What is the primary objective of **NIST 800-171**?

**NIST SP 800-171 provides recommended security requirements for protecting the confidentiality of Controlled Unclassified Information (CUI) in nonfederal systems and organizations.** It applies to components that process, store, transmit CUI, or provide protection for such components, tailored from NIST SP 800-53 Moderate baseline. Revision 3 (May 2024) supersedes Revision 2, organizing requirements into 17 families including new additions like Planning (PL), System and Services Acquisition (SA), and Supply Chain Risk Management (SR).

Who is legally or professionally required to comply with **NIST 800-171**?

**Nonfederal organizations handling CUI via federal contracts, grants, or agreements must comply with NIST SP 800-171.** This includes DoD contractors and subcontractors under DFARS 252.204-7012 for covered contractor information systems processing Covered Defense Information (CDI). Applicability is contractually enforced, excluding contracts solely for COTS items.

Does **NIST 800-171** require an external audit or third-party certification?

**No, NIST SP 800-171 does not mandate external audits or third-party certification.** Organizations develop a System Security Plan (SSP) describing implementation and a Plan of Action and Milestones (POA&M) for gaps, using SP 800-171A procedures (examine/interview/test). DoD may require SPRS score submission or CMMC Level 2 assessments.

How often should an assessment for **NIST 800-171** be performed?

**Assessments for NIST SP 800-171 should be performed annually at minimum, or after significant changes.** SP 800-171A Rev. 3 supports ongoing monitoring via SSP updates and POA&M reviews. DoD requires annual SPRS reaffirmation for self-assessments.

What are the consequences of non-compliance with **NIST 800-171**?

**Non-compliance with NIST SP 800-171 risks contract ineligibility, termination, and exclusion from DoD awards.** DFARS 252.204-7012 mandates implementation; failures lead to SPRS score penalties (down to -203), remedial demands, reputational damage, and potential False Claims Act liability.

Can **NIST 800-171** be mapped to other international frameworks?

**Yes, NIST SP 800-171 Revision 2 Appendix D maps directly to NIST SP 800-53 and ISO 27001 controls.** Revision 3 aligns closely with SP 800-53 Rev. 5, supporting integration into existing programs while maintaining CUI focus.

What is the first step to begin implementing **NIST 800-171**?

**The first step is to define the system boundary and inventory components processing, storing, or transmitting CUI.** Create data flow maps, isolate a CUI security domain using firewalls and controls, then conduct a gap analysis against the 97 Rev. 3 requirements to build the SSP.

What is the primary objective of **GLBA**?

**The primary objective of GLBA is to require financial institutions to explain their information-sharing practices and safeguard nonpublic personal information (NPI).** Enacted in 1999, GLBA's Title V mandates transparency via the **Privacy Rule (16 C.F.R. Part 313)**—initial and annual notices plus opt-out rights for nonaffiliated third-party sharing—and protection via the **Safeguards Rule (16 C.F.R. Part 314)**, requiring a written information security program with administrative, technical, and physical safeguards.

Who is legally or professionally required to comply with **GLBA**?

**GLBA applies to any "financial institution" significantly engaged in financial activities, including non-banks like mortgage lenders, payday lenders, debt collectors, tax preparers, and auto dealers arranging financing.** The FTC enforces for non-banks; banking regulators (OCC, Federal Reserve) oversee banks. Scope is activity-based, covering entities handling NPI; exemptions apply for those with fewer than 5,000 customers from some written requirements.

Does **GLBA** require an external audit or third-party certification?

**No, GLBA does not mandate external audits or third-party certification.** The **Safeguards Rule** requires internal risk assessments, vulnerability scans (semi-annually), penetration testing (annually for critical systems), and service provider oversight, with evidence like reports and remediation records. FTC enforcement focuses on demonstrable program effectiveness, not formal certification.

How often should an assessment for **GLBA** be performed?

**Risk assessments under GLBA must be performed periodically, at least annually, and after material changes in operations, technology, or threats.** The revised **Safeguards Rule** (effective June 2023) mandates written assessments inventorying NPI, evaluating threats, and driving controls; testing includes semi-annual vulnerability scans and annual penetration tests.

