the board in the government and private sector. Most of these standards are concerned with cybersecurity controls.

National Institute of Standards and Technology (NIST) home page

First, it’s essential to understand the Federal Information Security Management Act (FISMA) and how it relates to NIST standards and compliance.

The United States government needed a way to protect government information and data while reducing federal spending on information security. This endeavor resulted in a federal law passed in 2002 known as the Federal Information Security Management Act. The law mandates all government agencies to adhere to the FISMA guidelines.

For their part, the FISMA guidelines offer a comprehensive framework for agencies to protect government assets, information, and operations against cyber threats. NIST has consequently developed numerous standards to help government agencies comply with FISMA.

The most commonly used standards include:

Federal Information Processing Standards (FIPS) – FIPS is a series of standards developed by NIST for sensitive but unclassified data and information. The standards primarily cover encryption algorithms and data. Compliance is voluntary for private-sector businesses but mandatory for government agencies, contractors, and vendors.

NIST Cybersecurity Framework (CSF) –  Is perhaps the best-known NIST standard. It is an entry-level framework for organizations that want to protect systems, data, and networks from cyberattacks. It is similar to other regulations, such as the PCI DSS. As a result, many private sector businesses elect to comply with the CSF despite it not being mandatory. 

NIST SP 800-53 – This standard covers 18 areas, including access control, data recovery, incident response, and business continuity. It is intentionally designed to exclude specific vendors, tools, and companies. This omission builds flexibility into the framework. As a result, businesses can choose the best environment, systems, and technologies for their specific cybersecurity needs.

The NIST 800-53 is an exceptional framework for small businesses that want to build a strong foundation for a comprehensive cybersecurity policy. Its guidelines are also affordable and relatively straightforward to implement. 

NIST SP 800-37 – This standard mainly concerns prompt risk management. The standard provides a comprehensive Risk Management Framework (RFM) to help organizations define the risk management lifecycle process, roles, and responsibilities. It also covers critical security and risk privacy management processes such as control selection, information system categorization, and continuous monitoring.

It is a foundational document for organizations that prioritize risk management. The framework aims at near real-time risk management with the help of continuous monitoring processes. 

NIST SP 800-171 – This standard covers businesses within the federal supply chain. It is mainly concerned with safely handling sensitive, controlled, unclassified information (CUI). Controlled Unclassified Information refers to government-owned or government-created information that must be protected. Many government contractors work with CUI and are legally required to abide by the SP 800-171 Standards. Therefore, this case is especially true for government contractors.

Private companies that wish to procure defense contracts must abide by these standards. Similarly, subcontractors working under prime government contractors may also need to adhere to the standards. 

How NIST Compliance Works

NIST compliance simply means meeting the requirements for one or more NIST standards. These standards often overlap, so meeting the requirements for one standard usually implies compliance with other measures. For instance, meeting all the Federal Information Processing Standards (FIPS) requirements means adherence to the Federal Information Security Management Act (FISMA).

NIST compliance is mandatory for government agencies but voluntary for private-sector agencies. However, the latter part isn’t always true. There are situations where a private-sector business may be required to comply with one or more NIST standards.

For instance, private sector agents responsible for federally rolled out programs such as student loans, unemployment insurance, and Medicaid are required to comply with FISMA, among other standards. Similarly, vendors and contractors with access to US government systems must comply with one or more NIST standards.

Other government partners required to comply with NIST standards include:

  • Service providers
  • Consulting companies
  • Manufacturers in business with government suppliers or institutions
  • Academic institutions such as universities and colleges
  • Research institutions
  • Government staffing firms

Additionally, NIST compliance is a good idea for private-sector businesses hoping to procure government contracts. Non-compliance may automatically disqualify your business for a government contract.

Still, NIST compliance offers numerous benefits even for businesses that aren’t contractually obligated to adhere to the standards. Some of these benefits include:

  • Improved data handling
  • A competitive advantage when bidding for government contracts
  • Protection from cyber attacks
  • Mitigating damage caused by cyber attacks
  • Avoiding reputation damage resulting from a cyber attack
  • Qualifying for federal funding

Moreover, NIST doesn’t offer certification. Instead, the agency relies on self-certification. Businesses test and record compliance with NIST standards and document the evidence in a central document. NIST then uses these documents as evidence for self-assessment. 

These compliance documents include:

  • The Plan of Action with Milestones (POAM)
  • System Security Plan (SSP).

Private-sector businesses wishing to do business with the government may be required to provide compliance documentation. However, a business can earn NIST certification through independent third-party cybersecurity compliance companies.

Below are two practical examples of the benefits of NIST compliance.

Example 1: Achieving Executive Buy-In With NIST Recommendations

The IT department certainly understands the importance of a mature cybersecurity program. Such a program goes beyond mere compliance and is as proactive in stopping threats as responding to and recovering from attacks. Unfortunately, such a program doesn’t come cheap, and obtaining executive buy-in can be a tough sell for those tasked with the organization’s data security.

Things are more complicated if the industry isn’t covered by regulations such as the ISO 22301, CCPA, or HIPPA. Additionally, complex cybersecurity jargon makes discussing crucial security measures with non-technical stakeholders and decision-makers even more challenging.

