Building a Practical Cybersecurity Program with NIST CSF

How do you build a cybersecurity program that’s both comprehensive and practical- without breaking the bank or overwhelming your team? The answer lies in a framework that strips away complexity and replaces it with clarity.  

Enter the NIST Cybersecurity Framework—a game-changing approach that has transformed how thousands of organizations worldwide think about, implement, and communicate their cybersecurity strategies. Whether you’re a Fortune 500 enterprise, a scrappy startup, or a local government agency, understanding this framework isn’t just good practice—it’s becoming the baseline expectation for demonstrating cyber resilience in an age where “if” has been replaced by “when” in conversations about cyber incidents. 

What is the NIST Cybersecurity Framework? 

The NIST Cybersecurity Framework (CSF), developed by the National Institute of Standards and Technology, is a voluntary cybersecurity framework that provides organizations with a structured approach to managing and improving their cybersecurity posture. Originally created in response to Executive Order 13636 following increased cyber threats to critical infrastructure, the framework has evolved into one of the most widely adopted and influential cybersecurity standards across industries worldwide. 

The NIST CSF 2.0, released in February 2024, represents the most significant update since the framework’s inception in 2014. This enhanced version expands beyond critical infrastructure to serve organizations of all sizes and sectors, providing a flexible, outcome-based approach to cybersecurity that emphasizes governance, supply chain security, and organizational resilience. Notably, NIST dropped the “Framework for Improving Critical Infrastructure Cybersecurity” title from version 1.1, signaling that CSF 2.0 explicitly targets all sectors and organization sizes. 

Purpose of the NIST Cybersecurity Framework 

The NIST Cybersecurity Framework serves multiple strategic purposes that make it invaluable for modern organizations: 

1. Risk Management Excellence: The framework provides a systematic approach to identifying, assessing, and managing cybersecurity risks across the entire organization, enabling informed decision-making at all levels. 

2. Common Language Creation: NIST CSF establishes a standardized vocabulary that allows cybersecurity professionals, executives, and stakeholders to communicate effectively about cybersecurity risks, priorities, and investments.

3. Regulatory Alignment: The framework helps organizations align with various regulatory requirements and industry standards, serving as a foundation for compliance efforts across multiple jurisdictions and sectors. 

4. Continuous Improvement: By providing measurable outcomes through Organizational Profiles and Implementation Tiers, the framework enables organizations to track their cybersecurity maturity and identify areas for enhancement over time. 

Structure of NIST CSF and Implementation Tiers 

The NIST Cybersecurity Framework 2.0 is built around six core Functions, 22 Categories, and 106 Subcategories (outcomes), complemented by four Implementation Tiers that provide flexibility in application.

A. The Six Core Functions

The framework organizes cybersecurity activities into six Functions: 

1. GOVERN (GV) – Establishes cybersecurity governance, risk management strategy, and organizational oversight to enable informed risk-based decisions. This is the new Function in CSF 2.0, incorporating what were previously scattered governance elements from CSF 1.1. 

2. IDENTIFY (ID) – Develops understanding of cybersecurity risks to systems, people, assets, data, and organizational capabilities. 

3. PROTECT (PR) – Implements appropriate safeguards to manage cybersecurity risks to organizational assets and data. 

4. DETECT (DE) – Develops and implements activities to identify the occurrence of cybersecurity events promptly. 

5. RESPOND (RS) – Develops and implements response activities to take action regarding detected cybersecurity incidents. 

6. RECOVER (RC) – Develops and implements recovery activities to maintain resilience and restore capabilities impaired by cybersecurity incidents. 

CSF Framework Components Breakdown 

Source: NIST Cybersecurity Framework 2.0 (February 2024) 

B. Implementation Tiers

The framework defines four Implementation Tiers that characterize how an organization’s cybersecurity risk management practices—particularly governance and risk management processes—are applied through Organizational Profiles. These Tiers are not maturity levels for the entire organization but rather describe the rigor and integration of cybersecurity practices: 

Tier 1: Partial – Cybersecurity risk management is ad hoc and reactive. Limited awareness of cybersecurity risk at the organizational level. Risk is managed informally and, on a case-by-case basis. 

Tier 2: Risk-Informed – Risk management practices are approved by management but may not be established as organizational policy. Cybersecurity awareness exists, but an organization-wide approach is inconsistent. 

Tier 3: Repeatable – Risk management practices are formally approved and expressed as policy. Organizational cybersecurity practices are regularly updated based on changes to business requirements and the threat landscape. 

Tier 4: Adaptive – Practices are based on lessons learned and predictive indicators. The organization actively adapts to the changing cybersecurity landscape and incorporates advanced cybersecurity technologies and practices. 