What are the consequences of non-compliance with **GLBA**?

**Non-compliance with GLBA can result in civil penalties up to $100,000 per violation for institutions, $10,000 per violation for individuals, and up to 5 years imprisonment for willful violations.** FTC enforcement (e.g., Equifax, PayPal) imposes fines, remediation, consent decrees; post-May 2024, breaches affecting 500+ consumers require FTC notification within 30 days, amplifying reputational and operational risks.

Can **GLBA** be mapped to other international frameworks?

**Yes, GLBA's Safeguards Rule maps directly to frameworks like NIST CSF and ISO 27001 for risk assessments, access controls, encryption, and incident response.** Privacy Rule elements align with notice and consent models; mappings facilitate integrated compliance, with GLBA's Qualified Individual and board reporting enhancing governance.

What is the first step to begin implementing **GLBA**?

**The first step to implement GLBA is to determine applicability by inventorying NPI flows and designating a Qualified Individual to oversee the security program.** Conduct a scoping analysis of financial activities, map data across systems/vendors, then develop the written information security program with board reporting.

NIST 800-171 vs GLBA

Standards Comparison

NIST 800-171

Mandatory

2020

U.S. framework protecting CUI in nonfederal systems

GLBA

Mandatory

1999

US law for financial privacy notices and data safeguards

Quick Verdict

NIST 800-171 mandates CUI protection for defense contractors via contractual controls and assessments, while GLBA requires financial institutions to implement privacy notices, opt-outs, and security programs with FTC enforcement. Organizations adopt them for federal contract eligibility and consumer data compliance.

Controlled Unclassified Information

NIST 800-171

NIST SP 800-171 Protecting CUI in Nonfederal Systems

Cost

€€€€

Complexity

High

Implementation Time

12-18 months

Key Features

Scoped to CUI-processing, storing, transmitting components
110 requirements across 14 families from 800-53 Moderate
Mandates SSP and POA&M documentation artifacts
Enables CUI enclave isolation for boundary control
Contract-enforced via DFARS 252.204-7012 clause

Financial Privacy

GLBA

Gramm-Leach-Bliley Act (GLBA)

Cost

€€€

Complexity

High

Implementation Time

6-12 months

Key Features

Mandates privacy notices and opt-out for NPI sharing
Requires written information security program with safeguards
Designates Qualified Individual for oversight and reporting
Imposes 30-day FTC breach notification for 500+ consumers
Mandates service provider oversight and risk management

Detailed Analysis

A comprehensive look at the specific requirements, scope, and impact of each standard.

NIST 800-171 Details

What It Is

NIST SP 800-171 Revision 3 is a U.S. government framework providing security requirements for protecting Controlled Unclassified Information (CUI) confidentiality in nonfederal systems. Its primary scope targets contractors and supply chains, using a control-based approach tailored from NIST SP 800-53 Moderate baseline.

Key Components

97-110 requirements organized into 14-17 families (e.g., Access Control, Audit, Supply Chain Risk Management in r3).
Core artifacts: System Security Plan (SSP) and Plan of Action and Milestones (POA&M).
Assessment via SP 800-171A procedures (examine/interview/test).
Compliance model emphasizes contractual enforcement, self-assessments, and CMMC certification.

Why Organizations Use It

Mandated by DFARS 252.204-7012 for DoD contracts.
Reduces breach risks, ensures procurement eligibility.
Builds stakeholder trust, enables FedRAMP cloud equivalence.
Provides competitive edge in federal supply chains.

Implementation Overview

Phased: scoping/gap analysis, SSP/POA&M development, control deployment, continuous monitoring.
Applies to federal contractors of all sizes; audit via SPRS/CMMC.
Timelines: 6-36 months based on complexity.

