What is Security Protection Data and Assets?
Climbing Mount CMMCMarch 28, 2024x
19
00:29:1120.08 MB

What is Security Protection Data and Assets?

(Season One Episode 19) We are joined by Karen Stanford to discuss the controversy of defining Security Protection Data. This is an honesty-based episode, and we don't hold back. Let's dive in! As a seasoned cybersecurity professional with over 20 years of experience, Karen has a proven track record of delivering high-quality consulting services to both commercial and federal clients, especially in the field of cloud computing. Karen is the President and Founder of Archstone Security, LLC, a...

(Season One Episode 19) We are joined by Karen Stanford to discuss the controversy of defining Security Protection Data. This is an honesty-based episode, and we don't hold back. Let's dive in!

As a seasoned cybersecurity professional with over 20 years of experience, Karen has a proven track record of delivering high-quality consulting services to both commercial and federal clients, especially in the field of cloud computing. Karen is the President and Founder of Archstone Security, LLC, a company that she launched in 2022, to help organizations achieve and maintain compliance with the most stringent standards, such as FedRAMP, FISMA, and NIST.

Website: https://www.axiom.tech/
YouTube: https://www.youtube.com/channel/UCaJagoDasNG3MqLqw2Af_ZQ

Axiom's Linkedln: https://www.linkedin.com/company/axiomtech/

Bobby's Linkedln: https://www.linkedin.com/in/bobbyguerra/

Kaleigh's Linkedln: https://www.linkedin.com/in/kaleigh-floyd-079a52190/

[00:00:00] Welcome back climbers, I'm your co-host Kaley Floyd and this is another episode of Climbing Mount CMMC.

[00:00:11] In today's episode we're joined by Karen Stanford. Karen is a seasoned cybersecurity professional with over 20 years of experience.

[00:00:19] She is the president and founder of Arstom Security and she also has the CMMC Provisional Assessor Certification.

[00:00:27] She has extensive knowledge on conducting Fed Ram assessments and we are so excited to dive into the topic.

[00:00:33] What is security protection data and assets? So without further ado let's get into today's episode.

[00:00:41] Karen let me first start off by saying like you know what's kind of controversial when it comes

[00:00:46] to security protection data and what is it? Sure so I think it's you know in general it is the

[00:00:52] announcement that this is going to extend you know the boundary what they have recently decided is that

[00:00:59] your CMMC boundary needs to include security protection data even if it's not within your environment.

[00:01:04] So this would mean that if you are doing monitoring with a third party security operation center and

[00:01:10] you are porting all of your data over to their data center that their data center is now in the CMMC

[00:01:17] boundary and needs to be subject to the same requirement so your choices would be either to work with

[00:01:22] a security operation center that has an existing CMMC accreditation or a practice Fed Ram

[00:01:29] and or they need to get accredited themselves. So that is it's you know a lot of organizations in

[00:01:38] the DIP currently relied on managed service providers to help them do what they don't know how to do

[00:01:44] and so this is bad news for all of them and that it is now extending the boundary into their environment

[00:01:48] and they might need to be accredited. So a lot of the wisdom I think that people were thinking about

[00:01:53] is okay I'm going to get into CMMC right and when I get into CMMC I can start using other partners

[00:01:59] or vendors and as long as they're not specifically completing controls that involve collecting

[00:02:10] CUE they can they can they can participate and help like a sock like you're saying so they can

[00:02:16] look at your sim and those types of stuff but once they put this security protection data label

[00:02:21] on that type of data as they ingest it now they have a responsibility which I think is what

[00:02:28] everybody's kind of getting pretty up in arms about. Yeah there's definitely some concern so

[00:02:33] so this isn't a surprising move for me in that that occurred for FedRAM already and the concern

[00:02:41] from the parts of the Fed so that some of the data that is being exported has great interest to

[00:02:48] adversaries you know if you are ingesting audit data if you are managed service provider and

