While most of us understand cloud services through the common NIST definition, the Cybersecurity Maturity Model Certification (CMMC) takes a notably different approach. This distinction can significantly impact defense contractors and their compliance requirements. Let’s explore this through a practical example:
Imagine Quantum Naval Solutions, where employees can spin up or destroy virtual servers through a simple web form on their internal site. Their IT department manages all the infrastructure in-house. So, are they a CSP? The answer depends on which definition you use:
The NIST Technical View
According to NIST SP 800-145, Quantum Naval Solutions checks all the major boxes for cloud computing:
- They offer self-service virtual servers on demand
- Resources are pooled and dynamically allocated
- Services are accessible through their network
- Systems can scale based on demand
Under this technical definition, Quantum Defense Systems qualifies as a private cloud provider.
The CMMC Regulatory View (32 CFR)
The CMMC framework, through 32 CFR, takes a different stance. This regulation focuses on external vendors who handle sensitive government data and must meet specific compliance requirements like FedRAMP. Since Quantum Naval Solutions only provides internal IT services, they wouldn’t qualify as a CSP under these rules.
Why This Matters
This distinction has practical implications for defense contractors. While you might be operating what technically qualifies as a cloud environment under NIST, CMMC’s narrower definition could mean different compliance requirements apply. This is particularly important when handling Controlled Unclassified Information (CUI) and working within the Defense Industrial Base.
Organizations should carefully consider both perspectives when evaluating their cloud services. Understanding these differences can save significant time and resources in your compliance journey.
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