How CMMC Maps Onto Other Security Frameworks

Michael Peters

6 months ago

CMMC is already a comprehensive framework that the DoD uses to secure its digital supply chain. The maturity model includes three levels corresponding to the increasingly deep incorporation of NIST controls targeting the protection of Controlled Unclassified Information (CUI), specifically from Special Publications 800-171 and 800-172.

Organizations meeting CMMC requirements, therefore, meet the standards required to provide IT services to defense agencies. However, businesses that work with the DoD most likely work with other companies in other industries–thus necessitating that they meet different requirements in other frameworks.

It’s critical then that these organizations can map their security controls and policies across multiple regulations and frameworks. Fortunately, CMMC can serve as a solid foundation for these efforts.

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Overview of Other Security Frameworks

There are dozens of cybersecurity frameworks worldwide, but not all will apply to IT and software providers in the U.S. There are, however, several core frameworks that these organizations may run into during their work across different industries.

These frameworks include:

ISO 27001: ISO 27001 is an international information security management system (ISMS) standard. It systematically manages sensitive company information, ensuring its confidentiality, integrity, and availability. The standard focuses on establishing, implementing, maintaining, and continually improving an ISMS through a risk management process.
Health Insurance Portability and Accountability Act (HIPAA): HIPAA sets the standard for protecting sensitive patient data in the healthcare industry. It mandates that healthcare providers, payers, and other entities handling protected health information (PHI) implement stringent security measures to ensure PHI’s confidentiality, integrity, and availability.
System and Organization Controls (SOC) 2: SOC 2 is an auditing standard developed by the American Institute of CPAs (AICPA). It evaluates the controls at a service organization relevant to security, availability, processing integrity, confidentiality, and privacy. SOC 2 is critical for service providers storing customer data in the cloud.
Federal Risk and Authorization Management Program (FedRAMP): FedRAMP provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services used by federal agencies. It ensures that cloud service providers (CSPs) meet stringent security requirements to protect federal data.
Payment Card Industry Data Security Standard (PCI DSS): PCI DSS is a set of security standards designed to ensure that all companies that accept, process, store, or transmit credit card information maintain a secure environment. It focuses on protecting cardholder data through robust security controls and practices.

Mapping CMMC to ISO 27001

While CMMC is a maturity model and ISO 27001 focuses on developing ISMSs, both speak to the necessity of robust and foundational security controls. These include:

Information Security Policies: CMMC and ISO 27001 emphasize the importance of comprehensive information security policies. CMMC’s practices under the Access Control and System and Information Integrity (SI) domains align closely with ISO 27001’s Annex A 5.19, which mandates creating and maintaining information security policies.
Asset Management: CMMC includes asset management practices in its domain, mirroring ISO 27001’s Annex A 9, which focuses on the responsibility for and classification of information assets.
Access Control: The Access Control domain in CMMC (AC) aligns with ISO 27001’s Annex A 5.15, covering user access management, system access controls, and the secure allocation of access rights.
Incident Response: Both frameworks require robust incident response capabilities. CMMC’s Incident Response (IR) domain aligns with ISO 27001’s Annex A 5.26, focusing on detecting, reporting, and managing security incidents.
Risk Management: Both frameworks emphasize a risk management approach to security, requiring organizations to identify, assess, and mitigate risks to their information assets.
Training and Awareness: Employee training and awareness are critical components of CMMC and ISO 27001, ensuring that personnel are aware of security policies and procedures.

Mapping CMMC to HIPAA

Healthcare information is a common form of data that extends beyond primary healthcare providers, including military and Defense contexts. As such, the privacy of this data (and similar data) is a shared concern across these frameworks.

Protection of Healthcare Information: CMMC and HIPAA prioritize protecting sensitive information. CMMC’s practices under the Media Protection and System and Information Integrity domains align with HIPAA’s Security Rule, which mandates safeguards to protect the confidentiality, integrity, and availability of electronically protected health information (ePHI).
Access Controls: CMMC’s Access Control domain aligns with HIPAA’s requirements for access controls, including unique user identification, emergency access procedures, and automatic logoff.
Audit Controls: CMMC’s Audit and Accountability domain aligns with HIPAA’s requirements for audit controls, which involve the recording and examining of activity in information systems that contain or use ePHI.
Incident Response: Both frameworks require effective incident response mechanisms. CMMC’s Incident Response practices align with HIPAA’s incident response and reporting requirements.

Mapping CMMC to SOC 2

SOC 2 emphasizes the five Trust Services Criteria, which include Security, Availability, Confidentiality, Processing Integrity, and Privacy–all of which align with CMMC requirements in several places.

Security: CMMC and SOC 2 both prioritize security as a foundational element. CMMC’s Security Assessment and System and Communications Protection domains align with SOC 2’s security criteria, which include access controls, system operations, and change management.
Availability: CMMC’s System and Communications Protection and Maintenance domains align with SOC 2’s availability criteria, ensuring systems are operational and resilient.
Processing Integrity: While CMMC does not have a direct equivalent to SOC 2’s processing integrity criteria, practices within the System and Information Integrity and Media Protection domains contribute to ensuring data is processed accurately and completely.
Confidentiality and Privacy: CMMC’s Asset Management and Media Protection domains align with SOC 2’s confidentiality and privacy criteria, which focus on protecting sensitive information from unauthorized access and ensuring privacy controls are in place.
Access Controls: CMMC and SOC 2 require stringent access controls to ensure that only authorized personnel can access sensitive information.
Audit Logging: Both frameworks emphasize the importance of audit logging and monitoring to detect and respond to security incidents.
Incident Management: Effective incident management is critical for CMMC and SOC 2. It ensures that organizations can quickly identify, respond to, and recover from security incidents.

Mapping CMMC to FedRAMP

FedRAMP speaks directly to CSPs serving federal agencies and derives controls directly from NIST SP 800-53, which means it already has some basic alignment with NIST standards, as CMMC does. As such, CMMC’s rules for CSPs will overlap with FedRAMP requirements in many places.

Security Requirements for Cloud Service Providers: CMMC’s practices within the System and Communications Protection and Maintenance domains align with FedRAMP’s stringent security requirements for CSPs, which include robust security controls and continuous monitoring.
Continuous Monitoring: CMMC and FedRAMP require constant system monitoring to detect and respond to security threats. CMMC’s Risk Management and Security Assessment domains align with FedRAMP’s continuous monitoring requirements.
Incident Response: Both frameworks mandate effective incident response capabilities. CMMC’s Incident Response domain aligns with FedRAMP’s incident reporting, analysis, and mitigation requirements.
Unified Policies: Implementing CMMC’s comprehensive security practices can help organizations meet FedRAMP’s rigorous security requirements, as both frameworks focus on protecting sensitive information.
Automated Tools: Leveraging automated tools for continuous monitoring, as CMMC and FedRAMP require, can streamline compliance efforts and enhance security.
Protecting Cardholder Data: CMMC’s Media Protection and System and Communications Protection domains align with PCI DSS’s requirements for protecting cardholder data, including data encryption and secure storage.
Access Control Measures: CMMC’s Access Control domain aligns with PCI DSS’s requirements for implementing strong access control measures, such as restricting access to cardholder data on a need-to-know basis.
Information Security Policy: Both CMMC and PCI DSS require organizations to maintain and enforce comprehensive information security policies. CMMC’s Security Assessment and Risk Management domains align with PCI DSS’s requirement for maintaining a security policy that addresses information security for all personnel.

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