NIST 800-171 Checklist: Fastrack Your NIST Compliance

Meeba Gracy

Meeba Gracy

Mar 06, 2024

NIST 800 171 compliance checklist

NIST 800-171, or NIST SP 800-171, is a guideline issued by the National Institute of Standards and Technology (NIST) for non-federal entities. It outlines rules for securely handling Controlled Unclassified Information (CUI), covering storage, processing, and transmission.  

If your organization does business with the U.S. DoD, you must be NIST 800-171 compliant. It is designed to safeguard CUI in non-federal information systems. It applies to defense contractors or vendors who handle, store, or transmit CUI but are not federal agencies themselves.

Federal agencies often require NIST 800-171 compliance when they work with organizations that handle or store CUI. Non-compliance can lead to fines and penalties, so organizations must take the necessary steps to meet these requirements. 

We have compiled the NIST 800 171 compliance checklist (discussed in the next section) to help you further cement your defense in matters concerning sensitive information.

TL; DR

Why choose NIST 800-171If your organization does business with the U.S. DoD, you must be NIST 800-171 compliant. 
Steps to gaining NIST complianceAssess contract scope and CUI presenceClassify data, meet NIST 800-171 requirementsConduct gap analysis, remediateDevelop and test baseline controlsGather documentation, evidenceConduct continuous monitoringTrain your employees
Importance of complying with NISTComplying with NIST 800-171 is crucial because it sets strong information security standards and guidelines.

NIST 800 171 Compliance Checklist

The NIST 800 171 compliance checklist is important as it provides a step-by-step guide to protecting sensitive data. Let’s take a look at those steps:

  • Assess the scope of the contract
  • Identify whether you’re dealing with CUI
  • Classify the data
  • Gather appropriate documentation
  • Conduct a gap analysis
  • Develop and test baseline controls
  • Gather the right evidence
  • Conduct continuous monitoring
  • Train your employees

1. Assess the scope of the contract

Find out if your organization needs to follow the NIST 800-171 standard.

If you are subject to the standard, assess the contract’s scope to determine which NIST 800-171 requirements apply. Understanding the scope is the first thing you must do to know your company’s requirements to stay compliant.

The scope of the contract usually includes:

  • Adherence to the Defense Federal Acquisition Regulation Supplement (DFARS) and other relevant federal regulations
  • Compliance with cybersecurity requirements, such as those outlined in the Cybersecurity Maturity Model Certification (CMMC)
  • Obtaining and maintaining necessary security clearances for personnel
  • Ensuring secure handling and storage of classified information
  • Meeting specified technical and performance standards for products and services
  • Delivering products or services within the agreed timeline and budget

2. Identify whether you’re dealing with CUI

Determine if you’re dealing with CUI. CUI is any information created or held by the Government or another entity on behalf of the Government that must be protected according to laws, regulations, or government policies.

To meet NIST 800-171 compliance, companies must identify whether they are receiving and using CUI and know where it’s stored. This requires a complete audit of the company’s systems and data flows, from employees’ computers to third-party contractors.

Keep an eye out for certain keywords or topics that usually indicate CUI. Terms like “critical infrastructure,” “export control,” or “statutory” are red flags for potential CUI. Hence, you need to understand what typically gets classified as CUI to prepare for the next step in the checklist.

3. Classify the data

Once you identify CUI, categorize it according to its type. This is important because different types of CUI may require varying levels of protection. Knowing the type of CUI involved during a security incident helps quickly determine the appropriate response and remediation actions. 

With that being said, NIST 800-171 recognizes 20 categories of CUI, each with specific standards:

  1. Critical Infrastructure
  2. Defense
  3. Export Control
  4. Intelligence
  5. Procurement and Acquisition
  6. Financial
  7. Law Enforcement
  8. Legal
  9. International Agreements
  10. Natural and Cultural Resources
  11. Nuclear
  12. Provisional
  13. Patents
  14. North Atlantic Treaty Organization (NATO)
  15. Privacy
  16. Proprietary Business Information
  17. Statistical
  18. Tax
  19. Transportation

This step is important because correct classification is necessary to comply with the relevant standards for each category.