[00:02:53] you're ingesting audit data for a CMMC environment that shows that FTPs enabled on a host

[00:02:59] that's public facing then that and you know what people are going to have interest in that data

[00:03:03] it can be used to exploit the system so that's the concern. So let's first kind of talk about

[00:03:09] what security protection data is from the perspective of FedRAM because that's all we have to go on

[00:03:14] at this point we're assuming we're going to model after FedRAM so that's typically going to be any

[00:03:19] audit or event data and then you're also going to have any vulnerability scanning data if you're

[00:03:26] using vulnerability scanning as a service and that your data is living in their environment then

[00:03:31] that's going to extend the boundary into their environment under this new you know interpretation of

[00:03:35] the guidance. So do you feel that I mean that that is going to be a bit of the lens

[00:03:42] that that DOD is going to look through when they're talking about this through FedRAMP and

[00:03:46] their experience and utilization of how they did it there? I think so you know I think that the

[00:03:52] risk is the same for both you know it's that there is this is security related data that shows

[00:03:57] security vulnerabilities and it's not in a protected environment so I do think that will be how

[00:04:04] they do it for me it's a bit of a you know a bit of a disappointment in that you can you know

[00:04:11] you're going to get more effective monitoring from someone who does it for a living then being

[00:04:15] concerned about your boundary extending into those additional networks and then opting to keep

[00:04:21] it in house where you don't know what you're doing. There's kind of a trade-off but I do understand

[00:04:28] the risk that the federal you know the federal entities are trying to address with this. Yeah I agree

[00:04:33] it definitely makes sense but if I look correctly from wrong through 8171 and 171A and I look at the

[00:04:44] NARA I don't see anything about security protection data until the proposed rule dropped and then

[00:04:51] you know all of a sudden here's this thing that they're talking about it makes sense but boy did

[00:04:55] it seem like a right cross out of nowhere. It did I think especially for anyone who was not

[00:05:01] you know in the FedRAMP space where it was a big bomb dropped on to just a few years earlier so

[00:05:10] but I think the security protection data I think initially the intent was to about for FedRAMP

[00:05:16] you need to assess everything. You need to assess your Linux servers, you need to assess your

[00:05:22] Windows servers, you need to assess your network devices it's sorry you have to do the whole

[00:05:26] full control set for all of them and I think that's the you know I don't know for sure but it seems

[00:05:31] to me that the intent of creating the term security protection asset for CMMC was to say you don't

[00:05:36] need to do all of that you don't need to test all of the controls for the 8171 for your firewall you

[00:05:42] need to test you know only specific controls related to it but unfortunately I think that that

[00:05:49] is it's just kind of a runaway train at this point with people using you know what I'm seeing is

[00:05:55] people are trying to designate something as security a security protection asset so they can kind

[00:05:59] of remove it from the boundary so I'm not you know I'm not a fan of the term but I understand

[00:06:07] yeah so just to make sure those people are listening that aren't 100% in the know about this is

[00:06:13] that Kui right controlled unclassified information and security protection data they're not the same

[00:06:20] thing but there's this fear that it's going to start to become possibly the same thing but it has

[00:06:27] been utilized by the ruling and no uncertain terms as a mechanism to loop in maintenance service

[00:06:34] providers like myself so because you know maintenance service providers are trying to get in there

[00:06:40] and say okay we'll help with providing services for this company but you know we're only doing certain

[00:06:48] types of things so therefore we don't need to get level two certified ourselves but once that

[00:06:52] security protection data comes into their environment they're going to have to the way that I

[00:06:57] read the rule and if I'm getting wrong please correct me Karen but they're going to pull us in and

[00:07:02] make you know we're gonna have to get level two to match parity with who we're supporting because

[00:07:08] that security protection data is going to make us have to do that. I think that that is the correct

[00:07:15] interpretation and I think there's kind of two ways to look at it if you're a managed service

[00:07:20] provider and you are doing a lot of support for organizations that are attempting to get CMMC accredited

