NIST SP 800-161 Rev 1 - Cybersecurity Supply Chain Risk Management Strategy & Implementation Plan (C-SCRM SIP)
ComplianceForge developed an editable template for a C-SCRM strategy and implementation plan. This is fully-editable documentation (e.g., Word, Excel, PowerPoint, etc.) that can enable your organization to "hit the ground running" with C-SCRM operations that are aligned with NIST SP 800-161 Rev 1, which is the current "gold standard" for authoritative C-SCRM guidance.
The reality is organizations depend on a global supply chain to provide a variety of products and services that enable the achievement of its strategic and operational objectives. Given the global scope of identifying cybersecurity and data protection risks, threats and vulnerabilities throughout the supply chain are complicated due to the information asymmetry that exists between acquiring enterprises and their suppliers and service providers:
- Acquirers often lack visibility and understanding of how acquired technology is developed, integrated and deployed and how the services that they acquire are delivered.
- Acquirers with inadequate or absent C-SCRM processes, procedures and practices may experience increased exposure cybersecurity risks throughout the supply chain.
The C-SCRM SIP product is designed to implement a C-SCRM Program, as well as deliver an efficient and cost-effective method to develop a C-SCRM strategy and implement actionable steps to operationalize the C-SCRM strategy. Suppliers, Integrators and Service Providers (SISP) are in scope for C-SCRM operations, where the term SISP includes Original Equipment Manufacturers (OEMs), vendors, contractors, consultants and other entities that make up the supply chain. This scope of operations for the C-SCRM SIP includes all entities that:
- Transmit, process and/or store an organization's, or its clients’, data across the SISP's systems, applications and/or services;
- Manufacture products or product components used in an organization's operations and/or products; and/or
- Provide services for an organization's operations and/or service offerings.
Product highlights of the C-SCRM SIP include:
- Country-based risk guidance to determine minimum management decision levels for conducting operations in or contracting with suppliers from countries that pose a legitimate C-SCRM threat.
- The prioritized implementation plan contains mappings for NIST SP 800-161 R1 controls to each C-SCRM implementation phase.
- Professionally-written, editable documentation template that leverages industry-recognized "best practices" for C-SCRM.
- Cost-effective solution to quickly generate documentation for a C-SCRM strategy and implementation plan.
- Example flow-down contract requirements for suppliers, vendors, subcontractors, etc. (DFARS/CMMC, ISO 27001, NIST CSF, NIST 800-53, FAR, PCI DSS, and EU GDPR/CCPA).
Prioritized C-SCRM Implementation Plan (NIST SP 800-161 R1 Mapping)
The C-SCRM SIP contains a prioritized implementation plan that takes the controls identified in NIST SP 800-161 R1 and assigns the controls to one of twenty-four prioritized phases. This is designed to help prioritize controls that can prevent re-work during the control implementation process. This is one of the many helpful components that comes with the C-SCRM SIP product.
Country-Based Risk Management
To properly manage supply chain-related threats, your organization must evaluate country-based threats posed by its supply chain. This review must cover the geographic concerns where your products, services and support originate from or transit through:
- Transmit, process and/or store your company's or its clients’, data across the SISP's systems, applications and/or services;
- Manufacture products or product components used in your company's operations and/or products; and/or
- Provide services for your company's operations and/or products.
Within the C-SCRM SIP, that criteria for geographic-specific threat management is refined by guidance from:
- Priority Watch List & Watch List
- Corruption Perceptions Index
- Notorious Markets List
- Designated State Sponsors of Terrorism
- EAR / ITAR restrictions
- Potentially hostile data localization laws
Software Bill of Materials (SBOM) Guidance - EO 14028
Executive Order 14028, Executive Order on Improving the Nation’s Cybersecurity, is the driving factor for application security within C-SCRM, due to several, recent high-profile cybersecurity incidents. Specific to C-SCRM application security as it affects private industry, EO 14028 directs US Government agencies to develop plans to:
- Share information by removing barriers to share threat information;
- Modernize cybersecurity capabilities; and
- Enhance software supply chain security.
Due to the nature of how contract requirements flow down through the global supply chain, the ramifications of EO 14028 will be felt across all industries. The requirement that has the most potential to disrupt “business as usual” is expectations that software and services will be expected to have a Software Bill of Materials (SBOM).
Product Example - Cybersecurity Supply Chain Risk Management (C-SCRM) Strategy & Implementation Plan
The Cybersecurity Supply Chain Risk Management Strategy & Implementation Plan (C-SCRM SIP) is based significantly on "best practices" from NIST SP 800-161. It contains necessary components to implement a C-SCRM Program and operationalize a C-SCRM strategy with the provided implementation plan guidance. You get fully-editable Microsoft Word and Excel documents that you can customize for your specific needs
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Example C-SCRM SIP
Cost Savings Estimate - Cybersecurity Supply Chain Risk Management Strategy & Implementation Plan (C-SCRM SIP)
When you look at the costs associated with either (1) hiring an external consultant to write cybersecurity documentation for you or (2) tasking your internal staff to write it, the cost comparisons paint a clear picture that buying from ComplianceForge is the logical option. Compared to hiring a consultant, you can save months of wait time and tens of thousands of dollars. Whereas, compared to writing your own documentation, you can potentially save hundreds of work hours and the associated cost of lost productivity. Purchasing the C-SCRM SIP from ComplianceForge offers these fundamental advantages when compared to the other options for obtaining quality cybersecurity documentation:
- For your internal staff to generate comparable documentation, it would take them an estimated 350 internal staff work hours, which equates to a cost of approximately $26,000 in staff-related expenses. This is about 4-8 months of development time where your staff would be diverted from other work.
