Bad Ragaz - Original Sin

It always comes down to the humans. Even with the best security, the tiniest friction can cause all systems fail. That 2% of DNA separating us from chimpanzees really messes with your cyber hygiene.

If you want security you need to focus on the biggest attack vector: people.

The Cybersecurity Maturity Model Certification (CMMC) program revolves around a national awareness and training program to increase the validity and reliability of the cybersecurity hygiene for the Defense Industrial Base (DIB).

Relying on self-assessments hurts the overall validity of an organization’s cyber hygiene, due to the scoring system for determining compliance. In NIST-SP-800-171 nor 171a, the methodology describes a scoring scheme. That model of having 110 points, and subtracting either 1, 3, or five points, came from the Defense Contracting Management Agency (DCMA). It did not work.

Relying on self-assessments hurt the overall reliability of knowing if someone had achieved adequate compliance against NIST-SP-800-171. A lot of revenue depends on contracts from the Department of Defense that carry the 7012 clause. Many companies lacked experience or have had past success with a business development strategy of ignoring Department Defense mandates .

We use the amount of data exfiltration from small manufacturers as proof of the failure. The daily ransomware attacks DIB companies face is further observable evidence that self-assessment does not work.

CMMC requires us to realize cybersecurity isn’t just everyone’s job. Cybersecurity IS everyone. You must control your story, data, and identity. The people matter.

In fact, the CMMC model requires an Awareness and Training Policy for Level Two (and thus Level Three, given the cumulative nature of the model):


Establish a policy that includes Awareness and Training.

So how do you build an Awareness and Training policy? You need to understand what people need to know, when they need to know it, and how you will prove they know it. This begins, like all learning, by definining key terms.

What is Awareness?

I can understand the dangers of swimming in riptides in the absence of the training to escape one. All employees must have an awareness of the threats your company faces.

In fact NIST SP 500-172, defines awareness as

sensitivity to the threats and vulnerabilities of computer systems and the recognition of the need to protect data, information, and the means of processing them

However, awareness—like swimming—does not equal training. In terms of cybersecurity, a company needs to have a general understanding of threats and cyber hygiene in order for it to grow. So, for example, while I may hang Controlled Unclassified Information (CUI) posters in the enclave to keep people aware of company policies, that does not equal a training program on selecting the correct shredder for the destruction of paper-based CUI.

You may publish many of your policies in an employee handbook to make them aware of security issues. But you still need to train employees on how to execute these policies.

What is Training?

Awareness focuses on what, while training focuses on why and how. Training will take longer, and you as the learner will need to generate observable evidence of knowledge growth.

What Type of Awareness Programs do my Employees Need?

Based on the NIST 800-171a assessment objectives included in CMMC, you have to have an overall awareness of the threats CUI faces. All employees need an awareness of policies, standards, and procedures. This is often best covered in the Employee Handbook and Acceptable Use Policies.

Your technical staff will need to understand the security risks associated with their activities to keep data safe. This, again, will require the development of Operating System awareness, and you may need to run multiple awareness programs for each major and minor technical system.

Managers and system administrators need awareness of the applicable policies, standards, and procedures related to the security of the systems they oversee. This will include reference documents, a required tour of a wiki or database, and Security Technical Implementation Guides (STIGs).

Some Awareness and Training requirements kick in at Level Two when we talk Cybersecurity Maturity Model Certification (CMMC):


Ensure that managers, systems administrators, and users of organizational systems are made aware of the security risks associated with their activities, and of the applicable policies, standards, and procedures related to the security of those systems.


Determine if:

  • [a] security risks associated with organizational activities involving CUI are identified;
  • [b] policies, standards, and procedures related to the security of the system are identified;
  • [c] managers, systems administrators, and users of the system are made aware of the security risks associated with their activities; and
  • [d] managers, systems administrators, and users of the system are made aware of the applicable policies, standards, and procedures related to the security of the system.

To meet the assessment objectives of this practice you will need to provide multiple types of security awareness and training programs

What type of Training Program Do My Employees Need

Based on the NIST 800-171a assessment objectives included in CMMC, you have to have three domains of training. One domain is focused on your CUI policy, another on threat analysis, and another on your system, security, and roles.

