CMMC
DoD certification verifying cybersecurity for FCI and CUI
LGPD
Brazil's regulation for personal data protection
Quick Verdict
CMMC certifies DoD contractors' cybersecurity for FCI/CUI via tiered assessments, ensuring supply chain protection. LGPD mandates personal data safeguards for Brazilian residents with fines. Organizations adopt CMMC for contracts, LGPD to avoid penalties and build trust.
CMMC
Cybersecurity Maturity Model Certification (CMMC)
Key Features
- Three cumulative certification levels for risk-based maturity
- Third-party C3PAO assessments verifying NIST 800-171 compliance
- DIBCAC exclusive assessments for Level 3 APT defenses
- Mandatory supply chain flow-down via DFARS clauses
- POA&Ms limited to 180-day closures
LGPD
Lei Geral de Proteção de Dados Pessoais (LGPD)
Key Features
- Extraterritorial scope targeting Brazilian residents
- 10 core principles including prevention, non-discrimination
- Fines up to 2% Brazilian revenue per violation
- Mandatory DPO appointment for controllers
- ANPD-approved SCCs for cross-border transfers
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
CMMC Details
What It Is
Cybersecurity Maturity Model Certification (CMMC) is a U.S. DoD certification framework verifying cybersecurity protections for Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) in the Defense Industrial Base (DIB). It uses a tiered, risk-based model with three cumulative levels: Level 1 (basic FCI safeguards), Level 2 (NIST SP 800-171 for CUI), and Level 3 (NIST SP 800-172 enhancements against APTs).
Key Components
- 14 domains (e.g., Access Control, Incident Response) with 17 Level 1 practices, 110 Level 2 controls, plus 24 Level 3 enhancements.
- Built on FAR 52.204-21, NIST SP 800-171 Rev 2, and NIST SP 800-172.
- Assessment model: self-assessments (Level 1/2), C3PAO (Level 2), DIBCAC (Level 3); SPRS/eMASS reporting; limited POA&Ms.
Why Organizations Use It
Mandated for DoD contractors/subcontractors handling FCI/CUI; ensures contract eligibility, reduces supply chain risks, enhances resilience, and provides competitive procurement advantage. Builds stakeholder trust via verified maturity.
Implementation Overview
Phased approach: scoping, gap analysis, remediation, assessment preparation, certification, sustainment. Targets DIB firms (SMEs to primes); requires SSPs, evidence artifacts, annual affirmations. Typical for U.S. defense supply chain.
LGPD Details
What It Is
Lei Geral de Proteção de Dados Pessoais (LGPD), Law No. 13.709/2018, is Brazil's comprehensive data protection regulation. It safeguards personal data of natural persons, with extraterritorial scope applying to processing targeting Brazilian residents. LGPD adopts a risk-based approach, emphasizing accountability, minimization, and data subject rights.
Key Components
- **10 core principlespurpose limitation, adequacy, necessity, transparency, security, prevention, non-discrimination, accountability, data quality, free access.
- 10 legal bases for processing, including consent, legitimate interests, contracts.
- **Data subject rightsaccess, correction, deletion, portability, objection to automated decisions.
- **Governancemandatory DPO for controllers, Records of Processing Activities (RoPAs), DPIAs for high-risk activities.
- Compliance enforced by ANPD with graduated sanctions.
Why Organizations Use It
LGPD is legally binding, with fines up to 2% Brazilian revenue (R$50M cap). It mitigates risks from breaches, builds stakeholder trust, enables market access in Brazil, and supports innovation via anonymization exemptions.
Implementation Overview
Phased approach: governance setup, data mapping/RoPA, policies, technical controls, DSR/incident processes, audits. Applies to all sizes/industries processing Brazilian data; no certification but ANPD audits.
Key Differences
| Aspect | CMMC | LGPD |
|---|---|---|
| Scope | Cybersecurity for FCI/CUI in DoD contracts | Personal data protection across all sectors |
| Industry | Defense Industrial Base, US-focused | All industries, Brazil residents extraterritorial |
| Nature | Mandatory certification for DoD contractors | Mandatory regulation with ANPD enforcement |
| Testing | Self/C3PAO/DIBCAC assessments every 3 years | DPIAs, audits, no formal certification required |
| Penalties | Contract ineligibility, no direct fines | Fines up to 2% Brazilian revenue, R$50M cap |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CMMC and LGPD
CMMC FAQ
LGPD FAQ
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