- If you hire a consultant to generate this documentation, it would take them an estimated 225 consultant work hours, which equates to a cost of approximately $64,000. This is about 3-6 months of development time for a contractor to provide you with the deliverable.
- The C-SCRM SIP is approximately 5% of the cost for a consultant or 12% of the cost of your internal staff to generate equivalent documentation.
- We process most orders the same business day so you can potentially start working with the C-SCRM SIP the same day you place your order.
The process of writing cybersecurity documentation can take an internal team many months and it involves pulling your most senior and experienced cybersecurity experts away from operational duties to assist in the process, which is generally not the most efficient use of their time. In addition to the immense cost of hiring a cybersecurity consultant at $300/hr+ to write this documentation for you, the time to schedule a consultant, provide guidance and get the deliverable product can take months. Even when you bring in a consultant, this also requires involvement from your internal team for quality control and answering questions, so the impact is not limited to just the consultant's time being consumed.
Cybersecurity Supply Chain Risk Management (C-SCRM) Program
The first step to address that risk is to let your vendors know what is required from them - this addresses due care. The next step is to hold your vendors accountable to meet your requirements - that is due diligence. You owe it to your clients to ensure your risks are addressed across your organization and that is where our Supply Chain Risk Management (C-SCRM SIP) helps.
With requirements like the CMMC, EAR/ITAR, PCI DSS, etc., there is a need for a simple way for a company to inform its service providers of expectations when it comes to managing information security risks. It is a common-sense requirement that businesses should have in place, so that is why there is a push to reduce risk with service providers.
In light of the recent breaches at major corporations, it is likely that a crackdown will follow for businesses to follow better cybersecurity. One of the most important points to remember when it comes to compliance is that if you cannot prove you are compliant (e.g., documented policies & standards) then your business will be unlikely to count on business insurance to cover the expense of a breach.
The C-SCRM SIP can serve as a foundational element in your organization's cybersecurity program. It can stand alone or be paired with other specialized products we offer.
What Is The Supply Chain Risk Management (C-SCRM SIP)?
The C-SCRM SIP is an editable Microsoft Word document that is intended operationalize a C-SCRM Program that can enforce security across your supply chain (e.g., service providers, vendors, contractors, etc.).
- The C-SCRM SIP is based on NIST SP 800-161 R1 to develop a C-SCRM Program, that can apply across the entire organization.
- The text for specific flow-down requirements identified in the C-SCRM SIP can be used in contract a addendum.
- This product addresses the “how?” questions for how your company manages risk with third parties.
- Managing third-party risk is now a common requirement in statutory, regulatory and contractual obligations.
- The C-SCRM SIP helps provide evidence of due care in how your company informs third parties about their cybersecurity obligations.
What Problems Does The C-SCRM SIP Solve?
Procuring Information and Communications Technology (ICT) and Operational Technology (OT) products from suppliers establishes a direct relationship between those suppliers and the acquirers. This relationship is also usually guided by a legally-binding, contractual agreement between the acquirer and the supplier. However, commercial ICT/OT developed by suppliers are typically designed for general purposes for a global market and are not tailored to an individual customer’s specific operational or threat environments. Commercial Off The Shelf (COTS) ICT/OT have some shared vulnerabilities to bespoke products, applications and services, but the opaqueness of the components and modules that make up COTS creates its own issues.
- Lack of In House Security Experience - Writing security documentation is a skill that many good cybersecurity professionals simple are not proficient at and avoid the task at all cost. Tasking your security analysts and engineers to write comprehensive documentation means you are actively taking them away from protecting and defending your network, which is not a wise use of their time. The C-SCRM SIP is an efficient method to obtain documentation to build a C-SCRM Program!
- Compliance Requirements - It is becoming increasingly common for organizations, regardless of industry, to be required to govern its supply chain for cybersecurity and privacy threats and risks.
- Audit Failures - Many organizations run into trouble in audits when asked HOW third-party or supply chain risk is managed, since they cannot provide documentation beyond policies and standards. The C-SCRM SIP addresses the HOW for you!
- Vendor Requirements - It is very common for clients and partners to request evidence of third-party cybersecurity governance. The C-SCRM SIP provides this evidence!
How Does The C-SCRM SIP Solve It?
- Clear Documentation - The C-SCRM SIP provides the documentation to prove that your vendor compliance program exists.
- Time Savings - The C-SCRM SIP can provide your organization with a semi-customized solution that requires minimal resources to fine tune for your organization's specific needs.
- Alignment With Leading Practices - The C-SCRM SIP is aligned with NIST SP 800-161, which is the "gold standard" for supply chain risk management practices.
Reducing Risk Is Central To The Supply Chain Risk Management
Having a Supply Chain Risk Management (C-SCRM SIP) is focused on minimizing risk to your company, your partners and your customers. There is traditionally low level-risk (tactical) that is focused on weaknesses pertaining to routine systems and data. There is mid-level risk (operational) that is focused on weaknesses pertaining to business process. There is also high-level (strategic) risk that impacts at an organizational level. Having a secure vendor relationship can address risk at all three of these levels.