In today’s connected world disk encryption may check a security box but it is ineffective at protecting against the most common ways data is stolen by insiders or external bad actors who are using valid credentials. Learn why file-centric security is an essential layer on top of disk encryption and TLS to truly protect sensitive data.

Ask a CISO, CIO, or IT professional if their company files are encrypted and ninety-nine percent will respond yes. Ask this same group if their files are encrypted so they are protected from theft by someone who is inside their network or device, and ninety-nine percent will say no.  

How can there be such a discrepancy even though everyone believes their files are encrypted? 

The ninety-nine percent that say their files are encrypted are referring to disk encryption and not file encryption. Disk encryption is the most rudimentary level of protection that almost one-hundred percent of organizations have. But it protects against the most basic level of intrusion and wasn’t made to combat the most common ways data is stolen, e.g. insider theft, network breach, or network breach of a third party or vendor.  

This article explores key distinctions between disk encryption and file-level encryption, and examines the critical need for file encryption to thwart ransomware attacks and data theft by insiders and external bad actors.

What is Disk Encryption?

Disk encryption is a security method that encodes data stored on a computer's hard drive or storage system, making it unreadable without the user and password (appropriate encryption key). Disk Encryption primarily protects data at rest when the device is shut down, ensuring that unauthorized individuals without the password cannot access the information even if they physically obtain the device or hard drive. When the user credentials are entered, the disk is decrypted and the files can be freely accessed and moved. Disk encryption does not even provide encryption at rest, when a user is logged in. Disk encryption protection is only as strong as the user credentials and vulnerable to weak passwords, phishing exploits, and credential-based attacks that bypass traditional access controls. 

Disk encryption is sufficient for protecting against device theft or loss, but becomes ineffective in situations where bad actors or insiders acting with negligence or bad intentions are already inside the network or device. Disk encryption is not designed to control the flow of information in and out of the organization. 

Marketing in the cloud sharing space can add additional confusion about file safety and encryption through claims of “added” security. For example, cloud service providers, like SharePoint and Dropbox, and document management systems, such as NetDocuments and iManage, often highlight their strong security measures, including claims of "double encryption." At first glance, "double encryption" sounds like robust protection, but in most instances, this just means disk encryption. In other words, the files themselves are not encrypted and still remain subject to theft should someone have valid credentials, which is the most common situation for most data theft.

Marketing in the cloud sharing space can add additional confusion about file safety and encryption through claims of “added” security.

What are the Gaps with Disk Encryption?

While disk encryption offers significant protection for data at rest under limited circumstances, it presents several challenges: 

• Limited Protection Against Active Threats: Once the system is booted and authenticated, data becomes accessible in decrypted form, making it vulnerable to insider threats, credential theft, or malware attacks.

• Single Point of Failure: If the encryption key or password is compromised, the entire disk and all data become accessible.

• Performance Issues: Encrypting and decrypting the entire disk can lead to performance degradation, affecting system responsiveness.

Disk encryption does not stop the most prevalent and damaging thefts of data that arise from insiders and bad actors who are inside your network.  

While disk encryption provides effective protection against device theft or loss, its protections stop when bad actors or insiders acting with bad intentions are able to access the network or the device. File-level encryption picks up where disk encryption leaves off, ensuring that each file remains protected, no matter where it’s stored, shared, or accessed.

What is File-Centric Security or File-Level Encryption?

File-Centric Security applies a specifically strong type of encryption and strong access policies at the individual file level. Unlike disk encryption and TLS encryption, file-centric security protects you from credential-based and man-in-the middle attacks as files stay encrypted no matter where they are moved and accessed.  

Too often people conflate disk encryption with file-level encryption believing that the two terms refer to providing the same level of security. In reality, disk encryption only secures data while it is stored as opposed to file-level encryption, which ensures data stays protected and compliant, no matter where it travels. Here's how it works.

How File-Centric Security Fills the Gaps

File-centric security builds a new level of security layer on top of disk encryption to give organizations power to prevent ransomware, mitigate insider threats, and manage third party risks.

