CMMC: Policies and Procedures Contractors Should Have

Information security policies and procedures are the backbone of any cybersecurity program. This includes companies with cybersecurity maturity model certification (CMMC) level two or higher requirements. As a matter of fact, to have a mature cybersecurity program, contractors must “establish and document practices and policies to guide the implementation of their CMMC efforts” (CMMC Model Main V1.02).

Here are areas for which contractors with CMMC level two or higher requirements should have policies and procedures for:

• Access Control
• Audit and Accountability
• Configuration Management
• Configuration Planning
• Incident Response
• Identification and Authentication
• Information Flow Control
• Information Flow Enforcement
• Information System Maintenance
• Media Protection
• Media Sanitization and Disposal
• Mobile Code Implementation
• Password
• Personnel Security
• Physical and Environmental Protection
• Portable Media
• Risk Assessment
• Security Assessment and Authorization
• Security Awareness and Training
• Security Planning
• Separation of Duties
• System and Information Integrity
• System and Services Acquisition
• System and Communication Protection
• System Use

You can document policies for the above items in your information security policy and you should maintain a standard operating procedure document that “enables individuals to perform them (CMMC practices/requirements) in a repeatable manner”. Processes such as account provisioning, patch deployments, configuration changes, incident response, employee training and everything else that comes to mind should have a document process.