The Enclave CUI Management Model: A Necessity for CMMC Compliance
Since the United States Department of Defense (DoD) published the first iteration of the Cybersecurity Maturity Model Certification (CMMC) in early 2020, affected organizations have been reevaluating their cybersecurity strategies in order to ensure compliance.
Failing to obtain and maintain a CMMC certification will prohibit an entity from conducting business with the U.S. government.
Adhering to the CMMC framework and the standards set forth by the National Institute of Standards and Technology (NIST) will not only allow organizations to obtain a CMMC certification but will also assist companies in protecting their clients’ data.
In order to support compliance with the CMMC framework, defense contractors must upgrade their IT infrastructure and migrate to a secure operating environment. Such a comprehensive undertaking will not pose a substantial problem to enterprise-level contractors that almost exclusively engage in defense-centric work.
However, the same cannot be said for small businesses. Many small to medium-sized businesses (SMBs) are involved in a diverse array of projects, not all of which are related to the DoD.
Moreover, a full-scale migration and IT infrastructure upgrade are incredibly cost-prohibitive for these businesses.
This consideration has created a conundrum for SMBs that generate a portion of their revenue from DoD contracts. They must decide to either cease doing business with the DoD or find a way to viably introduce CMMC-level compliance to their organizational hierarchy.
The efforts to achieve CMMC compliance while simultaneously avoiding the need to implement network-wide protections have led to the development of an “enclave” model. When utilized strategically, the enclave method will allow businesses to effectively protect controlled unclassified information (CUI) and achieve CMMC compliance.
What Is an Enclave?
In the traditional sense, an enclave is a “distinct territorial unit” that is encapsulated within a larger territory or nation. As it applies to information security, an “enclave” is a segmented portion of a network that is isolated from the rest of the IT infrastructure.
When using the enclave approach to CUI management, companies will configure their hardware and software in order to create a highly regulated area for handling sensitive data.
A digital enclave separates unauthorized parties from authorized users. The latter will be able to view and interact with CUI and related data in order to carry out core job responsibilities.
Whereas a traditional approach to CMMC compliance requires an organization to implement compliance technologies across its entire infrastructure, the enclave methodology allows for a more measured deployment strategy.
Ultimately, this makes enclave CUI management a more cost-effective option for SMBs, and entities where only a small portion of work is defense-oriented.
When leveraging the enclave CMMC compliance strategy, businesses must systematically identify which employees will be handling CUI. From there, they can then implement the appropriate hardware and software necessary to obtain the requisite CMMC certification level.
In addition to being extremely cost-effective, enclave CMMC compliance models offer better organizational agility than an enterprise-wide deployment strategy. Enclaves can be implemented either temporarily or permanently, depending on the needs of the organization.
An organization that needs long-term CMMC compliance solutions can utilize the enclave model to separate users internally. Conversely, entities that are contracting with other vendors or third-party companies can deploy a temporary enclave infrastructure in order to facilitate secure interaction for the duration of the agreement.
Once the contract lifecycle has expired, the enclave environment can be eliminated.
How CMMC Changed CUI Handling Practices
Controlled unclassified information has not been designated as “classified” by a national security agency. However, it has been deemed sensitive enough to warrant the use of security controls in order to guard against unauthorized dissemination. The data exchanged between the DoD and contractors or vendors is often considered to be CUI.
Prior to the development of the CMMC framework, each contractor was required to implement cybersecurity protocols and monitor the integrity of its own network. Contractors were also directly responsible for protecting any CUI that was transmitted by or stored on their systems.
While contractors are still responsible for implementing and overseeing cybersecurity practices, the CMMC establishes a third-party compliance assessment framework.
