The Difference Between Policies, Plans, and Procedures in CMMC

Data security is an essential component of any organization's overall operations—and if you are part of a Defense Industrial Base (DIB) organization or work in sectors like finance, real estate, or law, understanding CMMC compliance requirements may be particularly important for your business.

One crucial aspect of CMMC compliance is understanding the difference between policies, plans, and procedures. These three terms are often used interchangeably, but they each serve distinct purposes in ensuring data security. In this article, we will take a closer look at what sets these components apart from one another and why they're important.

Basics of CMMC

Cybersecurity Maturity Model Certification (CMMC) 2.0 is a framework designed to enhance the cybersecurity practices of organizations within the DIB and other commercial sectors. Its objective is to protect sensitive government information by setting a unified standard for implementing cybersecurity practices.

This requires contractors and subcontractors to meet different CMMC compliance requirements depending on their level, which is based on the type of sensitive data they handle. The certification process involves an assessment conducted by certified third-party assessors, who evaluate policies, plans, and procedures related to data security.

CMMC Policies

What Are Policies?

Policies are high-level statements of intent that outline objectives, rules, and guidelines governing specific activities within an organization. They serve as a framework, establishing the overarching principles that dictate the direction and priorities of an organization, and can be heavily shaped by CMMC compliance requirements.

Purpose of Policies

The primary purpose of a policy is to provide the why behind actions and decisions. It sets the stage for what needs to be done and why it is essential for the organization's security and compliance.

Attributes of Policies

  • High-Level Statement: Broad and general, providing a vision.

  • Less Flexible: Provides guidelines that are rigid and less prone to change.

  • Requires Higher-Level Authorization: Typically approved by senior management.

  • Infrequent Updates: Policies are updated less frequently compared to procedures.

Examples of Policies

  • Access Control Policy: Governs who has access to what information.

  • Incident Management Policy: Defines how to manage and respond to security incidents.

  • Risk Management Policy: Outlines how risks are identified, assessed, and mitigated.

CMMC Plans

What Are Plans?

Plans are detailed proposals that outline the steps needed to achieve specific objectives. They translate the guidelines laid out in policies into actionable roadmaps.

Purpose of Plans

The primary purpose of a plan is to outline the who and the what. It takes the high-level objectives from policies and maps out who will carry out specific actions and what resources are needed.

Attributes of Plans

  • Detailed Roadmap: Specifies actions, timelines, and responsibilities.

  • Moderate Flexibility: Allows for some adjustments as needed.

  • Requires Approval: Generally requires approval, but at a lower level than policies.

  • Periodic Updates: Plans may be updated more regularly to adapt to new information or changing circumstances.

Examples of Plans

  • Disaster Recovery Plan: Details steps to recover data and resume operations after a disaster.

  • Incident Response Plan: Outlines how to respond to and manage security incidents.

  • Risk Management Plan: Describes processes for identifying and mitigating risks.

CMMC Procedures 

What Are Procedures?

Procedures are specific, step-by-step instructions for executing tasks or operations. They provide the how in the implementation process. These steps are generally not specifically outlined by CMMC compliance requirements, but they are an important part of reaching the broader goals involved.

Purpose of Procedures

The primary purpose of a procedure is to offer detailed instructions on how to perform specific tasks. These guidelines ensure consistency and compliance with the plans and policies.

Attributes of Procedures

  • Step-by-Step Instructions: Highly detailed and specific.

  • High Flexibility: Allows for variations based on the task at hand.

  • Requires Lower-Level Authorization: Generally approved at lower management levels.

  • Frequent Updates: Procedures are updated regularly to reflect changes in processes or technology.

Examples of Procedures

  • Administrative & Security Procedures: Specific steps for managing administrative tasks and ensuring security.

  • Data Backup Procedures: Step-by-step instructions for backing up and restoring data.

  • Incident Response Procedures: Detailed guidelines for handling specific types of security incidents.

Putting It All Together

Understanding these distinct roles are essential because they ensure a structured approach to cybersecurity within an organization. By clearly differentiating between policies, plans, and procedures, organizations can create a coherent and comprehensive cybersecurity framework that meets CMMC compliance requirements effectively.

Policies establish overarching expectations, while plans turn these directives into actionable steps and allocated resources, clarifying responsibilities. Procedures provide the details needed to execute the plans consistently and accurately. In other words, policies provide the foundational why, plans outline the who and the what, and procedures describe the how.

Prioritize Compliance with TechAxia

Navigating the complexities of CMMC 2.0 can be challenging, but understanding the difference between policies, plans, and procedures is a significant first step. By implementing these elements effectively, your organization can achieve better security, compliance, and operational efficiency.

Working with a knowledgeable partner like TechAxia can help your organization seamlessly integrate these elements into your cybersecurity strategy. TechAxia specializes in CMMC compliance requirements and can help you prepare for certification and maintain compliance.

To get started on enhancing your cybersecurity practices and compliance, contact TechAxia today.

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