As the digital landscape continues to evolve, the need for stringent cybersecurity measures has become paramount, especially for organizations handling sensitive government data. The NIST 800-171 and Cybersecurity Maturity Model Certification (CMMC) frameworks have been established to provide a set of guidelines that organizations must adhere to in order to safeguard Controlled Unclassified Information (CUI). Microsoft 365 offers a comprehensive suite of services that can be harnessed to create a secure enclave that meets the requirements of NIST 800-171 and CMMC. In this article, we will delve into the steps required to set up such an enclave using Microsoft 365 services.
1. Understanding NIST 800-171 / CMMC Requirements
Before you embark on the journey to set up a secure enclave, it’s essential to have a solid understanding of the specific requirements outlined in the NIST 800-171 and CMMC frameworks. These requirements cover a range of areas including access control, data protection, risk assessment, and incident response. Familiarize yourself with the controls that are relevant to your organization’s operations and align them with the capabilities provided by Microsoft 365.
2. Choose the Right Microsoft 365 Plan
Microsoft 365 offers several plans catering to different needs. To achieve NIST 800-171 / CMMC compliance, you should opt for a plan that includes advanced security and compliance features. Plans such as Microsoft 365 E5 provide robust tools for data protection, encryption, and threat detection. Features included in the Microsoft 365 E5/G5 plan that are not available in lower plans include:
- Azure Information Protection Plan 2 – Plan 2, when compared to plan 1, allows for additional DLP, data classification & automated classification / labeling for protected data.
- Advanced Message Encryption – Allows for additional control of sensitive emails shared outside organization with full audit trails, access logs & automation of encryption using key words.
- Customer Key – NIST 800-171/CMMC requirement to control your root encryption keys. These keys will be stored in an azure key vault and are under complete control by your organization. Keys can be revoked anytime which means even Microsoft cannot read the sensitive data.
- Microsoft Defender for Endpoint Plan 2 – Security monitoring service that continually scans endpoints for threats and vulnerabilities.
- Microsoft Defender for Identity – Security monitoring service that provides a real-time scan and analysis of all user sign-in activity to identify any suspicious or risky activity.
You can also get most of these features in licensing add-ons as well, namely the G5 Compliance add-on and the G5 Security add-on.
3. Implement Access Controls
Access control is a pivotal aspect of NIST 800-171 and CMMC compliance. Microsoft 365’s Azure Active Directory (AAD) offers identity and access management solutions that allow you to enforce strong authentication methods, role-based access controls, and conditional access policies. This ensures that only authorized individuals can access CUI within the enclave.
4. Encrypt Data at Rest and in Transit
Encryption is crucial to protect sensitive information. Microsoft 365 services, by default, are encrypted using Microsoft-managed encryption keys. Per NIST 800-171/CMMC requirements, these encryption keys need to be customer-managed. Additional, Microsoft Intune can be leveraged to roll out BitLocker encryption for data at rest for endpoints and Transport Layer Security (TLS) for data in transit. These encryption mechanisms help prevent unauthorized access and ensure the confidentiality and integrity of CUI.
5. Implement Data Loss Prevention (DLP) Policies
DLP policies are integral to preventing the accidental or intentional leakage of CUI. Microsoft 365’s DLP solutions can scan content across various services like Exchange Online, SharePoint, and OneDrive, detecting and preventing the sharing of sensitive information. Configure DLP policies based on the requirements of NIST 800-171 / CMMC to maintain compliance.
6. Monitor and Detect Threats
Real-time threat detection is essential to identify and respond to potential security breaches promptly. Microsoft 365’s Advanced Threat Protection (ATP) offers tools to monitor email, endpoints, and cloud applications for suspicious activities. ATP’s capabilities can help you detect and prevent phishing attacks, malware, and data exfiltration attempts.
7. Incident Response and Logging
Having a robust incident response plan is a crucial requirement for compliance. Microsoft 365’s Security & Compliance Center allows you to configure audit logs and retain them for the required period. These logs provide valuable insights into activities within your enclave and are essential for incident investigation and reporting.
The Azure-based service, Microsoft Sentinel, can serve as the Security Information and Event Management (SIEM) system. Microsoft Sentinel can serve as the central log repository that connects to all of your Microsoft 365 services and Intune-onboarded devices for automated incident handling and remediation.
8. Regular Security Assessments and Audits
Periodic security assessments and audits are necessary to ensure that your enclave remains compliant with NIST 800-171 / CMMC requirements. Microsoft 365 offers tools that help you conduct vulnerability assessments, penetration testing, and compliance reporting. Regularly review your enclave’s security posture and address any identified gaps.
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