GLBA Details

What It Is

The Gramm-Leach-Bliley Act (GLBA) is a US federal law enacted in 1999 as the Financial Modernization Act. It regulates nonpublic personal information (NPI) privacy and security for financial institutions. Employing a risk-based approach, it mandates transparency in data-sharing practices and comprehensive safeguards against unauthorized access.

Key Components

**Privacy Rule (16 C.F.R. Part 313)Initial and annual notices, opt-out rights for nonaffiliated third-party sharing.
**Safeguards Rule (16 C.F.R. Part 314)Written security program with administrative, technical, physical controls; Qualified Individual designation; board reporting; breach notification for 500+ consumers.
**Pretexting ProvisionsProtections against false pretenses for obtaining NPI. No formal certification; compliance via regulator enforcement and audits.

Why Organizations Use It

Mandatory for broad financial entities (banks, non-banks like tax firms, auto dealers).
Mitigates penalties ($100k/violation), enhances trust, reduces breach risks.
Builds competitive edge through robust security and privacy governance.

Implementation Overview

Phased: scoping NPI flows, risk assessments, controls (encryption, MFA, vendor oversight), testing, training. Targets US financial activities; scalable by size, ongoing audits required. (178 words)

Key Differences

Aspect	NIST 800-171	GLBA
Scope	CUI confidentiality in nonfederal systems	NPI privacy and security in financial institutions
Industry	Defense contractors, federal supply chain	Financial services, non-banks like tax preparers
Nature	Contractual NIST requirements, DoD enforced	Mandatory FTC regulation with civil penalties
Testing	SPRS scoring, CMMC assessments, examine/interview/test	Penetration testing, vulnerability scans annually
Penalties	Contract ineligibility, SPRS score penalties	Up to $100K per violation, civil/criminal fines

Scope

NIST 800-171

CUI confidentiality in nonfederal systems

GLBA

NPI privacy and security in financial institutions

Industry

NIST 800-171

Defense contractors, federal supply chain

GLBA

Financial services, non-banks like tax preparers

Nature

NIST 800-171

Contractual NIST requirements, DoD enforced

GLBA

Mandatory FTC regulation with civil penalties

Testing

NIST 800-171

SPRS scoring, CMMC assessments, examine/interview/test

GLBA

Penetration testing, vulnerability scans annually

Penalties

NIST 800-171

Contract ineligibility, SPRS score penalties

GLBA

Up to $100K per violation, civil/criminal fines

Frequently Asked Questions

Common questions about NIST 800-171 and GLBA

NIST 800-171 FAQ

GLBA FAQ

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NIST 800-171

GLBA

Quick Verdict

NIST 800-171

Key Features

GLBA

Key Features

Detailed Analysis

NIST 800-171 Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

GLBA Details

What It Is

Key Components

Why Organizations Use It

Implementation Overview

Key Differences

Scope

Industry

Nature

Testing

Penalties

Frequently Asked Questions

NIST 800-171 FAQ

What is the primary objective of NIST 800-171?

Who is legally or professionally required to comply with NIST 800-171?

Does NIST 800-171 require an external audit or third-party certification?

How often should an assessment for NIST 800-171 be performed?

What are the consequences of non-compliance with NIST 800-171?

Can NIST 800-171 be mapped to other international frameworks?

What is the first step to begin implementing NIST 800-171?

GLBA FAQ

What is the primary objective of GLBA?

Who is legally or professionally required to comply with GLBA?

Does GLBA require an external audit or third-party certification?

How often should an assessment for GLBA be performed?

What are the consequences of non-compliance with GLBA?

Can GLBA be mapped to other international frameworks?

What is the first step to begin implementing GLBA?

You Might also be Interested in These Articles...

Real-World ISO 27701 Success: Synthesized Case Studies, Metrics, and Lessons for Privacy Resilience

SOC 2 Trust Services Criteria in Plain English: Side-by-Side Decoder for Security, Availability, and Beyond

What is DORA and which Requirements does the Standard define?

Run Maturity Assessments with GRADUM

Check out these other Gradum.io Standards Comparison Pages

UAE PDPL vs LEED

PIPL vs ISO 14064

APPI vs PIPEDA