Under the CMMC, there are five distinct certification levels. In order to interact with CUI, businesses are required to obtain a Level 3 CMMC certification or higher and exhibit good cyber hygiene. Specifically, organizations that need to handle controlled unclassified information in order to fulfill the obligations of their defense contracts must:
- Utilize DNS filtering
- Use multifactor authentication
- Collect data management information and perform regular audits
- Implement endpoint encryption
- Encrypt all CUI when being transmitted and at rest
- Deploy firewalls and anti-virus software
- Regularly perform CUI data backups
In total, Level 3 of the CMMC framework includes 58 provisions that organizations must adhere to in order to be considered in compliance. Level 4 and Level 5 certification guidelines incorporate additional provisions and require organizations to develop practices for detecting and addressing advanced persistent threats (APTs).
Why Enclaves Have Become a Necessity
In order to ensure compliance with the CMMC framework, defense contractors must implement a dynamic range of cybersecurity resources. Otherwise, they will be found out of compliance and will be disallowed from handling CUI.
Unfortunately, the combined costs of a full-scale network migration and sweeping cybersecurity upgrades pose a major threat to business continuity for many defense vendors.
The financial burden of compliance has been exacerbated by pandemic-related challenges and the relatively short timeline between the CMMC being published and the start of compliance audits.
Cumulatively, these factors have made the enclave CMMC compliance model particularly appealing to businesses that are scrambling to find an alternative to an enterprise-wide infrastructure upgrade. The enclave approach can be scaled to incorporate as many or as few users as necessary.
Advantages of the Enclave Model
The enclave model to CMMC compliance has rapidly gained traction within the DoD contractor sector due to the distinct benefits that it offers. By leveraging the enclave model, businesses can:
Enhance Compliance Efforts
The enclave model facilitates more effective compliance when handling CUI. By utilizing the enclave method, businesses can minimize the complexity of their compliance strategies, thereby increasing transparency as well.
Enclave models only affect employees who interact with or manage CUI. As a result, organizations leveraging this tactic will not have to provide new training to their entire personnel.
They can modify their existing compliance model and training protocols to address the specific needs of a small group of staff members. The reduced scope of this approach will simplify the deployment process, reduce training costs, and minimize the chances of encountering delays during enclave implementation.
Limit the Need for Complex Migrations
Migrating an entire business network infrastructure is a complex process that takes weeks to complete. Not only is this process both time-intensive and labor-intensive, but it also poses a substantial risk to business operations. Even the most well-planned migrations will cause some level of business disruption.
Conversely, the enclave approach reduces the scope of network migration. This reduction will minimize any disruptions to normal business operations while expediting the deployment process. Enclaves can be created and utilized relatively expediently, especially when compared to full-scale migrations.
When using the enclave method, businesses only need to migrate personnel who will be interacting with CUI to the new platform. Other staff members will experience no disruptions to their normal workflow.
Facilitate Secure Interactions with Third Parties
Due to their relatively low costs, enclaves are a versatile compliance solution. As such, they can be deployed on a temporary basis in order to facilitate secure communications between a DoD vendor and a third-party entity. At the end of a contracted agreement, the enclave can be taken offline.
In addition, enclaves are a viable option for handling classified information in other scenarios. Organizations can implement enclaves in any instance where they need to safely manage CUI or other sensitive data but do not want to deploy enterprise-wide cybersecurity solutions.
The enclave model is far more cost-effective than a network-wide migration and cybersecurity software deployment.
This limited approach is particularly beneficial for businesses in which only a few individuals handle CUI. The DoD’s CMMC framework specifically authorizes the use of the enclave model for achieving compliance, as long as the CUI is appropriately protected across any location where it is stored or handled.
By utilizing the enclave model, SMBs can feasibly meet CMMC framework compliance guidelines without placing an undue financial burden on their organization. Enclaves can be created and managed for a fraction of the cost of a full-scale IT architecture upgrade.
Improve Data Security
Adherence to the CMMC framework is not only required for handling CUI, but it is also an effective way of reducing vulnerability to cyberattacks.
Organizations that implement enclaves to protect their most sensitive data can minimize the risk of falling victim to a data breach. In turn, this will allow them to protect their brand image, maintain the trust of their clients, and preserve business continuity.
As businesses continue to adapt to the new requirements set forth by the CMMC framework, the enclave CUI management model will remain a valuable compliance strategy.