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How the DOD Cyber Security Program Impacts Contractors

How the DOD Cyber Security Program Impacts Contractors

IT Management Standards, Quality Management Standards (QMS)

Military contractors are usually poised at the cutting edge of DOD cybersecurity programs. Their contributions help the US maintain the most impressive standing army in the world. Because of their position, they have always needed to have top-notch cybersecurity.

Before now, the US Government hasn’t had to put guidelines in place to enforce robust cybersecurity. That changed in June 2020, with the Cyber Security Maturity Model Certification (CMMC). According to the Office of the Under Secretary of Defense for Acquisition and Sustainment (OUSD(A&S)), the CMMC combined several security standards and industry best practices to reduce the risk of threats to contractor systems.

The implementation of this certification has changed the way contractors do business. In this article, we’ll look at the measures that the DOD has implemented to ensure governmental data safety when working with contractors. We’ll also delve into how contractors can figure out if they comply with current standards.

No Longer an Honor-Based System

In the past, contractors needed to sign a document that stated that they followed industry best-practices regarding their Cyber Security. Unfortunately, recent events have forced the government to reconsider its stance. In March 2019, NBC News reported that Iranian-backed hackers gained access to contractor systems, acquiring sensitive data on government-funded projects. Because of the potential fallout associated with sensitive information, the Pentagon decided to take action. The CMMC resulted from consultation, which was designed to ensure that contractors complied with the security standards the government has come to expect from its contractors.

The Cyber Security Obligations for Contractors

The DOD Cyber Security program focuses on one specific clause. The Defense Federal Acquisition Regulation Supplement (“DFARS”) clause 252.204-70122, also known as the “7012 clause.” It has also been referred to as the Safeguarding Covered Defense Information and Cyber Incident Reporting clause. It’s an addition that puts the onus for identifying sensitive information on the contractor. Additionally, the contractor is responsible for ensuring the data they’ve deemed as sensitive remains secure.

Contractors need to be aware of the information they will receive. Typically, the 7012 clause deals with “covered defense information” (CDI). CDIs include unclassified controlled technical data and any information inside the controlled classified information registry. If interaction with a CDI is contained within the contract, the company needs to verify that its practices meet the demands of the DOD Cyber Security program recommendations.

DOD Cyber Security Program Guidelines

Among the guidelines that the DOD suggests for contractors are:

  • Security Standards: At a minimum, contractors should implement the National Institute of Standards and Technology Special Publication 800-171 (“NIST SP 800-171”). This implementation includes putting together a system security plan and an action plan. Both of these plans must be approved by DOD personnel.
  • Rapid Incident Reporting: After an incident occurs, contractors have up to seventy-two (72) hours to submit a report. Reportable incidents have an expansive definition. All accounts must be made to the Defense Industrial Base (DIB) portal and require contractors to have a DOD-approved Medium Assurance Certificate. Because of how tiny the reporting window is, contractors should apply for this certificate in advance.
  • Cloud Computing Standards: The DOD Cyber Security program has its own recommendations for cloud-based solutions. If the business has its own in-house cloud solution, it must implement the NIST SP 800-171. For those using third-party cloud suppliers, the vendors must align with the Federal Risk and Authorization Management Program (“FedRAMP”) Moderate baseline. Vendors must also comply with all obligations related to forensic analysis, media preservation, malicious software, and incident reporting, and damage assessment.

Relying On Your Business Practices

Contractors already have their own standards for operation regarding their cybersecurity departments. However, it doesn’t hurt to have a fallback position. Sync Resource has an understanding of the NIST cybersecurity framework that both the CMMC and the standard DOD cyber security program obligations require. If you’d like a third-party audit of your systems or just advice on how to improve them, give us a call. We’ll be glad to ensure that you’re fully compliant with the DOD Cyber Security standards.

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The Critical Differences Between Quality Control And Quality Assurance

The Critical Differences Between Quality Control And Quality Assurance

Quality Management Standards (QMS)

There are critical differences between quality control and quality assurance.

Here are the definitions of the two:

Definition of Quality Control

Quality Control, often abbreviated as QC is a significant part of Quality Management System (QMS). The focus is to abide by all the quality standards and requirements to produce an optimum quality outcome. QC is more of a product quality oriented approach. The outcomes of QC are usually periodic inspections based.

Definition of Quality Assurance 

Quality Assurance, commonly abbreviated as QA is also an important part of Quality Management System (QMS) which is more process oriented by which products are being manufactured and whose major emphasis is on quality defects prevention.

Differences Between Quality Control And Quality Assurance in an Industrial Perspective

It is important to have a clear cut distinguished definition of Quality control and manufacturing industry so that separate roles and responsibilities can be performed effectively by both the departments. This is one of the differences between quality control and quality assurance.

