How To Implement NIST 800-171 Controls: A Step-by-Step Guide For IT Teams

Cyber threats are constantly evolving, so organizations should not allow their confidential information to fall into the hands of the wrong people. Thus, for organizations handling the U.S. government, including the Department of Defense (DoD), installing strong security measures is not advisable—it’s mandatory.

Special Publication 800-171 from the National Institute of Standards and Technology (NIST) establishes guidelines for protecting Controlled Unclassified Information (CUI) within non-federal systems.

That said, the NIST 800-171 defines 14 families with 110 controls aimed at helping organizations enhance their cybersecurity stance. The implementation of the controls may prove daunting for the IT departments responsible for managing policy with compliance.

This step-by-step process will guide the IT experts through the essential aspects of NIST 800-171 control implementation to encourage compliance and improve overall data protection.

Step 1: Understand NIST 800-171 Requirements

Before implementation, the IT staff should understand the purpose behind NIST 800-171 and how it applies to their company. The standard was developed to standardize the way subcontractors and contractors handle CUI when working with the government. Any company handling CUI directly or indirectly through a supply chain agreement should comply with these safeguards.

These 14 families of security requirements include access control, incident response, system monitoring, encryption, etc. There are certain controls within each family that must be implemented by the organizations for the sake of preventing unauthorized access, data breaches, and threats via the internet.

Therefore, the IT teams should carefully consider the requirements while developing a compliance strategy to ensure NIST 800-171 compliance and protect sensitive government data effectively.

Step 2: Conduct a Gap Analysis

Gap analysis is the first step toward the implementation of NIST 800-171 controls. The current IT teams need to be evaluated by the IT teams against the NIST requirements by comparing current procedures, technologies, and policies. The assessment determines areas and gaps where improvement needs to be made.

As a step within the gap analysis process, the current controls should be identified and cataloged, including which are currently aligned with the NIST 800-171 standards and which are not.

The gap analysis process provides a clear path toward compliance by identifying the primary areas of emphasis, including access control and risk mitigation mechanisms.

Step 3: Develop a System Security Plan (SSP)

Besides, a System Security Plan (SSP) is a fundamental requirement for NIST 800-171 compliance. The SSP specifies how the organization performs and maintains the security controls employed for the protection of CUI. The SSP should be detailed and include specifics about the organization’s network architecture, security policy, and control implementation plans.

The SSP will need to cover all 14 families of security controls and describe how each control is implemented within the firm. It will also need to define roles and responsibilities for the security team, outline risk assessment details, and describe the technologies employed for enforcing the security measures.

Step 4: Implement Access Control Measures

One of the most critical aspects of NIST 800-171 compliance is the control of access. The right individuals should be ensured by the IT team as the ones with access to CUI. It is a mix of role-based permissions, identity authentication, and robust authentication mechanisms.

In order to enhance access control, organizations should apply multi-factor authentication (MFA) for all users accessing confidential data. Role-based access control (RBAC) should be enforced where employees are granted permissions suitable for their job roles.

The IT teams should also enforce the session timeout policy to avoid the use of unattended workstations for unauthorized access.

Step 5: Enhance System and Communications Protection

Protecting data while in transit and at rest helps prevent data breaches. NIST 800-171 mandates federally approved encryption standards for the encryption process. The encryption protocols should be installed by the IT staff for data stored and data in motion, using AES-256 for data stored and TLS 1.2 and above for data moving.

Moreover, secure channels should be used for the transfer of confidential data. Organizations should use email encryption and virtual private networks (VPNs) to protect data against unauthorized parties.

Step 6: Monitor Auditing System Activity

In addition, continuous monitoring and auditing are necessary to identify and properly handle the incidents. The log mechanisms need to be implemented by the monitoring IT teams for user behavior, system events, and access attempts. The logs must be stored securely and audited periodically to identify suspicious behavior.

A SIEM solution also offers automated log collection and analysis with real-time alerting for potential threats. The organizations also need to perform regular audits to make their security policy and access control compatible with the requirements of NIST 800-171.

Step 7: Developing an Incident Response Plan

An effective incident response plan (IRP) is essential for minimizing the impacts of the breaches. The IT teams with protocols for discovery, handling, and recovery from the incidents should formulate the IRP.

The Incident Response Plan shall have clear-cut steps for identifying threats against security, i.e., breaches, identification of the cause, and restoration back to normal operations.

The IT teams shall also establish a communication policy to inform the stakeholders, government authorities, and law enforcement authorities in case of a data breach.

Wrapping Up

Implementing the NIST 800-171 controls is necessary for government security compliance and protection against Controlled Unclassified Information (CUI). With the help of gap analysis, System Security Plan (SSP) development, and the implementation of necessary security controls, the cybersecurity posture can be strengthened, and risks can be reduced.

Compliance involves continuous monitoring, frequent audits, and employee training to stay one step ahead of threats. While the process might be tedious, breaking it down into steps and following the guidance of experts can make it easier.