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Welcome to the Quick 10 Podcast brought to you by Quick Track, focusing on all things

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FedCon and cyber defense from different perspectives and different personalities, all in 10-ish

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minutes.

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Here's your host, Derek White.

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All right.

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Welcome back everyone to another episode of the Quick 10 Podcast.

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As always, if you're listening on your favorite podcast platform, make sure to like or subscribe.

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And if you're watching over on YouTube, please do the same so you don't miss out on any of

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the new episodes as they come out.

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Today, my special guest is Mark Berman, CEO of Future Feed.

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Mark, thank you for joining.

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Very happy to be here and thanks for inviting me.

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You bet.

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You bet.

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Today, we're going to get into talking about governance risk and compliance, also known

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as GRC.

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So we're going to say GRC a lot.

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So that's what it stands for.

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If that's a new term to you, and there are many terms to understand in the world of federal

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government.

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So if that's a new term to you, look that up, Google that.

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But today we're going to talk about what GRC means to you and what to do.

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So the first thing I think that would really be helpful, Mark, is can you give the listeners

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and our watchers a checklist of what a GRC tool should do for them?

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Sure.

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I'm happy to do so.

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So what a GRC tool needs to do and rather than a checklist, we'll just kind of talk

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the picture a little bit.

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But what it really needs to do is take all of the minutia that we have to track in order

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to be assessed by a complete stranger who's going to walk into our business or really

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a team of them, because it's usually two to five people, who will come in in a two week

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period.

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They maybe have never heard of your company.

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They don't know whether you make hydraulics or you make computers or you do services.

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They have to understand how you're using IT.

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And then they have to understand everything about your IT to know if it's secure or not

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secure.

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That's a lot of detail.

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And not only do they have to understand it, but then they have to look for proof that

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you follow your policies and procedures.

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So in order to find proof that you follow your policies and procedures, they're probably

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going to need to read them or at least read some of them.

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So what you're looking for with governance with GRC or GRC tool is a place where you

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can take all of that detail.

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And this really comes down to three lists, Derek.

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There's a list of the people that you have and the roles that they perform for your company,

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right?

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Every company.

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We don't just have people, we have people of jobs.

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So we have the people and their roles.

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We have the tools and services that make up the IT.

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So when I say tools, it's not just the tools that are installed on your computer because

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it's 2024.

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Last time I checked, we're using the internet an awful lot.

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So a lot of our data may not be anywhere on our network.

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It could be out there in the world.

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So we have our people who are using tools and services.

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And what do our documents do?

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They tell the people what the rules, boundaries and limitations, if you like, sees them or

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are.

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That's what he says all the time.

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What are the rules, boundaries and limitations for using our tools and services?

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And exactly what are the instructions as to how to use them?

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So what we need with the GRC tool is a place where we can take all of that data and organize

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it in a way that complete strangers in a very short period of time can consume it, evaluate

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it and give you hopefully a score of 110 and let you keep doing business with the government.

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Yeah.

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And that's thank you for clarifying that there's, you know, GRC governance, risk and compliance

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is a huge aspect of the word compliance to a lot of people, right?

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They hear that, but they don't really understand exactly what that means.

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And it depends on the framework, it depends on what you're applying that to.

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But when it comes specific to the CMMC world and the day is coming where you're right,

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it is a scary thing to think about no matter what kind of third party assessment you're

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going through, whether it's OSHA or anything related to things that you're required to

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do.

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Organization is a huge thing.

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I think a lot of people jumped into evidence collection, you know, trying to self assess

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and throw stuff somewhere and the first thing that you heard feedback from third party assessments

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on that stuff is where is it and who answered it, who is responsible for it.

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And you're right, having that organization is very, very key.

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What also is important is I think you hit on too, is the assessments are essentially

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moment in time, but the expectation and requesting to expectation, the requirement is that you

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keep it there.

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And if you're thinking that, hey, got it done, I'll pay attention to this down the road.

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That's, that's where I think a lot of people are going to fall short is that they have

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the right to ask you at any time.

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So some of the hidden benefits then, if we want to get into that topic on, you know,

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the hidden benefits of compliance, kind of, you know, going beyond just the assessment,

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talk a little bit about that if you can on on what that means and how a tool like, you

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know, what Future Feed does, for example, can be something you can't just put your fingers

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on what those benefits look like.

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I'd love to address that.

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So my background was not actually doing this kind of work.

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For 20 plus years, I ran a chocolate factory.