[00:07:27] it could be a differentiator for you to go ahead and get CMMC level two because then everyone can

[00:07:32] use you but as we've learned throughout this process it's not something that's going to happen

[00:07:37] overnight so you know it's a bit of a struggle for managed service providers to figure out what

[00:07:43] to do but one of the I think you know what I'm recommending to folks who are in that boat is

[00:07:50] to attempt to leave whatever the security protection data that they have ingested into their

[00:07:55] environment to try to put that back in your in the into their clients environment so this may

[00:08:01] consist of you know instead of porting all your auditing and monitoring or your log data into a

[00:08:06] security operation center you may want to bring that in house and have your security center

[00:08:10] analysts coming through a virtual desktop into your environment and work with it from there

[00:08:16] now that is not always feasible a lot of the tools that they need to use to conduct analysis are

[00:08:20] not in the environment so overall it's a it's a double-edged sword and that they're trying to

[00:08:26] protect the data which is of interest to adversaries however it is now kind of limiting

[00:08:34] how the Dib can protect itself you know there it's not as easy for them to to fulfill the

[00:08:39] requirements for CMMC and you touched on this Karen and I think it when we were talking earlier

[00:08:45] before we did the recording and and I think it it's definitely worth pausing and really kind of

[00:08:50] covering this a little bit more specifically is this ruling or this proposed rule is going to push

[00:08:57] a lot of people to start trying to keep the data in house and try to manage it themselves when

[00:09:03] they may not necessarily be the best qualified person to do that because of the fact that security

[00:09:09] protection data is so new from the perspective of people who are trying to get involved and get

[00:09:14] aligned for CMMC weren't quite ready for it and so it's a bear in wasteland out there as far as

[00:09:19] an organization that are fed ramp that can handle this type of data and manage service providers or

[00:09:25] MSSPs or other SOC organizations like you said that have those appropriate certifications because right

[00:09:30] now the CMMC certifications aren't happening right now so no one can say I've got it so the only

[00:09:36] other option is what fed ramp and or fed ramp equivalent and so I just kind of want to open the

[00:09:43] box a little bit to however you feel comfortable to talk about like what the risk is of organizations

[00:09:49] now having to feel like they have to keep that data local and then what does trying to go into

[00:09:54] the fed ramp space or try to look for those part or try to you know the equivalency can you

[00:09:59] sort of maybe try to make that mud a little bit clearer for us about that yeah I think one of

[00:10:04] the risks is that most of the fed ramp accredited situate you know software or software

[00:10:11] infrastructure service platform as the services center and most of that is geared towards

[00:10:15] federal technology you know it's designed for office workers who are working with data

[00:10:20] and the defense industrial base tends to do quite a bit of manufacturing so there's a lot of

[00:10:25] programs that are used heavily by the div that are that really don't have any interest in selling

[00:10:30] direct to the government you know so there's going to be my first concern with this

[00:10:36] is that there is not enough there are not enough tools that are certified for the

[00:10:41] div to be able to continue to support defense you know the department of events you know that

[00:10:46] for me is a significant concern it's kind of pulling the plug out cloud in a lot of ways

[00:10:51] you know so that's a that's a significant concern and then also I think it's you know while this

[00:11:00] did occur for fed ramp at some point they were like okay now we want you to start using fed ramp

[00:11:04] accredited you know solutions in your environment but they did that after there was enough

[00:11:10] kind of juice from you know there were some gaps but they didn't really wait to do that until

[00:11:15] there were products that you could use and and that's another concern for me is that there's nobody

[00:11:20] right now nobody can use anything you know there's nothing that's accredited and I don't know how

[00:11:24] that works with the chicken in the egg you know because I don't know that you can get you know

[00:11:29] assessed under the joint if you're a you know you need to have a contract with the with the government

[00:11:34] you need to be a prime or or a sub and a lot of these folks aren't going to be able to do a joint