What can you expect when you choose a File-Centric Security Platform?

• Continuous Protection Against Active Threats: Files remain encrypted at all times, even when actively accessed or moved. Any violation of policies or attempts to exfiltrate are prevented by strict encryption that persists irrespective of the data’s location or state. 

• Eliminating Single Point of Failure: Each file has its own encryption key and access policy. If one key is compromised, only the associated file becomes vulnerable, significantly reducing risk. 

• Granular Control: Dynamic, role-based, or location-based access controls and encryption is tailored to individual files, allowing organizations precise control over data usage, visibility, and movement. 

• Mitigating Insider Threats: Unlike disk encryption, file-level encryption maintains protection even when files are accessed internally, restricting unauthorized internal viewing or alterations based on stringent access controls. 

• Preventing Ransomware Attacks: By encrypting individual files, even if attackers gain system-level access or admin credentials, the data remains encrypted and unusable to the attackers. 

• Protection from Credential Theft: File-level encryption safeguards files independently from user credentials. Even if user credentials are stolen, attackers cannot decrypt and misuse sensitive data without appropriate keys and permissions. 

• No Dependency on Data Classification: File-centric security eliminates the dependency on data classification accuracy, as it encrypts all files individually, and protection policies are enforced through strict access controls rather than classification, ensuring consistent security without extensive administrative overhead or user friction. 

By addressing the core vulnerabilities that disk encryption leaves open, file-centric security delivers protection that’s persistent, adaptive, and effective regardless of where your files live or how they move. File-centric security platforms offer a smarter, more resilient way to secure your most valuable data.

FenixPyre’s File-Centric Security Platform

FenixPyre provides a comprehensive file-centric security solution, enhancing data security through advanced file encryption and dynamic access controls: 

• Military-Grade Encryption: Utilizes FIPS 140-2 validated AES-256 encryption, securing any file type, from standard office documents to specialized formats like CAD files. 

• Milliseconds of Latency: Every file is encrypted with a distinct encryption key. Encryption and decryption is optimized at a kernel-level implementation, with no noticeable impact to the client. 

• Strong and Performant Key Management: Every file key is encrypted and stored in a high-performance database. File keys can only be decrypted in a Hardware Security Module, where the master key is hosted. Customers can manage their own HSM. File contents are provably zero-knowledge to anyone outside of the client’s access list, including the possible external data management or cloud hosting solution. 

• Seamless User Experience: Offers frictionless integration into user workflows, ensuring files remain secure without impacting productivity. 

• Patented Dynamic and Context-Aware Access Controls: Implements robust role-based and location-based access restrictions and revocation capability, effectively reducing risk by controlling who can access files and under what conditions. Files remain protected even when stolen. 

• Comprehensive Compatibility: Supports encryption across various environments, including network shares, cloud storage platforms (SharePoint, AWS S3, Azure), and local file systems. 

• Real-Time Monitoring and Analytics: Integrates seamlessly with SIEM tools to provide real-time logs, behavioral analytics, anomaly detection, and proactive threat response capabilities, further enhancing organizational security posture.  

While disk encryption provides foundational security for anyone accessing data on a device, file-centric security solutions, like FenixPyre ,offer superior protection against modern threats, ensuring comprehensive, adaptive, and user-friendly data security. 

File-centric security doesn’t just reduce risk - it redefines control.  

By encrypting sensitive files and enforcing access at the source, FenixPyre ensures your data stays protected no matter where it goes or who tries to access it. Even when someone is inside your network with valid credentials.

Ready to secure what matters most?

View our resources below and see how file-centric security can transform your data protection strategy.  

• Connect with FenixPyre on LinkedIn

• View our industry blog for more strategic insights

• Talk to an expert to see how file-centric security can work for your business

With the advent of file-centric security solutions, the time has come to rethink the way we use traditional or modern Data Loss Prevention (DLP) solutions.