4. Gather appropriate documentation

To pass a NIST 800-171 compliance audit, you need thorough documentation showing that all controls and requirements are met. Before the audit, make sure to gather documentation in these areas:

  • System and network architecture: Detailed diagrams and descriptions of your system and network setup.
  • System boundaries: Clear definitions of where your systems begin and end, including interfaces with other systems.
  • Data flow: Documentation showing how data moves through your systems, including where it is stored and processed.
  • Personnel: Records of staff roles and responsibilities, including who has access to CUI and their training records.
  • Processes and procedures: Written procedures and policies for handling CUI, security measures, and incident response plans.
  • Anticipated changes: Information about any planned changes to your systems or processes that could affect compliance.

Does this step seem challenging? 

This is where GRC automation software like Sprinto can help. How does it help? Sprinto’s “Bring Your Own Controls” feature allows companies to configure various frameworks, including NIST, making Sprinto the platform of choice for automating compliance across all frameworks.

Sprinto simplifies the process by offering recommendations and an “Auto-map” feature that automatically links checks to controls, making starting and progressing your compliance journey easy.

Get NIST compliant with ease

5. Conduct a gap analysis 

Before starting the certification process, conduct a pre-assessment to determine your readiness. This includes a gap analysis to identify existing gaps. Focus on primary access control requirements first, then move on to other areas. Here, you need to document any flaws or control gaps so you can address them.

While an experienced NIST partner can help you perform a thorough gap analysis and system review, Sprinto offers a more efficient solution. Designed for cloud-based solutions, Sprinto quickly maps relevant controls to industry standards and identifies gaps.

Sprinto helps you run automated checks, highlights areas for improvement, and guides you toward a more structured approach to NIST 800-171 compliance. This way, your dependence on external bodies also lessens.

Fastrack NIST compliance through automation

6. Develop and test baseline controls

Another difficult task of an organization is to identify the quality of the selected security and privacy controls that would safeguard its mission and business functions from threats and risks. 

These controls must be compliant with the various legal requirements, security standards, and policies in place. If correctly adopted, they will enhance compliance and security standards as required.

Even if your company already has cybersecurity policies, it’s important to ensure that your baseline controls cover all 14 control families listed in NIST 800-171.

Sprinto helps to eliminate this problem by automatically mapping entity-level controls, thereby cutting down the time it takes to carry out this function. 

Assets can be categorized as production and non-production and it is possible to specify security parameters for both types; in some cases, some non-production assets can be excluded from the audit. This makes it possible to develop effective and efficient controls, that respond to the current requirements.

7. Gather the right evidence

Next, gather the necessary evidence for your NIST audit. Focus on the 14 NIST 800-171 criteria to identify the audit requirements you’ll address. While the main goal of collecting evidence during a security incident is to resolve it, this evidence might also be needed for legal proceedings. It’s crucial to document how all evidence, including compromised systems, is preserved. 

Designer: Recreate this image with the current color palette

As you make compliance changes, you must provide audit trail evidence to show your actions and ensure accountability. A GRC automation platform like Sprinto simplifies this by continuously monitoring and collecting evidence. 

You can add new custom processes for manual reviews, upload screenshots and documentation for each control, and create periodic processes. Sprinto will alert you to complete actions and upload the necessary evidence, making the entire process more manageable and efficient against cyber threats.

To learn more about automating evidence collection using Sprinto, watch this video

Regularly performing routine and ongoing audits will help you maintain and enhance security. Using automation tools can make this process much easier and more effective. Sprinto GRC automation tool will help you continuously monitor your systems and check for compliance with security standards without requiring much manual effort.

8. Conduct continuous monitoring

Continuous monitoring is the process and technology that detect compliance and risk issues related to a company’s operational environment. The best way to go about it is to regularly test it and whenever a vulnerability is noticed, improve your controls.

To help with this, Sprinto connects with your systems to automatically map and monitor controls against security standards like NIST 800-171, to test compliance, collect evidence, and trigger remediation workflows—24×7, 365 days a year. 

Sprinto has over 200 integrations and custom API that connects everything and everyone. This starts fromcloud apps, infrastructure, code repos, devices, and people — to build a centralized view of assets, risks, and controls. You test controls, execute compliance tasks, and collect evidence without errors or missing links.