CMMC has an entire set of objectives on developing and deploying a CUI policy. In your training, you need to ensure your managers and technical systems engineers, or Managed Service Providers (MSPs), know how CUI is protected on your system.

Your training around applicable policies, standards, and procedures related to the security of the system will need extensive documentation, and will include recognizing educational certificates and providing your own training related to your reference architecture.

For example, take AT.2.057, which requires contractors to “ensure that personnel are trained to carry out their assigned information security-related duties and responsibilities. ” This will require operating system training specific to a company’s reference architecture. You will rely on different certificate programs to ensure your technical staff can stay current as technology changes. You will need multiple trainings for each of the operating systems deployed on your major and minor systems that store, transmit, destroy, or create CUI as the result of a government contract.

What is the Purpose of my Awareness and Training Policy?

The first objective of AT.2.999 establishes a policy that includes Awareness and Training, which requires you to have a purpose to your awareness and training policy. For Level Three certification, you need a mission and strategic goals. AT.3.997 requires contractors to “establish, maintain, and resource a plan that includes Awareness and Training” objectives b and c.

We recommend you do this on company-wide scale, via a threat awareness and training program. Explore the threats, external and internal, you face. Analyze risks to your business and supply chain.

Break employees into groups and have them draft threat analysis documents (this is a Level Four requirement, but wise to implement ahead of time). Then when you have a complete list of threats, have the groups craft mission and goal statements.

You then work with the groups in a whole company setting to ensure your employees draft the kind of comprehensive policy statement you envision. Ownership builds awareness.

Many mature and large organizations will have awareness and training policies developed. If this is the case for your organization, you should still conduct ongoing threat analysis discussions at the department level.

At the end of the day, make sure folks are aware.

Who needs Awareness and Training?

Everyone. Awareness and training ensure policies and procedures become company culture. However, it is important to note that your managers, sales staff, and security engineers need different awareness and training.

NIST Special Publication 800-16, “Information Technology Security Training Requirements,” recommends creating a role-based training matrix. You can combine this approach with CMMC requirements to create a full curriculum scope and sequence for your awareness and training program.

In the first column of the Matrix, list all the user roles on your information systems. Include a row for “all.” You can group trainees by their roles as well.

Then create four domains in your awareness and training program:

  • Employee Responsibilities,
  • Information System Policies,
  • CUI
  • Reference Architecture

What kind of training an employee receives, and in which domain, depends on their role. For example, all employees may have to watch a training and certify they read the Employee Handbook and Acceptable Use Policies. You probably want a training on the email rules of your company for all employees.

For Level Three CMMC Certification, you need to document what will be learned. In fact, Assessment Objective [e] of AT.3.997 requires you to document “the plan documents, activities, and due dates.” In your matrices, be sure to list the trainings, in addition to when due dates occur.

Fill out the chart indicating when role-based awareness and training occurs, what it includes, and how it is assessed.

Large companies may have an internal learning management system that may track many of these metrics. Smaller companies may have to contract with a vendor. If you purchase IT or security products from MSPs or vendors, try to negotiate a training package, or choose those you see as compliance partners.

What should Awareness and Training Cover?

Employee Responsibilities

You need to cover the four domains of knowledge, but now you must also develop the scope of learning objectives and the sequence of training for the matrices.

First begin with employee responsibilities by examining the everyday system-wide awareness and trainings all employees must receive. This includes the employee handbook, sexual harassment, legal compliance, company wide posters, CUI handling posters, and stickers. These are everyday business practices that require awareness and training.

Then decide which of these policies need more than awareness and actual training. This could include a short video summarizing the employee handbook with a quiz. Employees often have to attend mandatory trainings with a supervisor.

Once you have the list, decide if the subject requires awareness or training. Add it to the matrix.

Controlled Unclassified Information

As noted above, you must include awareness and training on the “security risks associated with organizational activities involving CUI are identified.” In other words, you need to develop a CUI Training Program.

At Level Two of the CMMC, your company will need awareness and training on the internal threats faced by companies who have a legal right to handle Control Unclassified Information on behalf of a government contract.

