I’ve come across many terms and acronyms that can make even the most seasoned professional scratch their head. One such term is SSP or System Security Plan. What is it, who is responsible for its completion, and why should you care? In this article, I’ll demystify SSPs and provide you with much-needed clarity on this crucial component in cyber security. So, without further ado, let’s dive into the perplexing world of SSPs.
Who completes an SSP?
By completing an SSP and conforming to the DoD security requirements, contractors can demonstrate that they understand the importance of cybersecurity and are taking proactive steps to safeguard their systems and networks from potential threats. This can also serve as a competitive advantage when bidding for contracts and winning business with the DoD.
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1. Identify Roles: Determine the roles of key stakeholders in your organization who will be responsible for completing an SSP. These roles may include the information security officer, compliance officer, and IT personnel.
2. Review Policies: Ensure that your organization’s policies and procedures relating to information security are up-to-date and compliant with applicable regulations before completing an SSP.
3. Conduct a Risk Assessment: Conduct a comprehensive risk assessment that identifies potential threats and vulnerabilities to the confidentiality, integrity, and availability of information in your organization.
4. Define System Boundaries: Clearly define the scope of your organization’s SSP by identifying system boundaries, system components, and interfaces with external systems.
5. Evaluate Security Controls: Evaluate the effectiveness of your organization’s security controls by reviewing and documenting your current security posture and identifying areas for improvement.
SSP Overview: What is it and Why is it Necessary?
An SSP, or System Security Plan, is a document that outlines the security measures a contractor has implemented to protect their system in accordance with DoD security requirements. The SSP is an essential document for DoD contractors as it not only provides an overview of the system but also the security procedures in place.
An effective SSP is necessary because it demonstrates a contractor’s commitment to security and highlights the measures they have taken to protect the DoD’s data and information systems. Moreover, the SSP provides the DoD with an insight into the contractor’s security posture, which helps the agency understand the risks to its information systems and what steps the contractor has taken to mitigate those risks. A well-written SSP saves the DoD time and money by avoiding security issues and breaches that may arise.
Contractors and SSP: Who Needs to Submit One?
Any DoD contractor who hopes to secure a contract with the agency must submit an SSP. The DoD requires contractors to submit their SSP for review and approval before they can access any of the agency’s information systems. The DoD considers the system a critical part of the agency’s infrastructure and requires strict security controls to protect it.
Therefore, any contractor who handles sensitive DoD information or operates a system that processes or stores sensitive data must submit an SSP. This includes prime contractors, subcontractors, vendors, and anyone who handles DoD information.
Understanding DoD Cybersecurity Requirements for Contractors
DoD contractors must comply with all cybersecurity regulations outlined in the agency’s latest cybersecurity guidelines, including the NIST Special Publication 800-171, DFARS, and CMMC. Failure to comply with these guidelines can result in loss of contracts, fines, and reputational damage.
The NIST Special Publication 800-171, or simply NIST 800-171, outlines the requirements for contractors who handle controlled unclassified information (CUI). DFARS, or the Defense Federal Acquisition Regulation Supplement, mandates cybersecurity requirements to protect unclassified information in non-federal systems. The Cybersecurity Maturity Model Certification (CMMC) is a unified standard of cybersecurity that combines various regulations.
Putting Together Your SSP: Steps to Follow
Creating an SSP may seem daunting at first, but contractors can follow specific steps to ensure they are comprehensive and effective.
Step 1: Identify Your System and the Scope of the SSP
The first step is to identify the system that the SSP will cover. Contractors should also consider the scope of the SSP, such as which information systems, networks, and hardware the plan will cover.
Step 2: Conduct an Assessment of Your System
Conducting an assessment will help identify potential security weaknesses, vulnerabilities, threats, and risks in the system. The assessment should cover all aspects of the system, including hardware, software, process, and personnel.
Step 3: Identify Security Controls to Implement
Based on the results of the assessment, contractors should identify the appropriate security controls to implement.To simplify the process, contractors can use the NIST 800-171 control catalog as the primary resource.
Step 4: Document Your SSP
Next, contractors need to document their SSP. They should follow the DoD template and fill in the required information to describe their system, security controls, and procedures.
Step 5: Submit and Review
Once completed, SSPs must be submitted to the DoD for review. The DoD will review the document to ensure that it meets the required regulations and that the contractor has implemented the required security controls.
Key Elements of an Effective SSP
The key elements that should be included in an effective SSP are as follows:
System Identification: The SSP should begin with a description of the system’s nature and purpose.
Scope of the Plan: Contractors should identify the system boundaries and the scope of the SSP.
Security Management Process: Define the organization’s policies, procedures, controls, and guidelines for security.
Physical Security Controls: Describe facility security measures, access control, and facility access procedures.
Personnel Security Controls: Outline procedures for screening, identifying, and authorizing individuals to work with the system.
Technical Controls: Provide an overview of technical controls in place, such as access controls, encryption, and backup procedures.
System and Services Acquisition: Describe the security considerations for system and services acquisition, including vendor management and supply chain risk management.
Incident Response: Detail the process for detecting, reporting, analyzing, and responding to security incidents.
Continuity of Operations: Describe how the organization maintains the system’s continuity of operations during and after a disaster.
Common Mistakes in SSP Submission and How to Avoid Them
Some common mistakes in submitting SSPs include:
Missing Required Information: SSPs must include all mandatory fields required by the DoD template. Contractors should ensure that they include all necessary information.
Using Non-Standard Format: Contractors should use the DoD template for their SSP. The document should be appropriately formatted and easy to read.
Insufficient Technical Details: Incomplete technical details in the SSP will result in rejection. Contractors should ensure that they provide comprehensive information about their system.
Copying Other SSPs: Contractors may be tempted to copy other SSPs instead of creating their own. This is not advisable as every system has different requirements and needs.
Maintaining and Updating Your SSP Over Time
An SSP is a living document and requires constant updates and maintenance to remain effective. Contractors should update their SSPs each time there are changes in the system, such as hardware or software changes. Additionally, contractors should review their plan regularly to ensure their system remains secure and functional.
In conclusion, all DoD contractors must comply with the agency’s cybersecurity regulations, including submitting an SSP. An effective SSP demonstrates a contractor’s commitment to security and highlights the measures they have taken to protect the DoD’s information systems. Creating an SSP requires following specific steps, and the document should include key elements that make it comprehensive and effective. Mistakes in SSP submission can be avoided, and SSPs require updates to remain relevant.