[00:11:39] surveillance to get accredited for CMMC because they don't have you know the means and so

[00:11:45] there's a lag in being able to implement all of this that I think that nobody's considered

[00:11:50] and I think that's going to cause some problems. Well with with organizations starting to pull stuff

[00:11:55] in just for us because you know we decided last year early last year that we were going to

[00:12:01] go ahead and try to be one of the first over the hill to get level two certified ourselves

[00:12:05] but we made some assumptions about some cloud options that we might have available and once

[00:12:10] we started seeing stuff about security protection data we were like oh man this is not going to work

[00:12:16] you know we had to we started to have to pull some of this stuff in house we started having to look

[00:12:21] for vendors that do allow for hosting options which you know circuit four years ago everybody thought

[00:12:28] was just old school everybody's going cloud nobody's doing that now now with this rule it seems

[00:12:33] like everybody's like okay self-hosting is back on the table again folks and we need to start doing

[00:12:38] that but you know for me it was a challenge about education and trying to make sure that our team

[00:12:44] is ready to handle the requirements because it wasn't something that we were really good custom to

[00:12:49] doing and it's a challenge for us and I can only imagine how it would be for organizations that

[00:12:55] that are trying to do it themselves can you speak to that and how that might either help or

[00:13:00] security yeah so I think that one of the first things that folks are going to need to think through

[00:13:07] is AM well you know with respect to cloud is what I'm using actually a cloud service I think

[00:13:13] that we are seeing some evidence that folks don't really understand that they're like oh my god

[00:13:18] you know I need to have a fed record accreditation you know because I'm you know I have all of my

[00:13:23] whole all of my system components are hosted on a cloud service provider well that doesn't make you

[00:13:28] a cloud service provider you know there's what what you really need to think about is of your client

[00:13:34] stated that could be considered sensitive where does it live and how can I make it to not live

[00:13:39] there so if you are doing vulnerability scanning and right now you are jumping into an environment

[00:13:45] and conducting the scans pulling the data over to your environment and analyzing it just do that in

[00:13:50] their environment that's an easy one that's that's a relatively easy fix but you know it is going

[00:13:55] to be tough the first thing to do is figure out are you cloud if you're attempting to you know

[00:13:59] figure out if you wanted if you need to do veteran are you cloud and then also where does the data

[00:14:04] live and can I make that different so for for us as a manager's provider we're going to be

[00:14:12] having some of those tools that are going to have security protection data in our gcc high

[00:14:17] environment and that will all be part of our assessment when we get assessed ourselves so when

[00:14:21] we get level two certified that will all be included in in our assessment process is that in your

[00:14:27] opinion an option for people to who can still participate without having to go with the whole fed ramp

[00:14:35] process for them yeah absolutely I think that you know absentee ability to immediately become

[00:14:41] accredited which nobody has right now you should just we should prepare for it you know you

[00:14:45] should assume that if you are if your objective is to host data from folks who are going for CNM and

[00:14:51] C level two or level three or whatever is for you to become accredited at that level and to start

[00:14:55] to work towards that end so that's I think the way to go you know with respect to getting prepared

[00:15:03] right now for vendors that may not necessarily be that easy right because they have

[00:15:10] build levels and revs and things that they're trying to track and trying to get a whole product

[00:15:16] line to go through a level two certification but alone fed ramp is not going to necessarily be an

[00:15:22] easy thing for them it's not and what I recommend is for you to understand where that federal data

[00:15:30] that's of concern and this would you know this would you know probably be audit log data any vulnerability

[00:15:36] data you know anything to do with any security state in your in your environment your first thing

[00:15:42] is to understand where that lives and to try to to the extent possible you know to consolidate

[00:15:49] that all into one CUI boundary because some of the managed service providers are not just doing

[00:15:54] that that's a piece of what they're doing for everyone else so you want to create a little tight

[00:15:57] concise environment with as little in there as possible to be able to serve your customers and