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And one of the things that I learned about quality is that when you deliver quality consistency,

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consistently, you deliver profits to the ownership of the company.

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And so quality is driven by by doing things in a repeatable way.

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What is what is compliance really about?

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You have to have a list of controls.

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In the case of CMMC or NIST 800 171, you have 110 controls and 320 objectives.

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So for each one of those objectives, basically have to write down somewhere how you do that.

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And then the proof is in the pudding.

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So the proof is, do you have some evidence that you're repeatedly doing those things

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that you've written down?

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Well, those in another world, we don't really use the term SOP, standard operating procedure,

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very often in the compliance world.

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But really, that's what we're doing.

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We're saying when we do backups, we're going to follow this checklist of how to do a backup.

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When we review a change, we're not going to review the change randomly.

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We're not going to ad hoc have a different change management meeting every single time

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we look at a change.

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We're going to look at what are the security implications?

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How are they going to help our company move forward?

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We're going to evaluate the change.

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We're going to then send it to approval.

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Somebody is going to approve so that we have good communication.

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We're following these steps in the process.

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That's a standard operating procedure.

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When a company follows standard operating procedures, if you're a candy manufacturer,

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your candies come out with the same taste and experience for every single customer.

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If you're a car manufacturer or a tank manufacturer or something that you're doing for the government,

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some product that you build, you're going to have doors that close with the same gap

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every time.

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There are engines that run that have a reduced tolerance because even when you hire somebody

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on the first day, you're going to whip out this standard procedure.

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It could be an IT procedure.

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They're going to follow those steps.

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With compliance, they're going to sign off and you're going to keep a record that they

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followed the steps.

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When you do that consistently across your business, an interesting thing happens.

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The culture of the business changes.

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People then start to pay attention to process.

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When you pay attention to process, you pay attention to quality.

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Quality means repeat customers even if the government is your customer.

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You become the go-to contractor and you deliver profits.

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As the Willy Wonka of GRC, then you're saying the single point of failure could be a huge

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problem.

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No.

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There's free marketing things.

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If you haven't done that yet, then maybe the next time you're on, you should be dressed

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as Willy Wonka.

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It'd be great.

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We can do that.

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I think my Willy Wonka hat has been retired.

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Shoot.

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I could say I could think of some people that could be your Oompa Loompas.

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It'd be great.

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On that, I think the single point of failure quotation, that's one of the things that we

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see too and across this supply chain is a lot of small to medium size, most oftentimes

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disadvantaged when it comes to experience on cybersecurity and technology and stuff.

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We see a lot of that when you get into the future feed side of things.

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You get into the tools like you're talking about that responsibility, accountability,

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the racy side of who and what and where.

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There's a lot of times where the finger gets pointed back to the same person.

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That's Mark's job.

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Absolutely.

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What happens if Mark doesn't want to work here anymore?

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Mark wins the lottery, he takes off.

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What happens to your program?

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You can't have everything change just because there's a new person in the role.

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An important part of the GRC tool is it has to match the process that you're going to

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go through for the assessment.

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We understand that the whole process, I just spoke to the fact that that's going to help

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quality and profitability, but how's the tool going to take that process of actually going

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through an assessment and make it efficient?

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The process is actually three components.

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It's interviewing your people.

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It's examining the documents that you provide for them that tell the people what to do.

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It's testing your systems.

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What we try to do in our product and hopefully other GRC tools do the same is for the interview

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part, for everything that they're going to look at, we happen to use the racy model.

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We're basically identifying a person in charge of that thing.

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Your assessor isn't wandering throughout your company saying, who do I talk to about this?

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Who do I talk to about that?

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If they randomly pick people, they're likely to get very helpful people who will give the

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wrong answers because it's not their area of expertise.

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We want to identify who to talk to for each thing.

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Because they're an assessor, they're not just a tourist, they're going to ask the same questions

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to the person in charge as they're going to ask to one of the people responsible for doing

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the work.

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Hopefully, the answers are going to match.

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If they don't match, they're going to dive deeper and you may get a finding.

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That's one of their tricks is just ask the same question to two different people, the

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one in charge and the one that does the work, and then compare that to the policy and see

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if it matches.

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The second thing that they will often do is look at your documents and then they want

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to see if your documents all match up with each other.

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If you have a policy that says that you do something every 30 days and then you have

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records of doing a procedure every three months, there's a finding.

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The requirement may have been to do it every six months, but you chose to make a document

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that said every 30 days and your records are showing every 60 days and the real requirement

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is every six months.

