Policy Perspective

Navigating Unclassified Information System Security Protections (slides for COGR)Thursafternoon

The document provides an in-depth overview of Department of Defense (DoD) initiatives and regulatory requirements concerning the safeguarding of covered defense information (CDI), network penetration reporting, and the procurement of cloud computing services, focusing primarily on revisions to the Defense Federal Acquisition Regulation Supplement (DFARS) through Case 2013-D018. Central themes include the identification and marking of CDI, the implementation of adequate security controls—primarily through NIST SP 800-171 guidelines for non-federal systems—and the establishment of protocols for reporting and assessing cyber incidents affecting unclassified but sensitive defense-related data. The document delineates the scope of these rules, specifying the types of information and activities covered, the minimum required protections, and the responsibilities of prime contractors and subcontractors regarding both incident notification and compliance with security measures.

The document also addresses contractual considerations related to the use of cloud services within DoD acquisitions. It clarifies when specialized DFARS clauses apply, defines responsibilities for both direct government cloud contracts and contractor-managed cloud solutions, and references the DoD Cloud Computing Security Requirements Guide (SRG) for standardizing security expectations. Furthermore, it distinguishes between the application of NIST SP 800-171 (for contractor internal systems) and the SRG (for cloud environments). The text notes ongoing rulemaking and public consultation to refine these processes, highlights resources available for compliance guidance, and emphasizes the shift toward using uniformly structured, performance-based security requirements (as seen in NIST SP 800-171) to foster consistent protection of controlled unclassified information across defense supply chains.