NIST 800-171: Protecting Sensitive Information in Electronics Manufacturing

| Created: December 17, 2024

NIST 800-171 Protecting Sensitive Information in Electronics Manufacturing

With the global supply chains growing more interdependent as each year passes, it's clear that all manufacturing operations—including and, perhaps especially, electronics—rely on and thrive upon collaboration between stakeholders in different fields, countries, and markets. As a result, companies often share sensitive design and production information with contract manufacturers and suppliers, among others, to bring their products to life. This information can be a treasure trove of intellectual property, trade secrets, and even data related to defense articles or dual-use items. Protecting this sensitive data is of the utmost importance for companies intent on maintaining a competitive edge and ensuring compliance with regulations.

Chief among those regulations is the incredibly important National Institute of Standards and Technology (NIST) Special Publication 800-171 (NIST 800-171) for companies transferring sensitive information to contract manufacturers. If you are interested in learning about the specific requirements for companies sharing such data, or if you deal with defense articles or dual-use items as defined by the International Traffic in Arms Regulation, read on.

Understanding the Regulations: ITAR and NIST 800-171

The International Traffic in Arms Regulations (ITAR) governs the export and import of defense articles, technical data regarding defense articles, and services; companies dealing with ITAR-controlled information need to be aware of specific compliance requirements that extend beyond cybersecurity. NIST 800-171 is related to ITAR in that it defines cybersecurity performance standards that must be met in order to align with ITAR requirements, thus playing a crucial role in safeguarding this sensitive data.

While ITAR does not dictate specific cybersecurity controls, the National Archives and Records Administration (NARA) classifies "export-controlled" information as a category of Controlled Unclassified Information (CUI). This classification brings NIST 800-171 into play as the minimum cybersecurity standard for protecting this sensitive data.

NIST 800-171: A Framework for Robust Cybersecurity

NIST 800-171 provides a comprehensive set of security controls designed to safeguard CUI; these controls span a wide range of areas to form a complete cybersecurity framework. The following list explores the key elements:

Access control: Implementing strong access control measures ensures that only authorized individuals can access sensitive information. This includes multi-factor authentication, role-based access controls, and thorough access logging to monitor activity.
Awareness and training: Educating employees about cybersecurity best practices and ITAR compliance is key; regular training programs help employees identify and report suspicious activity, phishing attempts, and potential security breaches. Training should also cover ITAR-specific procedures for handling export-controlled information.
Incident response: A well-defined incident response plan helps companies swiftly identify, respond to, and recover from security incidents. This plan should outline procedures for containing the breach, mitigating damage (including potential data loss), eradicating the root cause, and reporting the incident to relevant authorities, which may include the Directorate of Defense Trade Controls (DDTC) for ITAR violations.
Data security: Protecting sensitive data at rest, in transit, and in use is a critical aspect of cybersecurity. NIST 800-171 outlines controls for data encryption (both at rest and in transit), data erasure procedures for disposing of electronic media, and secure data transfer protocols.

Putting these controls in place demonstrates a company's commitment to the protection of sensitive information and achieving compliance with NARA's CUI requirements. That being said, it is important to remember that NIST 800-171 serves as a baseline; companies may need to conduct risk assessments to identify their specific vulnerabilities and implement additional controls based on their findings.

A Step-by-Step Guide to NIST 800-171 Compliance for Contract Manufacturers

So, it's clear why NIST 800-171 compliance is important, but how do you go about ensuring the secure transfer of sensitive design and production information to contract manufacturers? Consider the following steps:

Step	Examples
Conduct a risk assessment	Identify sensitive information that will be shared, assess potential threats and vulnerabilities, and determine the level of risk associated with the transfer.
Establish a secure communication channel	Use encrypted communication channels (e.g., VPN, secure email) to protect data in transit, implement strong access controls to limit access to sensitive information, and regularly monitor and update security protocols.
Implement strong access controls	Enforce strong password policies and multi-factor authentication, grant access to sensitive information on a need-to-know basis, and regularly review and update access permissions as necessary.
Secure data storage and backup	Encrypt sensitive data both at rest and in transit, regularly back up sensitive information and store backups securely, and implement data loss prevention (DLP) measures to prevent unauthorized data transfer.
Train employees	Provide regular cybersecurity awareness training to employees, educate employees on ITAR regulations and their responsibilities, and conduct phishing simulations to test employee awareness.
Incident response planning	Develop a comprehensive incident response plan, establish procedures for detecting, responding to, and recovering from security incidents, and regularly test and update the incident response plan.
Monitor and audit security practices	Conduct regular security audits and vulnerability assessments, monitor network traffic and system logs for suspicious activity, and stay up-to-date with the latest security best practices and regulations.
Consider ITAR compliance	If you are dealing with defense articles or dual-use items, make sure you are ITAR-compliant and work with ITAR-registered manufacturers to mitigate export control risks.

ITAR Registration: An Additional Layer of Security for Defense and Dual-Use Items

If your company is transferring information related to defense articles or dual-use items as defined by the ITAR, working with an ITAR-registered manufacturer is essential. ITAR registration with the DDTC signifies that the manufacturer has established a comprehensive export control program to ensure compliance with ITAR regulations. This program goes beyond cybersecurity and encompasses a broader set of procedures:

License applications: Obtaining the necessary licenses for the export of defense articles or dual-use items is a critical step. ITAR-registered manufacturers understand the complexities of the ITAR licensing process and can guide companies through it, ensuring they have the proper authorization for the specific items being transferred.
Record keeping: Maintaining accurate and detailed records of all ITAR-related transactions is mandatory. ITAR-registered manufacturers have established systems for keeping these records for the required period, which can vary depending on the specific ITAR category of the item.
Disclosures: ITAR requires reporting specific disclosures to the DDTC, such as potential violations or unauthorized disclosure of ITAR-controlled information. ITAR-registered manufacturers are familiar with these reporting requirements and can ensure timely and accurate disclosures to the appropriate authorities.
Physical security: ITAR regulations also encompass physical security measures to safeguard controlled information. ITAR-registered manufacturers will have established protocols for access control to physical locations where ITAR-controlled information is stored or processed.

A Multi-Layered Approach for Maximum Protection

Companies in the electronics manufacturing industry that adhere to NIST 800-171 and work with ITAR-registered manufacturers can guarantee the protection of sensitive information and compliance with relevant regulations. But remember that NIST 800-171 provides just a foundation; additional controls may be necessary depending on specific circumstances. It's worth consulting with legal and cybersecurity experts to make sure that your company has a comprehensive approach to protecting such information and meets all compliance requirements. It's a multi-layered approach that helps to create a secure environment for collaboration within the electronics manufacturing industry and safeguards innovation and, in some cases, national security interests.

If your company is looking to level up its process and bring PCB design into compliance, take a look at Altium 365 GovCloud, a complete solution designed to support the requirements of defense and government projects.

About Author

Oliver J. Freeman, FRSA, former Editor-in-Chief of Supply Chain Digital magazine, is an author and editor who contributes content to leading publications and elite universities—including the University of Oxford and Massachusetts Institute of Technology—and ghostwrites thought leadership for well-known industry leaders in the supply chain space. Oliver focuses primarily on the intersection between supply chain management, sustainable norms and values, technological enhancement, and the evolution of Industry 4.0 and its impact on globally interconnected value chains, with a particular interest in the implication of technology supply shortages.