Are your PCB supplier’s security measures up to par?
In today’s interconnected digital landscape, safeguarding sensitive information is not just a priority – it’s a necessity. For businesses engaged with US government contracts, compliance with cybersecurity standards is essential to protect controlled unclassified information (CUI). One critical framework for ensuring this is the National Institute of Standards and Technology (NIST) Special Publication 800-171, which outlines security requirements for protecting CUI within non-federal systems and organizations.
Compliance with NIST 800-171 is increasingly significant for PCB manufacturers, as the electronics industry often intersects with sensitive defense, aerospace and other government-related sectors. Understanding the framework and its implications is vital for PCB manufacturers, as it ensures they can protect their customers’ sensitive data, meet federal standards and maintain their reputation as trusted suppliers in critical industries.
Likewise, for PCB buyers, ensuring manufacturing and assembly partners comply with these cybersecurity guidelines is critical – whether it’s a government contract or not.
Figure 1. Are your digital data properly protected?
What is NIST 800-171 Compliance?
NIST 800-171 establishes guidelines to protect CUI – a classification for information that requires safeguarding (but is not classified) under national security. The directive provides a structured approach to ensure that non-federal organizations handling CUI can maintain its confidentiality.
First issued in 2015 and made mandatory for US Department of Defense (DoD) contractors in 2017, NIST 800-171 is rooted in the Federal Information Security Management Act (FISMA) and aims to mitigate risks associated with cyberattacks, data breaches and unauthorized access. The framework specifies 110 controls divided across 14 families of requirements, ranging from access control to system integrity.
The Department of Defense increasingly requires its suppliers to adhere to NIST 800-171 through its Defense Federal Acquisition Regulation Supplement (DFARS).
These standards apply to various organizations, including contractors, manufacturers and suppliers working with federal agencies or handling CUI in any capacity.
Why PCB Manufacturers Need NIST Compliance
PCB manufacturers often serve industries that rely on secure and precise technology, such as defense, aerospace and healthcare. As such, they frequently encounter contracts or projects involving CUI, including:
- Gerber files
- Sensitive emails
- Sensitive contact information details
- Other application notes and details.
Key Requirements of NIST 800-171
To comply with NIST 800-171, organizations must implement robust security measures, grouped into 14 categories:
- Access control: Restrict system access to authorized users and processes, including employees and subcontractors.
- Awareness and training: Ensure personnel and subcontractors understand cybersecurity risks and policies.
- Audit and accountability: Maintain logs and ensure accountability for system activities.
- Configuration management: Enforce secure configurations for systems and software.
- Identification and authentication: Use strong authentication methods for system access.
- Incident response: Establish procedures for detecting, reporting and responding to security incidents.
- Maintenance: Perform system maintenance while safeguarding sensitive data.
- Media protection: Securely handle and dispose of physical and digital media.
- Personnel security: Screen individuals accessing CUI, including all entities involved in the supply chain, such as employees, suppliers and subcontractors.
- Physical protection: Restrict physical access to systems containing CUI.
- Risk assessment: Regularly evaluate risks to organizational systems.
- Security assessment: Periodically review security measures for compliance.
- System and communications protection: Securely transmit data.
- System and information integrity: Promptly detect and respond to security vulnerabilities.
An additional nontechnical requirement is to develop, implement and maintain a security program, including policies and a system security plan.
Implementing these requirements for PCB manufacturers, assemblers and brokers means safeguarding customer designs, intellectual property and sensitive specifications against cyber threats.
Beyond Compliance: CMMC 2.0
NIST 800-171 compliance is not just a regulatory obligation but a foundation for advanced cybersecurity initiatives. The Cybersecurity Maturity Model Certification (CMMC), for instance, builds upon NIST requirements, creating a tiered certification system for DoD contractors.
The recently finalized Cybersecurity Maturity Model Certification (CMMC) 2.0 program refines and streamlines the original framework, introducing three distinct levels of certification to match the sensitivity of the government data involved in contracts:
- Level 1 (Foundational). This tier addresses basic safeguarding requirements and applies to contractors handling federal contract information (FCI). It is based on 17 controls and requires an annual self-assessment.
- Level 2 (Advanced). This level incorporates the 110 controls from NIST SP 800-171 for contractors handling CUI. A subset of these contractors will undergo third-party assessments every three years, while others may only need self-assessments.
- Level 3 (Expert). Designed for the highest level of CUI sensitivity, Level 3 combines the controls from NIST SP 800-171 with an additional 24 controls from NIST SP 800-172. Third-party assessments are mandatory every three years.
The CMMC program underscores a risk-based approach to cybersecurity, ensuring contractors align with tailored requirements based on their risk exposure and the type of information they handle. PCB manufacturers and suppliers must understand and adopt the appropriate CMMC level to meet DoD requirements and maintain trust as a secure partner.
Evaluating PCB Partners: A Buyer’s Checklist
By searching for PCB partners that have achieved NIST compliance, PCB buyers ensure they have a partner that prioritizes cybersecurity and data protection and will continue to do so for future compliance requirements and challenges.
Actionable steps PCB buyers may take to vet potential suppliers – whether procuring for a federal contract or not – include:
1. Request certification or compliance documentation
- Ask potential PCB manufacturing partners for evidence of NIST 800-171 compliance or equivalent certifications such as Cybersecurity Maturity Model Certification (CMMC). Documentation should outline their implementation of the required security controls, as defined by NIST SP 800-171.
2. Evaluate cybersecurity policies
- Request an overview of the manufacturer’s cybersecurity policies. Ensure it has protocols for:
- Access control (restricting unauthorized access to sensitive data).
- Incident response (plans for identifying, reporting, and mitigating breaches).
- System integrity and data monitoring mechanisms.
3. Review self-assessments or external audits
4. Understand their supply chain security
- Confirm whether the PCB supplier ensures cybersecurity compliance across its supply chain, including brokers and component suppliers. A compliant partner must flow down and enforce similar standards among subcontractors.
5. Understand their role in protecting CUI
- Ask for clarity on how they handle controlled unclassified information, such as Gerber files, application notes and sensitive communications. Ensure they encrypt data, limit access and follow physical security protocols for servers and storage.
Why This Matters for PCB Buyers
Ensuring that the PCB manufacturing partner complies with NIST 800-171 helps to protect intellectual property from cyber threats, avoid potential contract breaches and meet any regulatory obligations tied to the industry. Cybersecurity is no longer optional; it’s necessary for buyers and their partners.
Andrew Gonzales is vice president of engineering at San Francisco Circuits (sfcircuits.com); This email address is being protected from spambots. You need JavaScript enabled to view it..
