NIST Releases Draft Cybersecurity Framework


The National Institute of Standards and Technologies (NIST) has released the first draft of the Cybersecurity Framework required by President Obama’s Executive Order 13636 and Presidential Policy Directive 21, as detailed in our earlier posts (found here, here and here). The draft outlines the tentative format of the final Framework, which would include four major sections:

  • A guide for senior executives and others on how to use the Framework to evaluate and manage their organizations’ cyber risk preparedness;
  • A user’s guide for more detailed implementation of the Framework;
  • The “core structure” of the Framework; and
  • A compendium of references such as existing cybersecurity standards, guidelines and practices.

The “core framework” is largely a blank shell at this time, which NIST expects owners and operators of critical infrastructure and other stakeholders to populate during the next cybersecurity workshop, to be held July 10-12, 2013 in San Diego. Specifically, NIST hopes to fill out five major cybersecurity functions (each with categories, subcategories, and references to standards) and three “Implementation Levels” to gauge an organizations’ implementation of the various functions of the Framework.

For example, the key “functions” of the Framework—“Know; Prevent; Detect; Respond; and Recover”—correspond to typical steps found in many existing standards and organizational cyber incident “playbooks.” The Framework’s “Implementation Levels” will define how well an organization satisfies these cybersecurity functions.

As drafted, NIST characterizes the Framework “as a guide rather than a detailed manual.” In fact, NIST recognizes that different infrastructure sectors – and even different organizations within a given sector – will need to make cybersecurity decisions based on the levels of particular risks for that sector or organization. Despite NIST’s effort to position the Framework as voluntary, there is concern among some stakeholders that the final Cybersecurity Framework could become the basis for future legislation or agency enforcement.

After a third workshop scheduled for September, NIST plans to publish a preliminary version of the complete Framework in October. The Framework must be in final form by February 2014.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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