While most organizations have either purchased or are considering a Data Loss Prevention (DLP) solution to enhance the visibility of sensitive information and comply with regulations, the majority of CISOs, IT, and security professionals know that these solutions are not enough to prevent a data breach. In fact, only 10% of those purchasing a DLP solution move beyond using it for just monitoring.  

In this article we examine how file-centric security offers a more secure and frictionless experience over the short-term and long term.

The Challenges of DLP Solutions

The core challenge with traditional DLP solutions is the time, complexity and effort required to accurately classify data and design policies that don’t destroy productivity for both users and IT teams. Without first establishing proper classification, it's difficult to enforce effective security policies, which is one of the key reasons so few buyers of DLP ever get out of monitoring mode. During this arduous process, files remain vulnerable. 

Data Classification and Policy Challenges

• Perfect accuracy is unattainable: A classifier achieving 100% accuracy is practically impossible due to data complexity and variability. 

• Identifying sensitive data with high confidence: Verifying the accuracy of sensitive data detection (e.g., determining if a flagged SSN is genuinely an SSN) is challenging, increasing the risk of false positives. 

• User dependence: Heavy reliance on end-users for manual labeling increases risks - users frequently mislabel files or bypass labeling altogether. Automated labeling systems often fall short, too, leaving user-based labeling as the main alternative.

• Scale and complexity: Data volumes are immense, often dispersed across multiple environments, including, Network shares, Endpoints and Cloud storage (SharePoint, AWS S3, Azure Storage, GCP storage). With such large volumes, implementing effective classification could take months or even years. 

• Maintenance and continuous adjustments: Constant updates and maintenance are often required due to evolving file formats. This demands a dedicated team to monitor and fine-tune classification logic, creating ongoing administrative overhead. 

• File type limitations: DLP and classification tools typically struggle with specialized files, such as CAD files, where sensitive information may be stored but is hard to identify reliably.

• Risk of misconfiguration: Misconfigured classifiers can lead to incorrect alerts, false labeling and reduced trust in the classification system.

• Policy Complexity: Protection policies are built directly on classification results that are imperfect. Errors in classification propagate directly into policy enforcement, which results in high friction with users. This can create policy exceptions that dilute security protections.

  • Impossible coverage of all workflows: It is practically impossible to create policies that comprehensively address all user workflows, file types and storage solutions. As a result, users often encounter legitimate workflow situations that policies do not anticipate.

  • Overly restrictive policies cause disruption: Stringent policies designed to maximize security can inadvertently disrupt legitimate business workflows, causing frustration and productivity loss. Friction results in users demanding exceptions, forcing IT departments to manage complex exemption requests (e.g., a CEO needing urgent file-sharing privileges despite classification restrictions).

  • Properly Configured or Misconfigured policies cause administrative overhead: Poorly configured policies result in false alerts and user-generated tickets. This creates unnecessary administrative burden, reduces operational efficiency and hinders productivity.

For all the reasons stated above, using typical or even “modern” DLP solutions to tackle protecting your sensitive files is highly complex, costly and drains limited IT resources. Moreover, DLP solutions take a long time to implement, leaving your files unprotected. The alternative is to use a file-centric solution that puts security at the file level in place immediately while, if you choose, you can continue to identify and classify data.  

The Benefits of File-Centric Security 

File-Centric Security applies a specifically strong type of encryption and strong access policies at the individual file level. Unlike disk encryption and TLS encryption, file-centric security protects you from credential-based and man-in-the-middle attacks as files stay encrypted no matter where they are moved and accessed. 

Too often when people think about file encryption, they refer to disk encryption, but disk encryption is not the solution to stop the type of threats that arise from insiders and bad actors who are inside your network. 

• Classification Does Not Have to Be Perfect

  With File-Centric security you do not need classification of files because any file can easily be secured and engaged with.  

  • By securing the individual file, it remains protected and allows compliance and security controls to travel with the file at all times. 

  • Deciding what data to protect is based on devices, users, folders and departments. 