[00:16:02] then to make that compliant yeah I think we earlier we had west on our our show and he talked about

[00:16:09] with vendors making sure that they knew about what they were collecting so if that type of data

[00:16:15] that they're collecting falls in there is there a way for them to disable that if they can

[00:16:20] and they can prove that they're not collecting that type of data then now you start looking like

[00:16:24] an option that could be available for someone because they have evidence to prove they're not

[00:16:30] collecting that type of data and they can participate which would be great because we need a lot more

[00:16:34] options than we've got right now right you know currently I don't recommend any tools but I do

[00:16:39] recommend that you understand what you're ingesting of your clients whether it's security protection data

[00:16:45] and you know with an interconnection security agreement to clearly delineate whose responsibility

[00:16:53] for example if you are transmitting data over to a managed service provider are you the you

[00:16:58] know the organization that needs a CMMC accreditation are you providing that encryption or are they

[00:17:04] so you need to really lock in what you're doing with respect to the data exchange and understanding

[00:17:10] where that data lives and then you need to clearly delineate when you have a contract with anyone

[00:17:15] who's in this boat you know anyone who's seeking CMMC accreditation or doing federal work of what

[00:17:21] they need to do you know you need to kind of absolve yourself of any risk if for example something

[00:17:28] is seized in transit or man-in-the-littal attacks something's taken in transit whose job was it to

[00:17:34] maintain that connectivity so you need to understand who's doing what and then you need to make sure

[00:17:38] the customer understands what they need to do so with that is that more like a shared responsibility

[00:17:44] matrix where that's kind of outlined it could be but you know that's not I think if you were to go

[00:17:50] to the CMMC route then you wouldn't have one anyway you know but there's you know

[00:17:56] you could also accomplish something similar through an interconnection security agreement just

[00:18:00] in understanding of who's controls do what but I think a security control responsibility matrix

[00:18:04] that you provide for your service you know whoever you're working with would be a great idea

[00:18:08] okay um all right so let's switch gears here if you feel like is now a good time to switch

[00:18:14] to security protection assets you've you've touched on a little bit uh security protection data is

[00:18:21] is is kind of the new kit on the block of controversy but security protection assets people were a

[00:18:28] little bit surprised when they looked at the scoping guide and they're like what the heck is this

[00:18:32] is it just appeared in the scoping guide correct um yeah can you can maybe try to draw some

[00:18:39] um some things based on your fed ramp experience about security protection assets uh because first

[00:18:48] off let me just ask is is there such a thing in fed ramp as far as in the delineation or such

[00:18:53] as something exclusive to CMMC okay and I'm not you know the biggest fan of the term just

[00:18:59] because you know I think to back up to what my my interpretation of the intent was

[00:19:04] is that in fed ramp when you do an 853 assessment you need to test all of the controls for all

[00:19:11] of the components so that would mean that if you have windows components in your environment you

[00:19:15] need to do the full scale of 8050 degree testing or you know what's relevant obviously some don't

[00:19:19] matter but you need to ensure that you're all the controls relevant to a technology are tested by OS

[00:19:24] by platform by component type etc so because you can't do a background check on a firewall right

[00:19:30] now exactly yeah that's not going to work but uh I think the intent of the creation of this term

[00:19:38] was to say we don't we aren't doing that here in CMMC you only really need to care about for

[00:19:44] example the firewall and the context of it being a boundary protection but device or providing

[00:19:48] your VPN or serving as that external perimeter um and to test it from that capability so I think

[00:19:56] they created the term with good intent but I think that what is happening what I'm seeing happen

[00:20:00] is because now the rules state that you don't need to do as much for things that are security

[00:20:06] protection assets or that have security protection data that people are trying to shoehorn anything

[00:20:11] that's like not fits compliant or whatever into that category so they can so they can kind of opt out

[00:20:18] as sort of the controls that aren't being met and so for me that's the concern with this term is

