CMMC program Audit Checklist
Overview
You’ve made it through the previous articles on CMMC and want a simplified checklist to follow along and forward with confidence. Click on the downloadable link at the end of the article for a copy of this checklist.
CMMC Audit Checklist
|
CMMC CHECKLIST |
| 1 – SCOPE |
| ☐ Identify the people, processes, and technology that support your business
☐ Have you identified the data category? ☐ Controlled Unclassified Information (CUI) ☐ Federal Contract Information (FCI) |
| 2 – LEVEL |
| ☐ Identify your CMMC Level based on your data category
☐ Level 1 if you have FCI data ☐ Level 2 if you CUI data ☐ Level 3 if you CUI data and want to demonstrate an expert security program |
| 3 – GAP ANALYSIS |
| ☐ Identify your current documentation posture
☐ Have you specified and properly documented the activities and procedures that make up your company’s control environment? ☐ Do you review documents on a regular basis to make sure they are up to date and accurate? ☐ Identify your current control environment posture ☐ What is the organization’s governance structure? ☐ What are the executive leadership and management tone and example? ☐ Have you designed and implemented hiring and exit procedures? ☐ What are the executive leadership and management tone and example? ☐ How are personnel who are implementing or directing internal controls evaluated for competency? ☐ Are possible threats being identified? ☐ Have you put any mitigating plans in place? ☐ Do you have a protocol for dealing with incidents and a disaster recovery plan in place? ☐ What kind of management supervision and governance do you have in place for your control the environment and reporting events, security problems, and fraud? ☐ Identify your current security environment posture ☐ Do you have access limited to positions that need it, with the appropriateness of the access? given being reviewed on a regular basis? ☐ Do you have policies in place for giving and taking away access from workers, customers, and other parties? ☐ Do you encrypt data while it’s in transit and while it’s at rest? ☐ Do you impose restrictions on administrative access to the technological stack? ☐ Identify your current risk mitigation environment posture ☐ Have you conducted vulnerability assessments or penetration testing regular basis to detect weaknesses in your environment? ☐ Do you have backup processes in place? ☐ Do you test your disaster recovery procedures on a yearly basis to guarantee that you can restart operations in case of a calamity? ☐ Do you regularly check for intrusion attempts, system performance, and availability? ☐ Identify your current system changes environment posture ☐ Are system modifications tested and authorized before they are implemented? ☐ Do you inform your employees about system changes? ☐ Are your controls being monitored on a regular basis? ☐ Have you enabled notification of settings changes? ☐ Is your technology up to date in terms of upgrades? ☐ Do you have a system in place for separating development and production tasks? ☐ Identify your current remote working environment posture ☐ Is technology being used uniformly across all employee locations? ☐ Do you provide staff with regular security awareness training, address data privacy in common spaces, use secure connections while working from home, and raise awareness of phishing attempts? ☐ Do you use multifactor authentication to get into your company’s network and other systems? ☐ Have you deployed mobile device management to make sure that mobile devices are encrypted and authenticated? |
| 4 – CONTROL IMPLEMENTATION |
| ☐ Design the controls to address your gaps
☐ Implement controls to address your gaps ☐ Test the controls to ensure that they are operating effectively. |
| 5 – SELF-ATTEST OR AUDIT READY |
| ☐ Self -attest through TrustCloud
☐ Identify the auditor ☐ Grant them access to TrustCloud ☐ Self-Attest via TrustCloud ☐ Third-party audit ☐ Identify the auditor ☐ Initiate kickoff to set expectations ☐ Grant them access to TrustCloud |
| 6 – MAINTENANCE |
| ☐ Maintain the program to show continuous compliance via TC integrations |
