The Strategic Imperative of CMMC Compliance: A Letter to the CEO and Board from their CISO

Introduction

In our digital age, the sanctity of data and the trustworthiness of systems are paramount. For organizations working within the Department of Defense (DoD) supply chain, this sentiment has taken shape in the form of the Cybersecurity Maturity Model Certification (CMMC). For CEOs and Boards, understanding the strategic and operational significance of CMMC is not just about compliance; it’s about safeguarding our collective national security interests and reinforcing trust with our governmental partners.

Why CMMC Matters to Us All

For any organization, the data we manage and the systems we employ form the backbone of our operations. In the context of the defense sector, the stakes are even higher. The CMMC stands as a testament to the DoD’s commitment to ensuring that all levels of its supply chain are secure against cyber threats. But it’s more than just another standard:

  • Reputation: Achieving CMMC compliance is a visible indicator of our commitment to cybersecurity. It builds trust with not just the DoD but also other stakeholders, demonstrating our unwavering focus on data security.

  • Economic Impact: Non-compliance isn’t an option if we wish to continue or seek contracts within the DoD supply chain. Compliance ensures our continued market relevance and positions us as leaders in the defense industry.

  • National Security: At its core, CMMC is about protecting sensitive information from falling into the wrong hands. Every breach in the supply chain is a potential threat to national security.

The Mountain We Climb

Understanding CMMC's Complexity

Achieving CMMC compliance is undeniably complex. The model spans five maturity levels, ranging from basic cyber hygiene to advanced practices. Its comprehensiveness is both its strength and its challenge:

  • Depth and Breadth: CMMC doesn’t just touch on technology. It encompasses processes, people, and governance structures.

  • Evolving Threat Landscape: The cyber threats of today aren’t static. As adversaries evolve, so must our defenses, making ongoing adherence to and beyond CMMC crucial.

  • Resource Intensiveness: Compliance requires significant investment – both in terms of technology and human resources. It’s not a one-time project but an ongoing endeavor.

Charting the Course

Steps to Achieving CMMC Compliance

Navigating the intricacies of CMMC might seem daunting, but with a systematic approach, it is attainable.
Here’s a roadmap for our journey:

  • Assessment of Current State: Before embarking on this journey, we need to understand where we stand. Engage external experts to perform a thorough audit of our current cybersecurity posture against CMMC standards.

  • Gap Analysis: Identify areas where our practices fall short of CMMC requirements. This gap analysis becomes the foundation for our action plan.

  • Building a Cross-functional Team: This isn’t just an IT project. Involve representatives from legal, HR, operations, and other relevant departments to ensure a holistic approach to compliance.

  • Prioritize Remediation Efforts: With the gaps identified, prioritize them based on risk. Address high-risk areas first to get the most significant security gains early.

  • Training & Awareness: Every employee plays a role in cybersecurity. Launch a company-wide training initiative to ensure that everyone understands their responsibilities under CMMC.

  • Continuous Monitoring & Improvement: CMMC isn’t a “set it and forget it” model. Implement continuous monitoring tools and practices to ensure ongoing compliance and to identify potential areas of improvement.

  • Engage a Third-party Assessor: Once we believe we’re compliant, it’s time to bring in an external CMMC assessor to validate our practices and grant certification.

A Call to Leadership

Why CEO and Board Engagement is Crucial

CMMC compliance is not just an operational challenge; it’s a strategic imperative:

  • Resource Allocation: Achieving and maintaining compliance requires investment. Your support ensures that we allocate the necessary resources effectively.

  • Culture of Cybersecurity: Leadership’s focus on CMMC sends a powerful message across the organization, fostering a culture that prioritizes cybersecurity.

  • Risk Management: Cyber risks are business risks. Your engagement ensures that we address these risks holistically, integrating them into our broader risk management framework.

Conclusion

The journey to CMMC compliance is undoubtedly challenging, but it is one we must undertake. For CEOs and Board members, understanding and supporting this initiative is paramount. It’s not just about securing contracts or meeting regulatory requirements; it’s about fulfilling our duty to our nation, our partners, and ourselves. Together, let’s champion a culture of cybersecurity resilience, ensuring that we remain trusted guardians of the data and systems entrusted to us.

Get in touch with us

Secutor Cybersecurity is a trusted partner comprised of industry leading experts in the fields of Cybersecurity and Governance, Risk and Compliance. We partner with our clients to deliver on-demand solutions tailored to expertly navigate the regulatory demands of their specific industries.

Our proven track record of successfully exceeding client expectations is achieved through the combination of our methodical approach, advanced technologies, subject matter experts, and synergy with client team members.

Secutor is your team of world-class problem solvers with vast expertise and experience delivering complete solutions keeping your organization protected, audit-ready, and running smoothly.

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Jason Fruge

Consulting Chief Information Security Officer (CISO)

Jason Fruge is an accomplished Consulting Chief Information Security Officer at Secutor Cybersecurity, bringing over 25 years of deep expertise in information security. His storied career includes leading and managing robust security programs for Fortune 500 companies across retail, banking, and fintech sectors. His current role involves providing strategic guidance and advisory services to clients, focusing on security governance, risk management, and compliance.

Apart from his consulting responsibilities, Jason is an active member of the global cybersecurity community. He is a Villager at Team8, a prestigious collective of senior cybersecurity executives and thought leaders. Additionally, he serves as an Advisor at NightDragon, an innovative growth and venture capital firm specializing in cybersecurity and enterprise technologies.

Jason’s tenure as a CISO is marked by a proven track record in developing and implementing comprehensive security policies and procedures. He adeptly leverages security frameworks and industry best practices to mitigate risks, safeguarding sensitive data and assets. His expertise encompasses incident response and root cause analysis, where he has notably managed cyber incidents to prevent breaches and minimize business disruption and customer impact.