[00:20:24] that it's being used to try to carve things into a different bucket where they don't necessarily belong

[00:20:30] yeah because you've got CMRAs you've got security protection assets and then kui assets which

[00:20:35] we're all going to have that exposure and there's some others like specialized assets but the

[00:20:41] the SPAs to me seem to create the most amount of frustration especially as I was kind of trying to

[00:20:48] get my head wrapped around it and I've almost just started taking the attitude as I'm just

[00:20:52] treating it almost like a kui asset from the perspective of if it's a Windows asset I'm going to

[00:20:58] I'm basically applying all possible policies and types of you know technical controls to limit

[00:21:07] in go through and accomplish every feasible way of applying controls that are relevant obviously

[00:21:15] I can't do a background check on a domain controller but or you know do I mean there's certain things

[00:21:23] obviously it can't do but we're going through it but when I read that scoping guide and have

[00:21:30] looked at it it seems like there's almost no distinction between a kui asset and a security

[00:21:37] protection asset I don't want to get into dangerous waters but can you give us a little bit more

[00:21:42] examples of what a security protection asset might be in a real world environment that would

[00:21:48] be labeled that way so for me a security protection well yeah I'll answer that and then I'll

[00:21:55] I there's another piece I want to address but yeah a security protection asset would be something

[00:22:01] that is necessary in the environment for you to fulfill all the security control requirements

[00:22:05] for the framework but they are saying to you know we don't want to go full scale on this we don't

[00:22:10] need to test everything so typically what you'll see for security protection assets are things like

[00:22:17] firewalls VPNs your multi-factor your your audit log data if you're using a sim

[00:22:25] if you are doing vulnerability scanning anything like that anything that is security related

[00:22:29] data or anything that is a tool that is providing a control within the framework they're saying

[00:22:35] this must be in your boundary but we don't need to do the full scale testing on it so those are

[00:22:41] the most common things that you'll see but I will say one of the things that you you know this is

[00:22:46] kind of how we do it in federity so the areas in which these come up the most would be well let me

[00:22:55] say how you can simplify it I guess if you were using some sort of federated or single sign on

[00:23:00] capability for all the components in your environment then when you test access controls you are

[00:23:04] testing those components access controls you know as long as they are integrated with what you

[00:23:09] already have if you're forcing multi-factor for everyone who comes into the environment then

[00:23:13] you're testing that in AC you don't need to look at it differently but for the most part where

[00:23:19] you're going to want those things to be doing compliance CMMC things is for your user log into them

[00:23:27] for all the password policies that are pushed to them if there's audit data coming out of those

[00:23:32] components that's going to matter as well as how are you managing these are you patching them

[00:23:37] are you scanning them etc so if you have an enterprise approach to those three capabilities

[00:23:43] then all we really need to care about for your security protection assets is are they working

[00:23:47] as intended to provide the requisite controls so is your firewall actually you know protecting your

[00:23:53] perimeter is your VPN actually being forced for everyone and you know functioning is intended in

[00:23:59] FIFS mode etc so you know I think that's the best way to look at it is to have enterprise management

[00:24:05] over all the components to the extent possible and at that point you can kind of relax and just

[00:24:10] think about that component from the perspective of is it doing what it needs to so if you're doing

[00:24:16] the more enterprise scoped assumed controls like patching and those types of things a lot of that's

[00:24:22] going to be covered actually so yeah and so you know that's one easy way to look at it is

[00:24:29] it's easy for you to say I only want you to focus on firewall for the firewall controls is

[00:24:34] if you have the rest of that under you know in scope that everything every change you make to your

[00:24:39] firewalls going to get through the same change control process that you have if all the users are

[00:24:43] provisioned the same way if they you're forced to do multifactor etc that's the easiest way to

[00:24:48] kind of isolate a security protection asset for what it needs to be gotcha Karen thank you so

[00:24:53] much for joining us today but I wanted to give you an opportunity just to kind of share some things