At Levels Two and Three, your awareness and training program must include your company policies on receiving, creating, labeling, disseminating, transmitting, storing, and destroying CUI. This policy should cover the specific workflows for handling this information. You will also need to include your Incident Response Training on handing CUI data spillage.

At Level Four, your CUI awareness and training program should include recognizing and responding to threats from social engineering that can lead to advanced persistent threat actors, breaches, and suspicious behaviors; you will be required to update the training at least annually, as well as when there are significant changes to relevant threats.

Information System Policies

Then you will have company-wide information system policies, such as your password policy, email policy, device policy, how Multifactor Authentification works (please turn on MFA), et cetera.

These Information System Policies apply to all employees, however, at this point you may have to start specializing. The account generation for your Mobile Device Management tools may vary from your payroll system. In fact, at this level you will start to specialize at the Operating System level.

Different types of operating systems will require you to verify employee training through different certificates. If you deploy in Kubernetes in Azure or use S3 in WS Govcloud, each of those stacks has individual Security Technical Implementation Guides (STIGs) and certification programs.

You must consider all the major and minor systems, the data that flows through them, and the laws and regulations that govern how that data is used and shared.

As a contractor, you also will need to consider trainings on your acquisition team on what kind of service level agreements you need in your vendor agreements with regards to information and technology systems. Trainings need to include examining vendor agreements and SLAs to determine if proposed security solutions meet CMMC Level Three standards.

Reference Architecture

As Tom Cornelius from Compliance Forge notes, “You must see policy as a blueprint and not documentation. You are more an archtiect than a writer.”

As an organization, you will need solid reference architecture on how you build secure systems that can handle a moderate baseline for the protection of Controlled Unclassified Information. You will have a set of documents that describe how to build the ideal environment for your use case. You will need awareness and training on how to use and update your reference architecture.

Take configuration management for example. If you do not have a clear configuration management documentation and provide baseline training on using the necessary references, you will not have the basics of Access Control, the root of cybersecurity.

Next, you can turn to the other domains in CMMC to determine the specifics of company-wide training policies.

What other Domains Should Awareness and Training Cover?

The Awareness and Training you provide must go well beyond the practices and process of the AT domain. In fact, according to Native Intelligence in a blog post on Amira Armond’s CMMC Audit, Awareness and Training needs to cover fourteen additional practices across five domains

  • Access Control (AC)
  • Media Protection (MP)
  • Maintenance (MA)
  • Physical Protection (PE)
  • Systems and Communications Protection (SC)

How to Get Started on an Awareness and Training Plan

Create an Instructional Leadership Team

You first begin by designating who owns your awareness and training program. The Instructional Leadership Team should contain stakeholders across the organization and not just from IT or your security team (if you even have either position. The team could include your Information System Security Officer, CIO, CTO, information System Security Manager, human resources, facility security officer, or employees designated to serve on the instructional leadership team.)

Craft Goals, Missions, and Objectives

Your instructional Leadership Team then crafts your goals mission and objectives. This begins by a walkthrough through of your threat environment. Understand the common threats to the sensitive data you hold.

You can have very generic goals, missions, and objectives for your trainings. You may want to consider utilizing the awareness and training domain to strengthen your talent across the board. However, you only need to track system security related training with CMMC.

Determine Roles for Awareness and Training

Next, the Instructional Leadership Team determines roles and responsibilities. Christina Reynolds of BDO-USA recommends using the RAC model: who is Responsible, who is Accountable, and who need to be Consulted. The goal is to create observable evidence that partially meets assessment objectives c, d, and g of AT.2.999

” the roles and responsibilities of the activities covered by this policy are defined; (i.e., the responsibility, authority, and ownership of Awareness and Training activities);”

“The policy establishes or directs the establishment of procedures to carry out and meet the intent of the policy;”

“the policy is endorsed by management and disseminated to appropriate stakeholders; and “

So you develop a matrix of roles and responsibilities. Include general users, data owners, system owners, and members of the Instructional Leadership Team. Make a column for each.

Then, in the rows include who must complete training, who develops the training program, who agrees to acceptable use policies, who decides which roles get what training, who completes role based training, and who is responsible for record keeping.

