DFARS 252.204-7012: Why a Proactive Incident Response Plan Is Crucial

DFARS 252.204-7012: Why a Proactive Incident Response Plan Is Crucial

Organizations should not wait for a security incident to happen before developing an incident response (IR) plan. Some organizations, however, neglect to develop an IR plan due to plain old procrastination and wait for something to trigger them to take action. On the other hand, others simply do not have the resources to do so.

This can spell trouble, because security incidents do happen, and an organization’s best defense to avoid the chaos that usually follows is to have an IR plan that can help them prevent further consequences and mitigate current risks.

What Is an Incident Response Plan?

Contractors for the Department of Defense (DoD) should have an incident response plan, or a set of guidelines that an IT team can follow to detect, analyze, mitigate, respond to, and recover from a security incident. These instructions are critical to addressing further breaches, data loss, downtime, and similar events that may threaten operations.

Having an airtight IR plan is essential to remaining compliant with the Defense Federal Acquisition Regulation Supplement (DFARS). Defense contractors, in particular, should comply with the DFARS 252.204-7012 clause, which outlines how controlled unclassified information (CUI) must be protected. Should there be a security breach, the DFARS also specifies the steps for reporting the incident.

How Can You Implement a Proactive Incident Response Plan?

A reactive incident response means taking action once an incident occurs, which tends to be disorganized and ineffective. By contrast, a proactive incident response entails having a clear, step-by-step guide that can be followed in case of any eventuality. 

Here’s what every organization must know about maintaining a proactive IR plan to remain DFARS-compliant.

Run Mock Incidents and Test Current Plans

An IR plan should consist of a list of primary and secondary contact persons who can be notified in case of an incident. They should be responsible for running mock incidents and testing the effectiveness of the organization’s current plan, as well as training employees’ preparedness for breaches and similar occurrences. 

Mock tests and training programs must be reviewed for effectiveness; specifically, they must be designed to identify mistakes and/or gaps in the IR plan that may prolong or worsen incidents. A faulty and/or ineffective response plan must then be tweaked immediately. Moreover, contractors should obtain as much data from tests as possible to improve organizational preparedness.

Responding to a network security breach incident requires organizations to have a process that is repeatable and therefore easy to follow. This can be done by assigning concrete duties to key individuals, having open lines of communication, and ensuring incident response policies are up to date.

Create a Reliable Incident Response Team

An incident response team (IR team) will be responsible for implementing and enhancing your IR plan. Their tasks will also involve gathering, preserving, and evaluating data relevant to any incident. In reporting a cyber incident, they will need to work with communications experts and lawyers who will ensure that legal obligations are met.

The IR team also needs to be aware of all the items that need to be included in a DFARS cyber incident report. These include basic information such as company name, company point of contact information, and date of the incident. A report must also list detailed information regarding the incident, including the location and type of compromise, the systems involved, the technique used in the cyber incident, and the like.

Ideally, the IR team should be composed of key IT staff, executives, PR relations and media officers, and other relevant experts — an entire group that could deal with issues from all levels for fast and widespread resolution. 

Perform a Gap Assessment

A gap assessment helps determine whether your organization is compliant with DFARS 252.204-7012. An incident response team must work with DFARS compliance experts who can determine the gaps in the organization’s security posture, fill in those gaps, and help maintain compliance.

Related reading: DFARS 252.204-7012: 14 Control Families You Can’t Afford to Overlook

Report Cyber Incident On Time

DFARS 252.204-7012 requires defense contractors to report cyber incidents within 72 hours of discovering the incident. The Department of Defense, which receives incident reports, requires comprehensive accounts of such events. This may make the process particularly laborious for the IR team who will need some time to gather relevant data to completely understand the nature of the cyberattack.

Being proactive in this regard means having an incident response strategy that streamlines the reporting processes so that in the event of a breach, the right people are alerted immediately. The incident response leaders can, in turn, handle the situation expeditiously and ensure your organization meets the DoD’s notification requirements. 

Any organization requires a solid security program that doesn’t just fend off attacks but also mitigates the consequences of a successful breach. Implementing a proactive IR plan is key to establishing the measures contractors need to take to remain compliant with DFARS and keep their IT systems ready for any cyber incident.

Charles IT is a company of compliance experts that can help you understand the fundamentals of DFARS that are essential to meeting the DoD’s data security requirements. Whether you are maintaining an existing defense contract or planning to acquire one, we are the team to call. Let our experts assess the gaps in your security posture and address your common issues in developing an effective incident response plan — schedule a Gap Assessment today.

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