[00:24:57] that you're doing and sharing content you know either way that we found you as through

[00:25:03] their great posts that you've been doing on LinkedIn and comments and questions because I've thrown

[00:25:07] out a lot of questions and you've shot so straight with me and given me some of the best clarity

[00:25:12] on some very controversial things when most people just want to keep their mouth closed because they didn't

[00:25:16] want to get toasted but you kind of stepped out into that space and shared some things and were

[00:25:21] you know a little fearless about getting trolled on some of that stuff and I just I think you have

[00:25:25] great content and I just wanted to give you an opportunity to share some things that you might

[00:25:29] be doing and sharing out there yeah I'm actually about to I think one of the one of the concerns that

[00:25:36] I think the the defense industrial base in the CMMC folks are dealing with this is federated

[00:25:41] equivalency memo so one of the things that I'm about to launch is an 853 it's a it's a YouTube

[00:25:47] series called NIST Control Freak and in it I'm going to discuss all of the 853 controls how

[00:25:54] you will assess it how can you interpret it how can we implement it pitfalls as well as how

[00:26:00] can you actually assess it so I think that this is it's just one of the things that I felt like

[00:26:05] in my career I had to do the most of when people ask me questions it's usually how do I test

[00:26:10] a specific control or this is what I'm seeing how how does this affect the interpretation of

[00:26:15] the control so I'm trying to get that knowledge out there so folks know because it's you know

[00:26:20] I've collected it over 20 years and it's been through a lot of you know let a high end

[00:26:24] organizations where I'm pretty sure that my interpretation at this point sinks with the rest

[00:26:29] of federal government so I'm trying to share that out with folks wow so they can help implement

[00:26:34] because I've worked forever in the the federated advisory space helping folks get federal accredited

[00:26:39] so they can help implement and they can also learn how to test and to be prepared for their own audit

[00:26:46] so with CMMC there's 320 assessment objectives with FedRAMT like how many total sub objectives

[00:26:57] if you added them all up for for FedRAMT to moderate well what would that be?

[00:27:02] Well they just put the Rev 5 out and you know there's a different control count used to be 325

[00:27:07] controls for a FedRAMT moderate baseline but you have to understand that within that there are

[00:27:11] sub parts right now so I mean and then you also have to layer on the fact that FedRAMT makes

[00:27:17] you do it at the perhaps at the OS level you know so there have been times in doing a FedRAMT

[00:27:23] assessment where the number of test cases I was doing was well over 3000 so yeah it's a little bit

[00:27:29] different. It's definitely on hardbed. I can't wait to see that and go through

[00:27:37] I'm sure that's probably going to be perhaps several years if you're trying to go through

[00:27:42] however some of you know because it's like by the you know I'm concerned about the revisions

[00:27:48] yeah I don't want any my content to go stale but just pull it off and put out a new one I guess.

[00:27:54] Well you know I think the connection between CMMC and FedRAMT is critical to understand

[00:28:01] and having that content out there would be massively helpful. I am not very savvy when it comes

[00:28:08] to the FedRAMT aspect so and that's why we're going to have you back on the show just to talk about

[00:28:14] in our next podcast about kind of the connectivity and the the commonality and the differences

[00:28:20] between FedRAMT and CMMC there's a lot of connectivity between them and there's also a lot

[00:28:26] of differences just as we were talking about you can kind of see that very clearly and so

[00:28:32] for if you guys are just tuning in to this podcast go back and look at some of the other things

[00:28:37] that we've done and also make sure you pay attention to Karen's next one that's going to be coming

[00:28:40] up that we're going to be talking about those connectivities because I think it's super important

[00:28:44] for you to understand if you're doing the CMMC journey to really have a good understanding

[00:28:48] of how they kind of connect. Make sure to follow us on LinkedIn and YouTube to stay up to date

[00:28:54] on the latest CMMC news. We hope you guys enjoyed today's episode and listen out for the next one

[00:29:00] but until then keep on climbing.