A key aspect of Jason’s role has been the creation and facilitation of executive and board-level cyber risk committees, ensuring organizational alignment and awareness. His responsibilities have extended to maintaining compliance programs for standards such as PCI and SOX, as well as leading privacy and business continuity programs. Holding prestigious certifications like CISSP, QSA, and QTE, Jason is also a recognized thought leader, contributing articles on cybersecurity to InformationWeek.

Jason’s passion lies in driving innovation and fostering collaboration in the cybersecurity field. He is currently seeking an executive CISO role in a leading retail, finance, or fintech organization, where he can continue to make significant contributions to the cybersecurity landscape.

Jennifer Bayuk

Cybersecurity Risk Management Expert

Jennifer Bayuk is a highly esteemed cybersecurity risk management thought leader and subject matter expert at Secutor Cybersecurity. Her extensive experience encompasses managing and measuring large-scale cybersecurity programs, system security architecture, and a wide array of cybersecurity tools and techniques. Jennifer’s expertise is further deepened with her proficiency in cybersecurity forensics, the audit of information systems and networks, and technology control processes.

Jennifer’s skill set is comprehensive, including specialization in cybersecurity risk and performance indicators, technology risk awareness education, risk management training curriculum, and system security research. Her academic achievements are noteworthy, holding Masters degrees in Philosophy and Computer Science, and a Ph.D. in Systems Engineering. This strong academic background provides a solid foundation for her practical and strategic approach to cybersecurity challenges.

Certified in Information Systems Audit, Information Systems Security, Information Security Management, and IT Governance, Jennifer is a well-rounded professional in the field. Her credentials are further enhanced by her license as a New Jersey Private Investigator, adding a unique dimension to her cybersecurity expertise.

At Secutor, Jennifer plays a pivotal role in steering cybersecurity initiatives, aligning them with organizational risk appetites and strategic objectives. Her ability to educate and train in the realm of technology risk has been instrumental in raising awareness and enhancing the cybersecurity posture of our clients. Her dedication to research and continual learning makes her an invaluable resource in navigating the ever-evolving cybersecurity landscape.

Jennifer Bayuk’s blend of academic prowess, practical experience, and certifications make her an indispensable part of our team, as she continues to drive forward-thinking cybersecurity solutions and risk management strategies.

Steve Blanding

CISO Consultant

CISSP, CISA, CGEIT, CRISC

Steve is an IT management consultant living in Dallas, TX. Steve has over 35 years of experience in executive IT leadership, IT governance, risk and compliance (GRC), systems auditing, quality assurance, information security, and business resumption planning for large corporations in the Big-4 professional services, financial services, manufacturing, retail electronics, and defense contract industries. He has extensive experience with industry best practices for adopting and implementing new technologies, IT service management frameworks, and GRC solutions that have dramatically improved customer satisfaction while reducing cost.

Industry Experience

  • State Government: 5 years
  • Retail: 5 years
  • Defense Contract: 5 years
  • Manufacturing: 2 years
  • Health Care: 2 years
  • Local Government: 2 years
  • Public Accounting (Big 4): 7 years
  • Insurance: 3 years
  • Financial Services: 5 years

Key Career Accomplishments

  • Conducted a full-scale ISO27000 audit 4 times over the past 6 years.  Also, conducted a “light” ISO27000 review of a small Dallas-based company in 2007.
  • Developed and authored a comprehensive IT security policy manual, incident response plans, training programs, security contingency plans and configuration management plans for FedRAMP regulatory compliance.
  • Conducted multiple DR and operational backup and recovery IT risk assessments of critical business systems on mainframe, LAN, and distributed system networks located across North America.
  • Conducted data centers audits for Tyco Corporation (Brussels, 2005 and Denver, 2006), Farmers Insurance (Los Angeles, 2006), Zurich Financial Services (Chicago, Kansas City, and Grand Rapids, 2006), and Convergys Corporation (Dallas, 2010, 2011, and 2012).
  • Led a project to remediate segregation of duties and streamline user access system security and HIPAA compliance administration across 5 regions in North America, resulting in cost savings of $700,000 per year (Kaiser Permanente).
  • Implemented Sarbanes-Oxley Section 302 and 404 IT general and application controls, reducing security administration costs and improving operational performance by 50% or $500,000 annually (Tyco Corporation).
  • Led the global SAP business-IT alignment, process re-design implementation initiative for financial accounting, materials management, production planning, quality management, sales and distribution, warehouse management, and plant maintenance, which resulted in creating $2,000,000 in cost savings.
  • Engaged by Arthur Andersen in Houston to transform the local IT organization and then direct 3 organizational mergers/consolidations, which resulted in a 25% reduction in operating costs, or $3,250,000, while improving customer satisfaction by 30%, and improving employee morale, technology availability and the quality of IT infrastructure and service delivery.
  • Assigned by Arthur Andersen global leadership to lead global project teams responsible for data center and customer support call center consolidation, which resulted in annual operational cost savings of 45% or $4,000,000.
  • Implemented ITIL service management practices for problem management, incident management, help desk, project management, and operations management.
  • Conducted SOX 404 audits at Duke Energy (6 months), Red Hat (3 months), Tyco (9 months), Zeon Chemicals (4 months), and Convergys (2 months). Experience includes control design/documentation and effectiveness testing.

Publications:

Author, various articles in EDPACS and Auerbach’s IT Audit Portfolio Series, 1981 – 2001

Author, various articles in the Handbook of Information Security Management, 1993 – 1995

Editor, Auerbach’s Enterprise Operations Management, 2002

Editor, Auerbach’s IT Audit Portfolio Series, 2000 – 2002

Consulting Editor, Auerbach’s EOM Portfolio Series, 1998 -2001

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