Establish Company-wide Baselines

Now, decide what basic training every employee must have. This will include your awareness activities, employee handbooks, email policies, acceptable use policies, etc. You may include optional training on overall threat awareness and common attack vectors, such as phishing.

The goal is to establish the bare minimum of security awareness you want with your employees. This wil usually include a variety of trainings like company wide meetings, video on-demands, or online learning.

Develop A Training Matrix

Now that you have a baseline of security awareness and training you want for employees, you next decide on specialized roles, and create a role-based training matrix. People in specialized roles and management positions will need additional training over and beyond what every employee recieves.

You need to group people into roles based on functions in the workplace.

Then create a list of topics, which includes items such as:

  • CUI
  • Email
  • Threat Awareness
  • Media Protection
  • Passwords
  • Mobile Devices
  • Access Control Policy
  • Reference Architecture
  • Crafting Service Level Agreements
  • etc

You then decide based on the number of roles created by your Instructional Leadership Team which group gets what training.

Develop Company Wide Awareness and Training Rubric

Next the Instructional Leadership Team needs to define success metrics for your awareness and training program. In terms of CMMC, it is important to know if a plan really does not kick in until Level Four process requirements, but you cannot have a compliant training program at this Level without evidence of learning gains.

The evidence of awareness and training success, like all compliance data, can fall into one of three categories: interview, observe and test.

First, you want to understand if your awareness and trainign impacts your operational security. Indicators could include reduction in down time, increased phishing test success rates, and incident reporting. If you can not automate these metrics, you can have the Instructional Leadership Team rate them on a four point likert scale.

You also have training program metrics, such as the frequency of training programs, learner performance, attendance, and learner feedback. You should check with your state on the requirements to protect and retain employee training data.

Evaluate Content

Now you have to choose content that will align your role based matrices with your required learning matrices. It will probably be cheaper to purchase curriculum than to develop it in-house. However, when you pay for an instructional designer to develop your program, you can align the program to your company culture and workflow.

The majority of cybersecurity training is video-based garbage designed to allow you to check off a compliance box about providing training. Develop or utilize a rubric for evaluating curriculum. You may consider hiring a consultant to help you evalaute curriculum. At the very least, choose your networks from word of mouth.

Create Deployment and Evaluation Schedule

Next, you must create a scope and sequence guide for your curriuclum. This document includes the objectives of your chosen curriculum, how those objectives will be measured, when the curriculum will be delivered, and who will evaluate the result. You can include information about awareness and training.

For awareness, you could include the posters you hang and monthly security reminders that are delivered by email. The awareness program occurs all the time, and for all users.

For training, this again will be a role-based document. Many people may end up including the role-based matrix in the scope and sequence of the curriculum.

Craft Awareness and Training Plan Compliance Documentation

Finally, you will need to create a way to document your awareness and training program, so you organize observable evidence in a way that would not require a CMMC assors to make any inferences about your program. Spell out how you meet each requirement in your Policy, Procedures and Plans. If you followed the path above, you will have the majority of the required documentation already.

Now, as your goal you must include the procedures you have decided upon for your Awareness and Training Policy, in addition to how you plan to include the metrics from your Awareness and Training in both your System Security Plan (SSP) and your Awareness and Training Plan.

Create a policy for retaining security training records. Create the procedures to make sure this happens.

Include a table in your policy that explicitly addresses all of the required Awareness and Rraining in a practice or assessment objective. Then, in your SSP, reference this policy and include two pieces of observable evidence that the assessment objectives have been met.

For example, you need to include training of internal threats at Level Two of CMMC. This means that for Level Three compliance, you must demonstrate you provide this training. Explicitly spell this out, in addition to any required training in your Awareness and training Policy and Procedures.

For many companies, beginning with the Awaress and Training domain may provide a great launching point for your CMMC journey.

Meet CMMC Compliance through Awareness and Training

Can you complete your SSP as you utilize and also reach compliance on the Awareness and Training domain? Would this approach lead to increased hygiene?

Everyone frets over CMMC devolving into a checklist of policy and confusing technical controls. Awareness and Training makes this difference.

Christina Reynolds co-authored this post in the guidance she provided in how to craft Awareness and Training Policy

Featured Image: “Bad Ragaz - Original Sin” by Kecko is licensed under CC BY