  • File-centric security can be set up so whether people are downloading files or working with certain applications – the files are automatically encrypted.  
    
    

• Policies are Not Reliant on Accurate Classification 

  File-Centric security policies are dependent on access controls, rather than classification. Since the files are encrypted at all times (even when shared externally), you can start off with the most permissive access controls, and slowly make it least permissive while still maintaining tight security. 
  
  

• Enhanced Security

  File-Centric security has multiple uses for mitigating multiple types of risks and threat vectors. This includes:

  • Insider Threat 

  • Ransomware 

  • Third-Party Risk Management 

  • Secure Sharing 

  
  

• Easier to Set up and Manage 

  Since File-Centric security does not depend on content inspection and classification, it is easier to setup and manage. 

  Most File-Centric security solutions require minimal change in user workflows so users can work with files without any friction. As soon as a user breaks the policies, they lose access in real time. 

  
  

• No User Dependency and Seamless User Experience

  With File-Centric security, you do not need to depend on your end-users to perform any special actions to protect the files. Protection is automatically enforced at the file level at all times. 

  
  

• File-Centric Security Supports any File Type

  Many File-Centric security solutions are able to encrypt typical office documents. Others are able to be agnostic to a wide range of file types.  

  Learn more about file-centric security and how it can protect your data.and how it can protect your data.

FenixPyre’s File-Centric Security Platform (FCS) 

FenixPyre’s FCS offers customers the most comprehensive and easy to deploy solution:

• Military-grade FIPS 140-2 validated AES-256 encryption modules - the best available. 

• Encrypts any file type and secures any application, from Microsoft Office to advanced CAD tools like Revit and SolidWorks. 

• Works seamlessly in all environments and storages, network shares, SharePoint, local files, etc. Users experience a seamless interaction with encrypted files with their native and cloud applications. 

• Applies dynamic, role-based or location-based access controls, restricting user’s access to sensitive files. Organizations can define precisely who accesses files, when and from where, significantly reducing exposure. 

• Securely share sensitive files for collaboration and compliance. Make uncontrolled data flow across diverse locations, including cloud sharing, a non-issue. FenixPyre ensures sensitive information remains protected based on factors such as user identity, location and device, and is tracked for every file with patented, context-aware encryption.

• Can be implemented on top of your existing permissions layer (NTFS or cloud) so that you don’t need to manage multiple permission systems. 

• Stream real-time audit logs into security information and event management (SIEM) tools, enabling behavioral analytics, anomaly detection and automated threat response to insider risks. 

  
  

File-centric security doesn’t just reduce risk—it redefines control. By encrypting sensitive files and enforcing access at the source, FenixPyre ensures your data stays protected no matter where it goes or who tries to access it. 

Ready to secure what matters most? 

View our resources below and see how file-centric security can transform your data protection strategy. 

• Connect with FenixPyre on LinkedIn

• View our industry blog for more strategic insights 

• Talk to an expert to see how file-centric security can work for your business 

The CMMC Compliance Certification is the Department of Defense’s way of ensuring that organizations are capable and adequately equipped to protect the kind of Controlled Unclassified Information (CUI) they collect and store. The solution for compliance with CMMC may be easier than you think.

As technology continues to improve and AI-assisted attacks proliferate, data security comes to the forefront. In response, companies are seeking to improve their data protection strategies beyond what has been available. This is especially true as it relates to CMMC requirements. As we’ve seen through recent attacks on secure information, these improvements are necessary for companies looking to stay one step ahead of security attacks.

In July 2024, AT&T suffered a massive data breach affecting 73 million customers. This incident highlights the ongoing vulnerability of large telecommunications companies to cyber attacks and the need for stronger data protection measures.

In May 2024, Dell experienced a significant cyberattack that potentially affected 49 million customers. The attack went undetected for nearly three weeks, raising concerns about Dell's cybersecurity practices.

