Standards Comparison

    CMMC

    Mandatory
    2021

    DoD certification model for cybersecurity maturity in DIB

    VS

    PDPA

    Mandatory
    2012

    Asian family of personal data protection acts

    Quick Verdict

    CMMC mandates cybersecurity certification for DoD contractors protecting FCI/CUI, while PDPA enforces privacy rules for organizations handling personal data in Singapore. Companies adopt CMMC for contract eligibility; PDPA to avoid fines and build trust.

    Cybersecurity Maturity

    CMMC

    Cybersecurity Maturity Model Certification (CMMC) 2.0

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Three tiered certification levels for escalating protections
    • Third-party C3PAO assessments verify Level 2 compliance
    • Mandatory flow-down to DoD subcontractors via DFARS
    • Limited POA&Ms with strict 180-day closure rules
    • Annual SPRS affirmations ensure ongoing compliance status
    Data Privacy

    PDPA

    Personal Data Protection Act (PDPA)

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Mandatory data breach notification (72 hours)
    • Consent and lawful processing bases
    • Data subject access and correction rights
    • Cross-border transfer limitation obligations
    • Accountability via DPO and policies

    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) 2.0 is a 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 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). The approach emphasizes scoping, evidence-based assessments, and verified compliance.

    Key Components

    • 14 domains (e.g., Access Control, Incident Response) with 17 Level 1, 110 Level 2, and 134 Level 3 practices.
    • Built on FAR 52.204-21, NIST SP 800-171 Rev 2, and NIST SP 800-172.
    • Certification via self-assessments (Levels 1/2), C3PAO (Level 2), or DIBCAC (Level 3); POA&Ms limited to 180 days.

    Why Organizations Use It

    Mandated for DoD contractors/subcontractors handling FCI/CUI; ensures contract eligibility, reduces supply chain risks, enhances resilience, and provides competitive advantage in bids. Builds stakeholder trust via verified maturity.

    Implementation Overview

    Phased approach: scoping, gap analysis, remediation, assessment preparation, certification, sustainment. Applies to all DIB sizes; requires SSP, evidence artifacts, annual affirmations in SPRS/eMASS. Timelines 12+ months for Level 2.

    PDPA Details

    What It Is

    PDPA (Personal Data Protection Act) refers to a family of statutes in jurisdictions like Singapore, Thailand, and Taiwan regulating personal data handling. These are principle-based regulations focused on protecting individuals' data while enabling legitimate organizational use. They adopt a risk-based approach balancing privacy rights with business needs through consent, transparency, and safeguards.

    Key Components

    • Core obligations: consent/notification, purpose limitation, access/correction rights, security, retention/transfer limits, accountability.
    • 8-10 main principles across regimes (e.g., Singapore's 9 obligations).
    • Built on GDPR-influenced structures with local nuances like DPO requirements, breach notification (72 hours), Do Not Call registries.
    • Compliance via self-assessment, no universal certification but regulator enforcement.

    Why Organizations Use It

    • Mandatory in applicable jurisdictions for data processors.
    • Mitigates fines (up to SGD 1M/S$1M, THB 5M), builds trust, enables cross-border operations.
    • Enhances reputation, reduces breach risks, supports digital economy participation.

    Implementation Overview

    • Phased: gap analysis, data mapping, policies, controls, training.
    • Applies to organizations handling local residents' data; risk-based for SMEs/multinationals.
    • No certification but audits, DPO appointment, ongoing DPMP required. (178 words)

    Key Differences

    Scope

    CMMC
    Cybersecurity for FCI/CUI protection
    PDPA
    Personal data collection/use/disclosure

    Industry

    CMMC
    US DoD contractors/supply chain
    PDPA
    All organizations in Singapore/Thailand/etc.

    Nature

    CMMC
    Mandatory certification for contracts
    PDPA
    Mandatory privacy regulation with fines

    Testing

    CMMC
    C3PAO/DIBCAC assessments every 3 years
    PDPA
    Self-assessments, audits, no certification

    Penalties

    CMMC
    Contract ineligibility, no direct fines
    PDPA
    Fines up to SGD 1M or 10% revenue

    Frequently Asked Questions

    Common questions about CMMC and PDPA

    CMMC FAQ

    PDPA FAQ

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