9. Train your employees

Roy H Williams said “Training is not an expense, but an investment to human capital.” Hence, as a part of getting NIST 800-171 compliant, make sure to develop a detailed training plan that includes:

  • Assessing current knowledge levels of employees
  • Sett clear objectives
  • Create engaging materials such as videos, presentations, handbooks, and interactive tools

This way, you’ll be well on the way to face any cybersecurity challenges.

Importance of Complying With NIST 800 171

Complying with NIST 800-171 is crucial because it sets strong information security standards and guidelines. While preparing for NIST certification can be challenging, understanding its importance helps clarify why it’s worth the effort.

Consider the cybersecurity issues that might keep you up at night:

  • Identifying assets: Not knowing exactly what needs protection.
  • Risk management: Understanding how to handle security risks with your current tools and solutions.
  • Resource allocation: Your team spends too much time on low-impact issues instead of focusing on real risks.
  • Hidden vulnerabilities: Worries about unseen risks and vulnerabilities.
  • Team ownership: Colleagues outside the security team don’t fully understand or take responsibility for critical mitigation tasks.
  • Compliance questions: The board asks if your cybersecurity plan aligns with NIST standards.

NIST 800-171 helps address these challenges. It offers a framework for prioritizing investments and making informed decisions in cybersecurity. In essence, NIST 800-171 guides you through the complexities of cybersecurity, helping you learn from others who have faced similar issues and ensuring your organization meets high-security standards.

Simplify Your NIST Journey With Sprinto

Achieving NIST certification involves many steps and extensive preparation. However, with the right tools and processes, you can simplify and expedite this process. This is where a GRC automation platform like Sprinto comes in handy for a full-blown risk and security assessment.

Sprinto makes NIST SP 800-171 standard compliance faster and easier. Our automation tool helps you assess your existing controls and identify what’s needed to comply with regulations. Here’s how Sprinto can assist you:

  • Sprinto evaluates your current controls and highlights areas that need attention to comply with NIST 800-171 audit.
  • We provide API endpoints for every check on Sprinto, allowing you to set up secure integrations and automatically push evidence to the platform. This means you can collect and manage the evidence required for compliance.
  • Sprinto helps you scale your security program without worrying about the tools you use. You can set up evidence collection for any critical open-source tool that needs monitoring.
  • With Sprinto, you can focus on the most critical aspects of your security program, ensuring that all compliance requirements are met without unnecessary hassle.

Interested? Get in touch with our compliance experts to know more.

FAQs

Who is required to comply with NIST?

Any company that does business with the United States government is required to comply with NIST standards. This includes:

  • Federal Government Agencies: All agencies within the U.S. government must adhere to NIST standards to ensure robust cybersecurity practices.
  • Federal Contractors and Subcontractors: Businesses and individuals hired by the government to perform work on projects must also comply with NIST standards.

What is the difference between NIST 800-171 and 800 172?

  • NIST SP 800-171: Provides security controls for safeguarding CUI in non-federal systems.
  • NIST SP 800-172: Adds an additional level of security for CUI associated with high-value federal assets or critical government programs, building upon the controls in NIST 800-171.

Does NIST 800-171 require FIPS?

Organizations need to employ FIPS 140-2 or FIPS 140-3 cryptographic protections to be compliant with NIST 800-171.

What are the 5 stages of NIST?

̌The 5 stages of NIST are:

  1. Identify 
  2. Detect
  3. Protect
  4. Respond 
  5. Recover

How many types of NIST are there?

The NIST Cybersecurity Framework’s “core” material consists of five functions, which are further divided into 23 categories. Each category is broken down into a number of subcategories, totaling 108 subcategories that define specific security controls and cybersecurity outcomes.

How many types of NIST are there?

The NIST Cybersecurity Framework divides its “core” material into five distinct “functions”, which are further divided into a total of 23 “categories”.  For every category, it defines a number of subcategories of security controls and cybersecurity outcomes, with a total of 108 subcategories in all.

Meeba Gracy

Meeba Gracy

Meeba, an ISC2-certified cybersecurity specialist, passionately decodes and delivers impactful content on compliance and complex digital security matters. Adept at transforming intricate concepts into accessible insights, she’s committed to enlightening readers. Off the clock, she can be found with her nose in the latest thriller novel or exploring new haunts in the city.

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