To meet CMMC requirements, organizations need a security strategy that integrates technology, people, and policies. It is important to know when to use IT solutions and when to involve HR and leadership so everyone works toward the same goals.
If you are a Department of Defense contractor preparing for CMMC certification, remember that people and policies are as important as technology.
The Human Element in Security
Most security breaches occur due to human actions, not just technical attacks. Studies show that 82% to 95% of incidents are caused by actions such as clicking phishing links, misconfiguring cloud resources, or reusing compromised passwords.
CMMC recognizes that people and processes are equally vital to protecting CUI. Following that, Level 2 or Level 3 certifications require organizations to move beyond compliance training and design systems that account for human behavior under pressure.
This way of thinking, known as Human Factors Engineering, is now a key part of strong compliance programs.
The CMMC Domains That Center on People
CMMC has several control groups that focus on human behavior and organizational setup. The two most important for understanding the human side are Awareness and Training (AT) and Personnel Security (PS).
Awareness and Training (AT)
The Awareness and Training area is much more than yearly videos or simple quizzes. At higher CMMC levels, organizations need to demonstrate they understand advanced threats, such as persistent attackers and sophisticated social engineering. Employees should know not only what phishing looks like, but also how attackers might target them based on their job or access.
Practical exercises are also a key requirement. Phishing simulations and scenario-based training help employees build the muscle memory needed to respond to real threats. According to guidance on CMMC awareness and training requirements, role-based training is essential. A system administrator faces very different threats than a contracts officer, and one-size-fits-all training fails both groups.
Effective programs typically include:
- Targeted Content for Specific Roles: Training that addresses the actual threats a person is likely to encounter in their daily work, rather than generic awareness material that may not apply to their job.
- Hands-On Exercises and Simulations: Phishing tests, incident response drills, and tabletop exercises that give employees practice responding to threats in a low-stakes environment before they encounter them for real.
- Continuous Reinforcement: Regular updates and refreshers that keep security top of mind throughout the year, rather than a single annual session that is quickly forgotten.
Personnel Security (PS)
The Personnel Security domain addresses what many organizations overlook: changes in an employee’s circumstances that affect their trustworthiness. CMMC requires organizations to respond to “adverse information,” data that reflects negatively on an individual’s integrity. This might include criminal activity, serious policy violations, or other risk indicators.
Part of this is moving fast when something comes up related to specific people and their roles. These include identifying systems and data the individual can access, examining logs for unusual activity, and applying enhanced monitoring where appropriate. This is not about punishing employees but ensuring access to CUI is continuously evaluated, not just decided at hiring.
Cognitive Load and Human Failure
A bigger part of managing your people is understanding what can cause failure. In the past, we’ve covered problems like insider threats, but it’s just as likely that a breach or unauthorized access will occur because someone wasn’t 100% on their game. Research consistently points to the same root causes of cognitive overload and fatigue.
Cognitive Load and Workload Pressures
When employees juggle competing deadlines and hundreds of emails, it’s not entirely fair to think they’ll get it right every time. Preoccupied employees are more likely to take shortcuts, skip verification, or click without thinking. This is not a character flaw but a predictable result of how human attention works under stress.
Fatigue in cybersecurity comes in several distinct forms, and each one creates its own risk:
- Alert Fatigue: Security teams often work with dozens of tools that generate thousands of alerts per day. When most alerts turn out to be false positives, analysts begin to dismiss them reflexively.
- Decision Fatigue: Every employee makes dozens of small security-related decisions each day. As the day wears on, the quality of these decisions degrades, potentially introducing errors.
- MFA Fatigue: Multi-factor authentication is one of the strongest defenses available, but attackers have learned to exploit it by bombarding users with prompts. Eventually, some users approve a prompt just to stop the notifications, granting the attacker access.
Complexity and Misconfiguration
Cloud services, on-premises systems, identity providers, and third-party integrations interact in ways that we can’t really fully predict. Research shows that many breaches trace back to misconfigurations rooted in these webs of integrations, and many of those issues arise when user controls and permissions aren’t updated over time due to hiring, firing, or role changes.
What Is Human Factors Engineering?
Awareness training alone is not enough. ISACA’s research on Human Factors Engineering in cybersecurity shows that training results are often mixed and short-lived. Employees may perform well on a phishing test in March and fail one in September. The deeper solution is to design systems that account for human limitations from the start. Human Factors Engineering is an approach that helps your organization clear out much of the noise that can pile up for employees, helping them avoid missing important information.
In practical terms, this means avoiding common antipatterns that work against users:
- Cryptic Links and URLs: Internal systems that send links made of random characters teach users that suspicious URLs are normal. When a real phishing email arrives with a similar cryptic link, users are conditioned not to question it.
- Confusing Encrypted Email Workflows: “Encrypted” email systems that require users to click a link, log in to an unfamiliar portal, and download an attachment look almost identical to phishing attempts. Users either fall for real phishing or refuse to engage with legitimate encrypted messages.
- Overly Aggressive Security Prompts: Systems that constantly interrupt users with warnings and challenges train people to dismiss prompts without reading them.
The goal is to make secure behavior the path of least resistance, rather than something employees have to fight their workflow to achieve.
Building a Culture of Accountability
Even the best-designed systems will fail if the surrounding culture works against them. Organizations preparing for CMMC need to think carefully about the cultural conditions that either support or undermine their technical controls.
- Shadow IT: When official tools are too cumbersome, employees find workarounds. They use personal email to send files, store documents in unsanctioned cloud services, or install productivity tools without IT approval.
- Insider Threats: While intentional sabotage is what most people think of first, unintentional negligence is far more common. An employee who accidentally emails a CUI document to the wrong recipient or connects an unencrypted USB drive to a sensitive system can cause just as much damage as a malicious actor. CMMC’s personnel security and monitoring requirements are designed to address both, but they only work if the organization is paying attention to the behavioral and process indicators that distinguish them.
- ROI and Trust: The most resilient security cultures are not built on fear but on trust. When employees feel safe reporting that they clicked a suspicious link, accidentally sent a file to the wrong address, or noticed something unusual on their system, the organization can respond quickly. When employees fear retaliation, they hide mistakes until they become catastrophes.
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