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CMMC 2.0 Compliance: Navigating Title 32 & Title 48 with Data-Centric Security

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    The Cybersecurity Maturity Model Certification (CMMC) program emerged in 2020 as a critical guide map and framework for protecting Controlled Unclassified Information and working with the DoD. In 2024, on its second, more stringent iteration, it's been published to the Federal Register. Which means it's gametime for DIB contractors to work toward compliance and maintain their contracts.

    So today, we're diving into the latest developments included in the published final rule, and exploring how data-centric security solutions like Virtru are playing a pivotal role in this journey.

    Understanding CMMC 2.0: Title 32 and Title 48

    The DoD is crafting two separate but interdependent Code of Federal Regulations (CFR) titles for CMMC:

    1. Title 32: Will be effective in December 2024, this establishes the CMMC program and its ecosystem. It defines cybersecurity standards, levels, and assessment requirements.
    2. Title 48: Anticipated to take effect in early 2025, this creates the DFARS 252.204-7021 clause for DoD contracts, enforcing CMMC requirements in contracts.

    This phased approach allows organizations time to prepare and get certified before CMMC becomes a contractual requirement. However, the time to act is now, as some prime contractors are already requiring minimum cybersecurity standards from their subcontractors.

    The Role of Data-Centric Security in CMMC Compliance

    As organizations embark on their CMMC compliance journey, data-centric security solutions are emerging as crucial tools. Virtru, a leader in this space, is already being utilized by hundreds of federal contractors, universities, research institutions, and other organizations to get ahead of the curve.

    How Virtru Supports CMMC 2.0 Compliance

    Virtru's data-centric security products address a significant portion of CMMC 2.0 requirements, particularly those related to the protection of Controlled Unclassified Information (CUI). Here's how Virtru contributes to CMMC compliance:

    1. Comprehensive Control Support: Virtru supports 27 of the 110 total CMMC controls, covering a large portion of data security needs in the compliance journey.
    2. Access Control: Virtru's solutions limit system access to authorized users and control the flow of CUI in accordance with approved authorizations.
    3. Audit and Accountability: With robust audit capabilities and activity logs, Virtru ensures that actions of individual users can be traced and accounted for.
    4. Encryption: Virtru provides FIPS-validated cryptography to protect the confidentiality of CUI both in transit and at rest.
    5. Media Protection: Virtru's access control and data-centric security features protect CUI stored on digital media during transport and in backups.

    CMMC Compliance: A Journey, Not a Destination

    It's important to understand that achieving CMMC compliance is not an overnight process. It's a journey that requires continuous effort and improvement. This is why adopting solutions like Virtru is crucial:

    1. Affordable and Easy to Deploy: Virtru's controls are designed to be cost-effective and simple to implement, making them an ideal starting point for organizations beginning their CMMC journey.
    2. User-Friendly: The ease of use ensures that these security measures can be adopted across the organization without significant disruption to workflows.
    3. Immediate Impact: While not a silver bullet for all CMMC requirements, Virtru provides immediate enhancement to an organization's data security posture, addressing a significant portion of CMMC controls.

    Taking the Next Steps

    As we approach the implementation dates for CMMC 2.0, organizations should: Start preparing for CMMC certification as soon as possible; focus on improving their cybersecurity posture, including implementing data-centric security solutions; stay informed about the implementation timelines for both Title 32 and Title 48; and consider engaging with C3PAOs (CMMC Third Party Assessment Organizations) for assessments once Title 32 is effective.

    Remember, the goal of CMMC is not just compliance, but genuine improvement in cybersecurity practices. By adopting robust data-centric security measures like those offered by Virtru, organizations can make significant strides in protecting sensitive information and meeting CMMC requirements.

    As you navigate your CMMC compliance journey, consider how data-centric security can provide a strong foundation for your efforts. It's not just about meeting standards—it's about creating a resilient, secure environment for handling critical information in the defense industrial base.

    Matt Howard

    Matt Howard

    A proven executive and entrepreneur with over 25 years experience developing high-growth software companies, Matt serves as Virtu’s CMO and leads all aspects of the company’s go-to-market motion within the data protection and Zero Trust security ecosystems.

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