Quality Control: A Defect Detection Strategy

Quality control is a more of a defect detection and control methodology. QC practices deals with the set of activities that are made to determine the quality of the manufactured products or services ensuring that it should meet the desired quality standards as prescribed in the quality standard.

Quality Assurance: A Defect Prevention Strategy

One of the differences between quality control and quality assurance is that quality assurance is a more focused approach towards defects before they actually happen in the very first place. QA is more of a proactive tactic as compared to QC as it deals with the relevant planning and documentation all to prevent defects happening in the first place.

Comparison of  Differences Between Quality Control And Quality Assurance

S. No. Aspects Quality Control                                Quality Assurance
1. Concept Quality control is a set of best practices whose focus is to ensure flawless product quality. Quality Assurance is a set of best practices whose focus is to ensure flawless quality in the manufacturing process through which final products are being developed.
2. Spotlight On The spotlight of Quality Control is to identify and rectify defects in final product. The spotlight of Quality Assurance is to prevent defects in the process through which final product is developed.
3. Approach QC is Corrective approach towards defects. QA is Preventive approach towards defects.
4. Example The practical example of QC is product testing. The practical example of QA is product validation.
5. Focus Product Oriented Process Oriented

 

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Quality Assurance Frameworks

How Auditing & QA are interlinked with Each other?

Auditing is part and parcel of QA functions whose entire purpose is to draw a comparison between conditions that actually exists versus the requirements of the standard procedures. Quality audit is a practice to verify the effectiveness of Quality Assurance department for not only identifying the defects but for the number of customer complaints regarding product quality, minimization of rework generation and other waste reduction during production cycles. The core essence of QA Audit is to check the amount of orientation of any firm towards winning customers’ satisfaction, trust and confidence. An active QA team plays a vital role in retention of loyal customers.

Total Quality Management (TQM)

Total Quality management is one of the quality assurance framework which is more linked towards the final product quality rather having a paperwork of error observing, defects recording in order to present as a Metrics of the Product Quality Performance. TQM is a business oriented approach which directs towards continual improvement of manufacturing process by reducing waste generation and defected products, high end quality products and services which all results in customers’ satisfaction.

Method of Writing QC/QA Plan

Regardless of the differences between quality control and quality assurance, here are the steps of writing a methodology about designing a QC/QA plan are as follows:

  • Making an Organizational Plan: Detailed job descriptions with defined roles and responsibilities are initial requirements of Quality assurance plan. Secondly, Training Need Analysis (TNA) of every employee (Starting from top leadership managers to junior shop floor team) should be made by mentioning competency level of team members. After TNA being designed, the next step is to make and circulate a training calendar among the employees and managers should be stressed upon the fact that the team working under them should be spared from their day to day tasks so that they can attend their scheduled training sessions.
  • Verification of Work: The QA plan must not only dependent on the person who will be taking all required actions but also on the senior managers who will be keeping a professional check on the completion of the work with defined timelines.
  • Receiving of Raw Materials: Any material that is being purchased should have the specifications defined and any purchased material that doesn’t meet the required specifications should not be put into use to make the final product.
  • Supplier / Vendor Qualification: Suppliers / Vendors should undergo a detailed quality inspection and quality assurance procedure so that the raw materials they provide will also of specified quality standards following the final product being made of unmatched premium quality.
  • Feedback of Customers: Observing consumers’ behavior and recording their feedback voices is another essential part of QA plan. In case any customer feels dissatisfied with your products or services then there should be a proper channel through the customer can launch a complaint against your products or services. After launching a complaint, its closure should be ensured along with specific action plan which can ensure that the same flaw or same mistake would not happen again in the system or in the product and it will not lead to repetitive same natured consumer complaints.
  • Corrective and Preventive Actions: Every defect that happens to appear in the system must be solved after taking actions against the actual root cause. The mindset of the team should be formed in a way that they start disregarding quick fixes to be made in the system which are another temporary solutions that tends to fail in the longer run. It is mandatory to realize that only correcting the mistake is not enough, one must be able to devise such solutions that resist the same mistake to happen in future so a need of comprehensive corrective and preventive actions should be designed after getting approval from all the stakeholders of the final product or services.
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Outsourced Process and Control

Outsourced Process and Control

Quality Management Standards (QMS)

A lot of work gets outsourced in order to operate leaner and still be able to complete task in time for outsourced process.  Everything from HR, Administration, Accounts, Manufacturing, Shipping, Payroll and so on can be outsourced.

Recent trends have made it hard for people in so many terms to not come out as winners. You do what you are good at and rest of it outsource. Seemingly it is the most efficient way of doing things. But there is a glitch. Once process is outsourced it still remains your responsibility to make sure that results are delivered. Out sourced does not translate that it will be somebody else’s responsibility altogether. (more…)