Data breaches are not limited to large companies; in fact, 46% of all cyber breaches impact businesses with fewer than 1,000 employees (StrongDM). These data breaches show us that most sensitive data is at risk of being accessed and leaked. So how do you prevent these data leaks and help to protect CUI as mandated by CMMC?

CMMC Compliance can help with that – and FenixPyre helps companies get there faster and more affordably.

Table of Contents

• What is CMMC or the Cybersecurity Maturity Model Certification?

• Why is CMMC important?

• Who needs CMMC Certification?

• Understanding CMMC Certification Levels

• More About CUI

• CMMC Compliance FAQs

What is CMMC or the Cybersecurity Maturity Model Certification?

The CMMC Compliance Certification is the Department of Defense’s way of ensuring that organizations are capable and adequately equipped to protect the kind of Controlled Unclassified Information (CUI) they collect and store.

CMMC is a structure of compliance levels that helps the government determine how capable an organization is to secure vulnerable or controlled unclassified information based on the CMMC certification requirements.

The CMMC compliance certification was announced by the Department of Defense in 2019 and applies to all companies in the defense industrial base (DIB). However, CMMC 2.0, a newer version, was released in November 2021. The CMMC 2.0 compliance levels are precise, therefore organizations can determine where they best fit within the levels to maintain national security protocols.

Check out this useful CMMC guide to help with CMMC compliance.

Why is CMMC important?

As hackers become more sophisticated in their pursuit of secure information, organizations must be knowledgeable about how to protect and secure the CUI they possess.

The CMMC compliance requirements check how capable an organization’s cybersecurity standards are in protecting the sensitive government information they hold. CMMC certification requirements look beyond firewalls and access systems that are necessary but do not encompass enough protection to satisfy the requirements.

The CMMC guidelines ask critical questions:

• How credible is the staff regarding espionage or sabotage?

• What about the work culture and ethics of the organization?

• Beyond having comprehensive knowledge of their data protection, are they actively optimizing and improving their data protection strategies to combat the cyber threat?

Performing a CMMC compliance self-assessment can help you understand where your business currently falls in the process. The checklist gives a clear direction in what organizations should be doing to protect CUI within their level of vulnerability. As an organization that holds access to CUI and values your business with the DoD, you should seek a CMMC compliance certification and continue to increase your level of data security.

Who needs CMMC Certification?

The DoD requires all organizations that work as prime contractors or subcontractors to have a CMMC certification. These cybersecurity standards ensure a more collaborative relationship and minimize any barriers to complying with DoD requirements. If you are working with an MSP or other outsourced IT services, they too will have to demonstrate compliance and can be a key partner as you work toward certification.

The DoD is the largest employer in the world, with a total of over 2.87 million employees. This figure is even larger when considering the DoD’s partnership with defense organizations.

Since the Department of Defense works with a variety of prime contractors, CMMC certifications come in multiple levels, depending on how vulnerable each organization’s data is. The more vulnerable the secured information is, the higher the requisite CMMC compliance certificate and mandatory practices that must be put in place.

A CMMC Certification is a great way to show that your organization is serious about cybersecurity and data protection. With this advanced level of compliance, your clients, partners, and vendors will know that you have the resources to offer data protection measures that follow a strict protocol of security.

Understanding CMMC 2.0 Certification Levels

CMMC 2.0 is the second revision of the CMMC initiative and the one you should pay attention to. Released in November 2021, the new program focuses on cutting costs for SMBs and keeping cybersecurity requirements in tandem with federal requirements and back to pure NIST SP 800-171 controls. The DoD reshaped CMMC to prioritize security throughout the DoD supply chain. This new approach remains accessible to smaller companies and is made up of maturity processes as well as cybersecurity best practices.

Most significantly, CMMC 2.0 reduced the levels of compliance to three.

• Level 1 (Foundational): This level is for FCI-focused (information not intended for public release) companies and represents basic cyber hygiene. The criteria for getting certification at this level are the 15 controls in FAR 52.204-21, focus on the protection of FCI, and Basic Safeguarding of Covered Contractor Information. Annual self-assessments will also be required. Data protection is an important component at Level 1.