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The difference between what you do and what you say you're going to do is a finding regardless

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of whether what you do is actually over and above what's needed.

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You don't want to overly create your policies that direct your team to do something in a

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way that you can't actually sustain and support because that's going to create a problem with

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your assessment.

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So your tool should be able to capture all these documents to inspect for the assessor,

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but also the tasks or some evidence that you're actually doing those things.

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And certainly we try to do that in our product.

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The last part, the testing, is a little bit harder to capture in a GRC tool.

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It's a little bit more random.

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This is where the assessor is going to come in.

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They will not go in and log into your system and just explore it.

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In fact, they're not allowed to.

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But what they will do is stand over your shoulder and ask you to bring up an Active Directory

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report, bring up this report or that report.

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And then they will watch to make sure that whatever you're representing on the interview

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and examine actually has some reality in your systems.

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And for that part, you're pretty much going to just have to be there.

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What you do need is a list of your systems.

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And I think one of the great aspects of CMMC is they have you categorize all your tools

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and services.

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Which ones are CUI assets that store, process or transmit CUI?

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They're going to focus really hard on those.

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Then they're going to focus on the ones that protect those CUI assets.

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They're called security protection assets.

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And then there are a couple more categories of assets where you're basically saying, okay,

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this could be relevant, but it's not normally in the process of doing CUI or it's completely

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out of scope.

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So actually when you make a list of your stuff and you say, here's 10 things that are relevant

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to the assessment and here's 40 things that are not relevant, you're finding focus and

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you're going to go through that assessment more quickly.

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So you want to make sure your tool, if you're using a tool to organize all this information,

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imagine if all this information was just like randomly in SharePoint or in Excel, it'd be

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very hard to maintain and support.

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That's why we have tools to help with the problem.

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Well, that's well said and to kind of wrap this up then the golden ticket to the Wonka

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factory is a really good tool that organizes and traces everything back to what you need

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to make things efficient.

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And I thank you for hitting on the efficiency side because that is, think about five years

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ago when CMMC was first coming from behind the curtain.

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I think the number one feedback on any sort of consulting engagement or any sort of third

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party view of was I can see a lot and it's all over the place, but this is going to take

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forever until we figure out how to organize this.

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And in fact, organize it and then we'll come back because otherwise we're going to end

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up spending three times as much time and that's money.

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Money in time is money.

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So well, that's good.

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Thank you, Mark, again for being my guest today.

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But more importantly, where can people learn more about Future Feed and how it helps on

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everything that you were talking about today?

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It looks like it's right under my picture on the screen, futurefeed.co.

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You can check it out.

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QuickTrack is a fantastic partner of Future Feed.

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They can give you some implementation answers like how hard is it to do?

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How long does it take?

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All of those things and they'll help you walk through it.

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It is a lot of information, but at the end of the day, having all this information that

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you gather up about your network and about your people, just having the information isn't

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enough.

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So make sure that whatever your process is, you have a tool so that you can quickly and

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easily find that information and make it useful.

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And whether it's Future Feed or another tool, what you're really looking for is a place

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where you can quickly access the information because there's so much of it.

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I'm going to leave you with one last thing.

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All this information that you gather, which is really mostly summary form, this is your

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system security plan.

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This is the keys to your castle.

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Make sure that if you're putting all that data, you're putting into something that you're

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putting into something that you feel good about the security of.

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We use the AWS government cloud.

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So it's the Gov cloud.

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We are kind of almost at the end of our journey to be FedRAMP moderate equivalent.

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Make sure whatever product, no matter how wonderful it is, if it's insecure, you're

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really allowing the bad guys to come in and not just steal information from you, but steal

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the plan on how to get, where is all your information, how to get there and all that.

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So make sure that you're considering the security of your platform as you are looking at various

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products in the marketplace.

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Well, there's probably an everlasting Gobstopper reference to make there somewhere, but we'll

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save that for next time.

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Well, thank you, Mark.

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This is going to be a good episode for people to reference for quite a while still.

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We still have plenty of things to learn from how these assessments are going to go.

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So thank you for joining today.

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That's going to wrap our episode.

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And as a reminder, as always, make sure to pop that subscribe button on your podcast

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platform that you're listening on.

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And if you're on YouTube watching over there, you can hit the subscribe button and that

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fancy little bell too, if you want to get the notifications when new episodes come out

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in the future.

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So again, thank you, Mark.

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And thanks for everyone for listening and watching.

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But we will catch you next time.

