Thoughts on Just-In-Time procedures and NIST SP 800-171 / #CMMC compliance...
At Kieri Solutions - Authorized C3PAO , we figured out that people follow procedures best when they 𝘢𝘳𝘦𝘯'𝘵 𝘱𝘳𝘰𝘤𝘦𝘥𝘶𝘳𝘦𝘴.
???
Let me explain.
You're onboarding a new user. To be compliant with #CMMC, your onboarding team needs to go through a convoluted process involving getting details about the new user, verifying NDA, background checks, training, requesting permissions, justifying permissions, reviewing permissions, authorizing permissions, creating accounts, creating records of the accounts, creating records of the permissions for the accounts, assigning expiration dates for each account, setting up a laptop, authorizing the laptop...!!! It goes on and on.
If your strategy is to tell your HR and IT team that they need to perfectly follow a 70 step process on page 19 of ye old 𝐈𝐓_𝐏𝐫𝐨𝐜𝐞𝐝𝐮𝐫𝐞𝐬_𝐌𝐚𝐧𝐮𝐚𝐥, 𝘺𝘰𝘶 𝘮𝘪𝘨𝘩𝘵 𝘢𝘴 𝘸𝘦𝘭𝘭 𝘱𝘢𝘤𝘬 𝘶𝘱 𝘺𝘰𝘶𝘳 𝘣𝘢𝘨𝘴 𝘳𝘪𝘨𝘩𝘵 𝘯𝘰𝘸. The error rate will be upwards of 80%, unless you nag and threaten 😡 everyone constantly, in which case you might get down to an error rate of 30% (and your team will quit).
Instead, if you use a combination of a well-designed Access Request Form and an Account Management database, all your team needs to do is remember to start with the correct form. 📝 The form should have fields and just-in-time instructions for each step of the process between HR and your IT Department. All your team needs to do is fill out each field in the form and they will complete the background screening, training, permissions, justifications, etc. naturally without nagging.
Then, a well designed Account Management database helps your team manage the accounts long-term by including checks ◻️ for commonly-forgotten steps (like user agreements), next-review dates, annual training refresher dates, mapping the user to their supervisor, granular "should-be" permissions for both digital systems and facilities, and historic authorization notes.
The last step for perfect procedures is a regular review to look for and fix errors. But again, if you want to be successful, don't expect your team to remember your dusty policies and procedures book in the corner. Instead, use a scheduled task, a ticket, or a checklist with just-in-time instructions to make sure that the review gets done. Pro-tip: next-review-dates are an excellent way to spread this task across time, instead of trying to do it all in one lump.
Are your compliance policies and processes working for you, or against you? There is a better way. Use thoughtful design in your compliance system to reduce errors and streamline functionality.
Screenshot below is from the Kieri Compliance Documentation's Account Management Database, showing some of the magic of our full-featured 800-171 / CMMC Level 2 compliance program. I'll put the link in comments, for anyone that is interested.