With its various standards, regulations, and recommendations, NIST makes it easy for anyone to understand cybersecurity risk management. Specifically, the NIST Cybersecurity Framework takes a risk-based approach that executives understand and appreciate. NIST compliance also provides a common language that technical and non-technical stakeholders can use to discuss important cybersecurity concepts and action steps.

Example 2: NIST Compliance for Long-Term Cybersecurity Risk Management

All NIST standards take a long-term view of cybersecurity risk management. The cyber threat landscape constantly evolves and requires businesses to implement a continuous compliance approach. As a result, NIST standards offer a strong foundation for businesses that need guidance in every step of their risk management journey.

These standards offer recommendations for all key decision points. Furthermore, they cover all stages of cybersecurity maturity from small businesses yet to create an action plan to large enterprises focusing on preventive cybersecurity measures.

NIST standards also bring together the best minds in cybersecurity. NIST documentation is reliable, and most clients, vendors, and partners understand what it means to be NIST compliant. Adhering to known third-party standards is also a great way to build confidence with clients and partners, even when not mandated.

Additionally, these standards help organizations remain compliant despite the ever-changing regulations. NIST has a physical laboratory where it is continuously developing and refining regulations and standards for government agencies and private businesses alike. Finally, NIST compliance often means you also comply with other vital regulations by default.

How to Get Started With NIST Compliance

NIST compliance varies depending on the standards you want to implement and your specific business environment. However, a few steps cut across all scenarios and can help you successfully comply with NIST requirements.

Choose Your Compliance Program

This step is simple for government agencies and businesses working with the federal supply chain. These entities are mandated to comply with specific NIST programs. It’s as simple as finding out which program applies to your business. For example, businesses bidding for Department of Defense (DoD) contracts must comply with the NIST 800-171 and 800-53.

However, private businesses generally have the most to gain from the NIST Cybersecurity Framework (CSF). The CSF cuts across all major industries and addresses varying security requirements. It’s a flexible framework that easily adapts to your organization’s current cybersecurity posture, resources, and risk appetite.

It’s worth noting that the CSF doesn’t replace the NIST 800-53 and 800-171 standards. As a result, private businesses working with the federal supply chain are still liable for complying with the relevant NIST standards. However, the NIST CSF goes a long way in creating a foundation for implementing other NIST standards.

Finally, the NIST CSF is a great first choice for small businesses not mandated to adhere to any NIST standards. The CSF outlines clear steps for risk analysis and risk management. It’s also a comprehensive framework for preventing cyberattacks without an existing cybersecurity program.

Conduct A NIST Risk Assessment

Government agencies and contractors must perform a risk assessment under the Federal Information Security Modernization Act (FISMA). However, it’s still an essential step for businesses that don’t need to comply with NIST standards. The assessment provides a deep understanding of the specific risk your organization faces. It’s a great starting point for developing a roadmap to mitigate the identified risks.

Fortunately, NIST provides a comprehensive Risk Management Framework (RMF). The framework is detailed in Special Publication 800-30. It outlines four main steps, including:

  • Preparing for assessment
  • Conducting the assessment
  • Sharing the discovered findings
  • Maintaining continuous assessment

The actual assessment may look different depending on your business environment. For instance, the assessment goals, scope, information source, analytic approach, and risk model determine the practical aspects of the assessment. However, the purpose of the risk assessment is always the same.

This assessment should highlight potential sources of threats, including possible events leading up to the threat. Furthermore, the review should clearly identify and categorize all potential vulnerabilities. Finally, the report should contain an analysis of the possible impact of all potential threats and the likelihood of each threat.

This information should also be shared with all stakeholders. This includes individuals that might be affected by the identified risks, whether directly or indirectly. The RMF also requires organizations to monitor existing and new risk factors continually and regularly update their risk management procedure accordingly.

Conduct a NIST Gap Analysis 

A NIST gap analysis is like a regular IT security gap analysis. This step is essential for determining your current cybersecurity posture in relation to established NIST standards. For example, you can conduct the analysis based on the framework you choose, such as the NIST CSF or NIST Special Publication 800-171.

The gap analysis is especially useful for developing your compliance program. For instance, the analysis results can help determine which actions to prioritize and where to allocate your budget. You may conduct the analysis in-house or through third-party auditors.

NIST Gap Assessment Tool

Either way, it’s essential to score the assessment. The score provides a quantitative figure to determine how far you are from the desired state. You can also compare the current figures with the desired score to determine the work required to improve your security posture to a satisfactory level.

Develop a Plan of Action with Milestones (POAM)

Remember that you may be required to submit a Plan of Action with Milestones (POAM) to qualify for specific government contracts. Regardless, it’s a valuable document for providing general guidance toward your cybersecurity goals.

NIST provides several documentation and resources to help you create a POAM. In summary, your POAM document should include specific details about:

  • The particular tasks that need to be accomplished
  • Resources required to achieve the plan
  • Target milestones with scheduled completion dates

You can now create a roadmap for how to become NIST compliant. Fortunately, the agency provides detailed documentation every step of the way. You can also partner with a third-party technology company with experience helping businesses become NIST compliant.

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Bryan Wise
Bryan Wise,
CIO of GitLab

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