• Level 2 (Advanced): This level applies to CUI-focused companies. Level 2 reflects the 110 security controls and 14 levels established by the National Institute of Technology and Standards (NIST) for CUI protection and the implementation of safe practices, this aligns with NIST SP 800-171. Data security is critical for Level 2.

• Level 3 (Expert): This level will incorporate all 110 controls from NIST SP 800-171 (which are also required for Level 2) plus a subset of controls from NIST SP 800-172, however, the specific subset of NIST SP 800-172 controls to be included is still under development by the DoD. One main difference for Level 3 certification – it will require a government-led assessment conducted by the Defense Contract Management Agency (DCMA) Defense Industrial Base Cybersecurity Assessment Center (DIBCAC), rather than a third-party assessment. The DoD estimates that less than 1% of defense contractors will require CMMC Level 3 certification. Data security is imperative at Level 3.

The Department of Defense (DoD) anticipates that CMMC requirements will begin appearing in contracts in Q1 2025 and will be a phased approach. CMMC 2.0 compliance takes time, but key new technology for data security, like FenixPyre, gives you a significant jumpstart on compliance for every level.

More About CUI

To understand the certification levels and where your organization falls, you must be able to determine whether your organization deals with CUI. Controlled Unclassified Information (CUI) refers to any information that needs to be safeguarded or controlled according to relevant laws, Executive Order 13526, or the Atomic Energy Act.

Former President Barack Obama created the CUI program by Executive Order 13556. The goal was to create a streamlined method for safeguarding and sharing information through strict security controls. The Information Security Oversight Office (ISOO) serves as the Executive Agent (EA) of the National Archives and Records Administration (NARA). This makes the EA responsible for overseeing the CUI program.

Information classified under CUI includes health-related information, patents, and budgetary and technical data. At all stages of information security, the CMMC’s cybersecurity requirement remains essential to any organization.

In addition, file encryption is essential for safeguarding CUI in regard to CMMC compliance. It encodes data into an unreadable format only accessible with a decryption key. The protection of CUI is mandated by government regulations, making file encryption important for organizations managing this type of data. Incorporating file encryption into their security strategy shows commitment to putting CUI protection first and achieving CMMC compliance.

How to do a CMMC Assessment

The CMMC 2.0 assessment is completed with the assistance of a certified third party. If the assessor determines that you meet all the requirements for that level of certification, then you will be certified.

Measuring yourself against the CMMC certification requirements is no easy task. In February 2022, the Deputy DoD CIO David McKeown said that based on the Department’s analysis of DoD contractors, “the CMMC 2.0 changes mean about 140,000 defense contractors that handle less sensitive “federal contract information” will only need to submit a self-assessment of their cybersecurity policies to comply with CMMC Level One requirement. However, all 80,000 contractors handling CUI will require third-party assessments.” This is why CMMC support is crucial. CMMC compliance support helps you understand the weaknesses in your system and how best to improve them to meet contract requirements.

They also help you understand the breakdown of CMMC compliance costs in time. You may also engage CMMC compliance software to provide training on any of the requirements that you fall short of.

The CMMC compliance certification is a welcome development for helping organizations plan to secure data safely. This certification has also become the ticket to DoD contract awards. Though the new NIST CMMC compliance has yet to be fully implemented, companies can begin to work with FenixPyre as a guide.

FenixPyre can help you satisfy many components of CMMC compliance using simple and cost-effective technology that addresses access control, data protection at rest, in transit, and during sharing and collaboration, and forensic logging for reporting. It does not affect your workflows and is invisible to end users.

CMMC Compliance FAQs

What is CMMC Compliance?
CMMC Compliance stands for Cybersecurity Maturity Model Certification and is a framework designed by the Department of Defense (DoD) to ensure that organizations taking on federal contracts protect sensitive information from malicious cyber threats.

