CMMC and ISO 9001 Synergies

What does compliance with CMMC or other cybersecurity requirements have to do with ISO 9001? A lot.

Compliance with CMMC requires organizations to have mature business processes and procedures to address and document things like:

• Configuration Management systems to establish and maintain baseline configurations and inventories of organizational systems (CM.L2-3.4.1)
• Processes to create and retain system audit logs to monitor, analyze, investigate and report unauthorized system activity (AU.L2-3.3.1)
• Develop and implement plans of action to correct deficiencies and reduce vulnerabilities (CA.L2-3.12.2) on a regular cadence
• Keep updated compliance records such as documentation of required role based training to ensure that personnel are trained to carry out their assigned information security-related duties and responsibilities. (AT.L2-3.2.2)
• Maintain asset Inventories, authorized access lists, and employee screening records

And there are more. Without a systematic way to create, review, approve, and consistently update this documentation, managing compliance overhead becomes difficult at best. This is where ISO-9001 comes in.

ISO-9001's systematic process methodology provides a robust framework for implementing CMMC cybersecurity requirements and being prepared for assessment and annual reporting. By treating security as an integrated business process, companies need to create a comprehensive management system that addresses both quality and protection of controlled unclassified information (CUI).

The Plan-Do-Check-Act (PDCA) framework from ISO-9001 aligns perfectly with CMMC's requirement for ongoing cybersecurity assessment and enhancement. This iterative approach enables organizations to:

• Systematically manage emerging security threats
• Adapt cybersecurity practices incrementally
• Maintain alignment with organizational quality objectives

Conventional wisdom in CMMC, ISO 27001, and other cybersecurity frameworks suggests starting with an asset inventory, mapping the flow of sensitive information like CUI through the organization, and developing a network architecture. However, this is the wrong place to start. The first step in creating a credible cybersecurity program that will pass an assessment is to establish and institutionalize a Quality Management System.

A Quality Management System is critical for efficiently implementing any type of major effort within an organization. ISO-9001 provides a framework for doing that. So, the first step I recommend to organizations seeking CMMC compliance is to review their ISO-9001 documentation to identify steps they are already taking that overlap with CMMC requirements and to ensure that their business processes are ready for CMMC.

What if an organization is not ISO-9001 certified? Now might be a good time. Is it required? No. But, If nothing else, documenting a systematic process to create, review, approve, and consistently update critical compliance documentation is essential.