Raj Ananthanpillai is the chief executive officer of IDentrix.
There are major changes on the horizon for government contractors working with the Defense Department.
By the end of November, the new DSS NISPOM Conforming Change 2 will impact DOD contractors who must have a written program in place to establish an insider threat program. These programs must be able to deter, detect and mitigate insider threats before they can become a risk to classified information.
These changes stem from growing concerns over insider threats in recent years because of a number of high-profile incidents. Malicious insiders are a top security threat for federal agencies. For security professionals monitoring cleared personnel, changes in life circumstances can signal alerts that a potential threat could be looming.
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The government once operated in a “trust but verify” mode, yet that posture has led to damaging security breaches. Whether an insider poses a cyber, physical or workforce threat, we’re living in a “no trust” environment.
Agencies began to proactively thwart insider threats because of a large number of incidents that would have been prevented if the right monitoring tools were in place. For example, a recent Deloitte report noted 92 percent of insider threat cases surfaced after a negative work event, such as a dispute with a supervisor or a termination. In those instances, the right continuous risk monitoring program could have caught possible malicious activity before it damaged the organization.
This is one example of why DOD is requiring contractors to put an insider threat program in place, so nefarious actors can be identified before it’s too late. While implementing a program will provide untold benefits to agencies and contractors, it can also seem daunting to get up and running.
To help simplify the process, here are three steps contractors can take to create the necessary insider threat program that will keep your company—and federal agencies—secure.
1. Know What the Requirements State.
Before you develop an insider threat program, it’s important to make sure it addresses the requirements outlined by the DSS NISPOM Conforming Change 2. The 13 monitoring guidelines as specified in the Defense Security Service Industrial Security Letter include: allegiance to the U.S., foreign influence, foreign preference, sexual behavior, personal conduct, financial considerations, alcohol consumption, drug involvement, emotional, mental, and personality disorders, criminal conduct, security violations, outside activities and misuse of information technology systems. Keeping these guidelines in mind is critical to creating a program that can gather, integrate and report relevant and credible information in a timely way.
For many companies, those who monitor or staff internal security programs can get inundated with false alarms and too many alerts. Contractors should focus on developing a program that will alert them to only credible threats to investigate further without wasting time on low-risk events. Complying with the requirements will ensure contractors remain in good standing with DOD and avoid losing their facility clearance which would in all likelihood mean losing their government contracts.
2. Decide What Matters to You.
To get the most out of the program, contractors need to decide what features or capabilities would be most useful to them. A focus on customizable personnel risk alerts may be the most important aspect of a decision. The company can choose which type of alerts to evaluate, ensuring online information that could predict a security risk is evaluated.
By taking the time to create a program designed specifically for your needs, you can ensure you’re getting the value out of your investment.
This stage in the program implementation is also a good time to discuss budget and make sure the significance of the program is understood. With input and agreement from executives, your IT team can plan and implement a robust insider threat program.
3. Determine the Right Vendor.
After spending the time to review the requirements and determining what solution is best for your organization, consider your budget and implementation needs. At this point, it may be tempting to try to create a program in-house to save on budgeting. But this can lead to a number of challenges, including taking the risk of not meeting the standards outlined by DOD.
Going with an outside resource that has a history of developing insider threat programs can more readily create a program that’s best for you. One of the biggest advances in insider threat detection is continuous risk monitoring, which analyzes publicly available data in real-time and alerts your organization when the risk status of an employee has changed.
For example, an employee who has been arrested may not self-report but a continuous risk monitoring solution will alert managers of that arrest in near-real-time. As most DOD contractors do not have real-time monitoring currently available and are required to conduct periodic reinvestigations of employee backgrounds every five to 10 years, they are assuming risk. Supplementing in-house tools and practices with outside vendors can balance that risk and create a fully functioning and robust program.
While creating an insider threat program can seem like a difficult challenge, it can be addressed step by step. With new requirements and guidance in place, the time has come for contractors to meet the challenge head on. By focusing on requirements and outlining a plan, contractors can readily achieve their goals by creating an insider threat program by the Nov. 30 deadline.