How does CMMC Compliance work?
The CMMC model consists of three distinct maturity levels with corresponding control requirements, ranging from basic preventive measures aimed at safeguarding data to more advanced cybersecurity practices such as continuous monitoring and auditing. Organizations intending to take on DoD contracts must be certified according to the appropriate level depending on the nature of the contract they are pursuing.

Who needs to meet CMMC Compliance standards?
Any organization applying for a contract with the Department of Defense must demonstrate compliance with the relevant level of CMMC Certification before being considered for the project. Keep in mind this also applies to subcontractors as well.

How do I obtain CMMC Certification?
Obtaining certification under this framework requires organizations to assess their cybersecurity posture against the applicable maturity level’s controls and provide evidence that proves their compliance with all required measures and best practices recommended within each standard’s domain areas (e.g., access control, media protection). Organizations that need higher than Level 2 must engage a third-party auditor certified by DoD to obtain independent assessment and verification of their security posture against specific maturity level criteria set out in the framework.

What risks are associated with not meeting CMMC Compliance standards?
Beyond the loss of ability to gain government contracts, companies may face cybersecurity gaps, which can lead to threats or risk organizational reputation damage, financial losses due to decreased sales, or potential civil litigation resulting from data breaches or other cyber incidents caused by insufficient security safeguard measures in place at your organization/clients’.

Are there any tools available that can help me achieve CMMC Compliance?
Yes – several commercial tools have been developed specifically for helping companies audit, assess, and manage their security posture against any given level within this maturity model (CMMC Level 1 through 3). Additionally, many traditional IT management tools, such as log analytics solutions or vulnerability scanners, have been adapted to assess risk across multiple domains as required by this regulatory compliance scheme. These tools and platforms will help illustrate gaps. Since data security is such a critical area for CMMC, seek out solutions that will help protect your data no matter where it ‘lives’ or how it is used or stored, has the ability to encrypt data without being a burden to your users, and allows you to operate ‘business as usual’ without modifying your workflow or operational processes.

Are there any resources available that explain how to implement these controls?
Yes – There are multiple sources available online that provide guidance on how to implement different control measures as per each specific level’s criteria within this framework; such documents typically include detailed recommendations regarding technical implementation steps needed in order to achieve full compliance status according to the criteria established by DoD’s Cybersecurity Maturity Model Certification (CMMC) program stated objectives/purposes.

Learn how FenixPyre can quickly and cost-effectively accelerate your journey to CMMC 2.0 compliance.

Working as a contractor for the Department of Defense (DoD) can be a rewarding and lucrative path. However, in order to reap these rewards, you will have to first comply with the Cybersecurity Model Maturity Certification (CMMC) framework, which is overseen by the Office of the Under Secretary of Defense for Acquisition and Sustainment (OUSD-A&S). Achieving CMMC 2.0 compliance is no easy feat. It requires strict adherence to several layers of requirements, all of which are analyzed by an official CMMC assessment performed by an accredited CMMC Third Party Assessment Organization (C3PAO).

In this guide to CMMC compliance, we’ll walk you through the highlights of CMMC and the many traps contractors can fall into during the assessment process.

What Does It Mean to Be CMMC 2.0 Compliant?

Intellectual property and sensitive data theft are national security issues that cost the U.S. economy billions of dollars every year. Many of these attacks happen throughout the Defense Industrial Base (DIB) supplier base. In response, the DoD has established numerous security measures and frameworks over the years. The Cybersecurity Maturity Model Certification (CMMC) is a key framework designed to enhance the protection of Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) within the DIB.

Key Data Types Protected under CMMC 2.0

• Federal Contract Information (FCI): Information not intended for public release, generated by or for the government under contract.

• Controlled Unclassified Information (CUI): Information that must be protected from unauthorized disclosure according to laws and regulations, such as International Traffic in Arms Regulations (ITAR) data.

