The threats facing industry’s ability to adequately safeguard its critical infrastructure are escalating dramatically.
Hacking tools that require little or no skill to execute are increasingly available online, lowering the barrier of entry for bad actors and increasing their capabilities. Cybersecurity attacks are complex and often go undetected.
Additionally, Department of Defense (DoD) policy states that “cybersecurity be fully considered and implemented in all aspects of acquisition programs across the life cycle and responsibility for cybersecurity extends to all members of the acquisition workforce.”
General Dynamics Information Technology is committed to a proactive and compliant cybersecurity approach to safeguarding our networks, information, and systems. Below are resources for our Suppliers on federal regulations and how to report cybersecurity incidents. (Please note, "suppliers" or "supply chain" may include contractors, subcontractors, consultants, vendors or OEMs.)
This above reference FAR clause is applicable to all solicitations and contracts when a Supplier at any tier may have federal contract information residing in or transiting through its information systems, including commercial items other than commercially available off-the-shelf items (COTS).
Synopsis of FAR 52.204-21:
Requires basic safeguarding requirements and procedures to protect covered contractor information systems
Imposes 15 categories of security controls focused on safeguarding contractor systems that process, store or transmit Federal contract information
Although not specifically stated, contractors in compliance with the more expansive NIST SP 800-171 security controls will presumably be in compliance with the FAR requirements
Applicable to all solicitations and contracts when a contractor or subcontractor at any tier may have federal contract information residing in or transiting through its information systems. Does not apply to contracts or subcontracts for COTS products.
Additional Defense Federal Acquisition Regulation Supplement (DFARS) provisions:
DFARS: 252.204-7008 Compliance with Safeguarding Covered Defense Information (Oct 2016)
Prescription: All solicitations, including solicitations using FAR part 12 procedures for the acquisition of commercial items, except for solicitations solely for the acquisition of commercially available off-the-shelf (COTS) items
DFARS: 252.204-7009 Limitation on the Use or Disclosure of Third Party Contractor Reported Cyber Incident Information (Oct 2016)
Prescription: All solicitations and contracts, including solicitations and contracts using FAR part 12 procedures for the acquisition of commercial items, for services that include support for the Government’s activities related to safeguarding covered defense information and cyber incident reporting
DFARS: [252.204-7012 Safeguarding Covered Defense Information and Cyber Incident Reporting (Oct 2016)
Prescription: All solicitations and contracts, including solicitations and contracts using FAR part 12 procedures for the acquisition of commercial items, except for solicitations and contracts solely for the acquisition of COTS items
DFARS: 252.239-7009 Representation of Use of Cloud Computing (Oct 2016)
Prescription: All solicitations, including solicitations using FAR part 12 procedures for the acquisition of commercial item, for information technology services
Prescription: All solicitations and contracts, including solicitations and contracts using FAR part 12 procedures for the acquisition of commercial item, for information technology services
NIST SP 800-171 defines the security requirements for protecting Controlled Unclassified Information (CUI) in non-federal information systems and organizations. Generally, Department of Defense contractors, except COTS suppliers, are required to implement these security requirements by no later than December 31, 2017. Please refer to DFARS 252.204-7008, DFARS 252.204-7012 and NIST SP 800-171 for more details.
Department of Defense (DoD) Cybersecurity Maturity Model Certification (CMMC)
CMMC is a DoD certification process to measure a company’s ability to protect Federal Contract Information (FCI) and Controlled Unclassified Information (CUI). CMMC combines cybersecurity standards and maps these best practices and processes to maturity levels, from basic cyber hygiene to advanced/progressive.
All DoD contractors and subcontractors, except subcontractors that solely provide Commercial-off-the-Shelf (COTS) items, will have their cyber acumen scored on a scale of 1 to 5. The Department of Defense will use the same scale to stipulate in solicitations the CMMC level required.
A CMMC Accreditation Body -- a neutral third party that will maintain the standard for DoD –- was established to train and verify third-party cybersecurity certifiers who will conduct audits. Additional information regarding the CMMC Accreditation Body is available at https://www.cmmcab.org/.
DoD contractors and subcontractors must be audited and scored.
CMMC will be included in RFIs starting in Summer 2020
CMMC will be included in RFPs starting in Fall 2020
Certification of cybersecurity compliance will be required for suppliers to do business with GDIT and the U.S. DoD, unless the supplier solely provides COTS items. Certification of cybersecurity compliance is led by the Office of Under Secretary of Defense for Acquisition and Sustainment, and CMMC scores will be tracked by the DoD. Again, all companies will require a CMMC rating from 1 to 5 (except COTS suppliers), and DoD solicitations may restrict the use of suppliers below a specified CMMC level. In order for a supplier to process, store or transmit CUI, it must be certified at least at CMMC level 3.
Suppliers will be responsible for sourcing, conducting and reporting their CMMC audits via accredited third-party entities. The CMMC Accreditation Body is developing the process for certifications. Refer to the “Organizations Seeking Certification” section of the CMMC Accreditation Body site for additional information.
The applicable flow-down clauses are included in General Dynamics Information Technology terms and conditions for its Suppliers.
Reporting a Cybersecurity Incident
In accordance with DFARS 252.204-7012 Safeguarding Covered Defense Information and Cyber Incident Reporting, Suppliers are required to rapidly report cyber incidents within 72 hours of discovery to the GDIT SOC Hotline number 1-571-386-3500, and directly to Department of Defense (DoD) at https://dibnet.dod.mil/portal/intranet/. This includes providing the incident report number, automatically assigned by DoD, to General Dynamics Information Technology as soon as practical.
Achieving Cybersecurity Compliance – Other Helpful Cybersecurity References