Benefits of CMMC 2.0 Compliance

CMMC compliance helps ensure the robust protection of CUI through compliance requirements across various domains. Being CMMC compliant makes an organization a preferred contractor for the DoD and other government branches. Additional benefits include eligibility for Safe Harbor provisions, which protect certified entities from certain penalties and audits. Companies are encouraged to conduct a self-assessment to understand their readiness for certification, evaluating policies and practices against the framework's levels and domains.

Understanding the CMMC 2.0 Framework

CMMC 2.0 simplifies the original CMMC structure, focusing on streamlining the certification process and reducing the burden on DIB companies. The updated model categorizes requirements into fewer levels:

• Level 1: Basic safeguarding of FCI.

• Level 2: Aligns with NIST SP 800-171 to protect CUI, serving as the necessary certification level for most contractors.

• Level 3: Designed for companies handling highly sensitive defense projects, requiring advanced cybersecurity measures.

Each level provides a scalable approach to cybersecurity, ensuring contractors meet specific security requirements based on the sensitivity of the information they handle. Data security related to CUI is critical to address at all levels.

Next Steps in Achieving CMMC 2.0 Compliance

While self-assessment is a valuable starting point, it does not guarantee compliance. A deeper understanding of the CMMC 2.0 framework, its requirements, and the certification process is crucial. Contractors should aim to integrate cybersecurity practices as specified for their required CMMC level, preparing for assessments and potential audits to maintain compliance. CMMC 2.0 represents a critical step towards securing the DIB against evolving threats and ensuring the integrity and security of defense information.

Domains of CMMC 2.0

CMMC 2.0 consists of 17 domains, each representing a distinct set of security practices to safeguard FCI and CUI. These domains are derived from Federal Information Processing Standards (FIPS) 200 and NIST SP 800-171, with three additional domains: Asset Management, Recovery, and Situational Awareness. The domains include:

• Access Control (AC): Restrictions on data access.

• Asset Management (AM): Identification and management of assets.

• Audit and Accountability (AU): Ensuring traceability of activities.

• Awareness and Training (AT): Providing cybersecurity awareness.

• Configuration Management (CM): Maintaining system standards.

• Identification and Authentication (IA): Managing roles and access rights.

• Incident Response (IR): Reporting and managing incidents.

• Maintenance (MA): Regular system maintenance.

• Media Protection (MP): Safeguarding digital and print media.

• Personnel Security (PS): Security protocols for personnel changes.

• Physical Protection (PE): Restricting physical access.

• Recovery (RE): Systematic data backups.

• Risk Management (RM): Assessing potential risks.

• Security Assessment (CA): Evaluating security measures.

• Situational Awareness (SA): Threat monitoring.

• System and Communications Protection (SC): Communication security.

• System and Information Integrity (SI): Identifying and rectifying weaknesses.

Processes and Practices in CMMC 2.0

Achieving compliance with CMMC 2.0 involves integrating processes and practices for building resilient cybersecurity infrastructure:

• Level 1: Basic Cyber Hygiene.

• Level 2: Intermediate Cyber Hygiene.

• Level 3: Good Cyber Hygiene.

This streamlined structure focuses on essential practices for defense contractors to meet cybersecurity requirements.

Potential Pitfalls of CMMC 2.0 Compliance Assessment for Contractors

Passing the CMMC 2.0 audit is challenging. Here are common issues:

1. Open items on a Plan of Action and Milestones (PoAM): Unlike NIST 800-171, CMMC does not accept open PoAM items. Close all items before assessment.

2. Overshooting Your Target Level: Only pursue the certification level needed. Most contractors require Level 2 certification.

3. Cloud Confusion: Ensure everyone understands cloud security, especially given the remote work environment. Levels 2 and 3 require stringent cloud security measures.

4. Incomplete Policies and Procedures: Make sure all policies are complete, consistent, and fully implemented to avoid red flags.

Self-assessment is invaluable, but achieving CMMC compliance can be complex. FenixPyre is a CMMC and NIST SP 800-171 compliance solution that can ease the process, satisfying critical requirements.