Using Profiles and Tiers in Practice 

Organizational Profiles are a cornerstone of NIST CSF 2.0 implementation. This is how they work: 

• Current Profile: Document your organization’s current cybersecurity posture by identifying which outcomes you currently achieve and at what Tier level. 

• Target Profile: Define your desired future state based on business requirements, threat environment, and risk tolerance. 

• Gap Analysis: Compare Current and Target Profiles to prioritize improvements and allocate resources effectively. 

Example: A healthcare provider creates a Current Profile showing Tier 2 implementation of PROTECT outcomes related to data security. Their Target Profile sets Tier 3 for these same outcomes within 18 months, driving investment in encryption, access controls, and staff training. 

Certification and Attestation Requirements 

Unlike many cybersecurity standards, the NIST Cybersecurity Framework does not require formal certification or third-party attestation. NIST does not accredit any NIST CSF certifications. The framework is designed as a voluntary, flexible tool that organizations can adapt to their specific needs and risk tolerance, as emphasized in the NIST CSF 2.0 release documentation. 

However, organizations may choose to undergo various forms of assessment or validation: 

• Self-Assessment: Organizations can conduct internal evaluations of their cybersecurity posture using the framework 

• Third-Party Assessment: Independent assessors can evaluate an organization’s implementation of the framework 

• Regulatory Compliance: Some regulations reference the NIST CSF as a baseline for cybersecurity requirements 

• Supply Chain Requirements: Partners or customers may require demonstration of framework implementation 

Practical Validation Alternatives 

Since there’s no official certification, consider these validation approaches: 

• Internal audits aligned to CSF outcomes and documented in Profiles 

• External readiness assessments by qualified consultants 

• Using Current and Target Profiles as evidence for boards, insurers, and customers 

• Mapping to established standards (ISO 27001, SOC 2) that recognize CSF alignment 

Governance and Oversight 

The NIST Cybersecurity Framework operates under a unique governance structure that emphasizes collaboration and continuous improvement: 

Primary Oversight Organization-NIST 

National Institute of Standards and Technology (NIST) – NIST, an agency of the U.S. Department of Commerce, maintains and updates the Cybersecurity Framework through ongoing stakeholder engagement, research, and analysis of emerging threats and technologies. 

Key Stakeholder Groups 

• Industry Partners: Private sector organizations across all industries contribute to framework development 

• Government Agencies: Federal, state, and local government entities provide input on regulatory alignment 

• Academic Institutions: Research universities contribute to cybersecurity research and best practices 

• International Organizations: Global partners help ensure framework relevance across borders 

Enforcement and Compliance Landscape 

The NIST Cybersecurity Framework itself is not legally enforceable. However, various regulations and requirements may reference or mandate its use. 

Regulatory Integration 

While not directly enforceable, the framework is increasingly referenced in various regulatory contexts: 

• Federal Contractors: Some government contracts may require framework implementation 

• Critical Infrastructure: Sector-specific regulations may reference the framework 

• State Regulations: Some states incorporate framework elements into cybersecurity requirements 

• Industry Standards: Many sector-specific standards align with or reference the framework 

Key Provisions and Control Classifications 

1. Control Frameworks Integration 

The NIST CSF serves as an umbrella framework that can integrate with various control frameworks. NIST maintains Informative References that map CSF 2.0 outcomes to established standards via the CSF 2.0 Reference Tool, facilitating integrated audits: 

• NIST SP 800-53: Security and Privacy Controls for Federal Information Systems 

• ISO/IEC 27001/27002: Information Security Management Systems standards 

• CIS Controls: Critical Security Controls for Effective Cyber Defense 

• COBIT: Control Objectives for Information and Related Technologies 

• NIST SP 800-171: Protecting Controlled Unclassified Information 

2. Supply Chain Risk Management in NIST CSF 2.0 

CSF 2.0 places significant emphasis on Cybersecurity Supply Chain Risk Management (C-SCRM). The GOVERN.Supply Chain (GV.SC) category specifically addresses third-party risk. Organizations should reference NIST SP 800-161 Rev. 1 as a companion guide for comprehensive C-SCRM implementation. This focus helps organizations extend cybersecurity requirements to vendors, suppliers, and partners through contractual obligations and ongoing monitoring. 

3. Privacy and AI Integration 

CSF 2.0 explicitly relates to privacy risk management and references NIST’s AI Risk Management Framework (AI RMF) to help organizations manage AI system risks alongside cybersecurity concerns. This integration reflects emerging threats and the interconnected nature of cybersecurity, privacy, and AI governance in modern organizations. 

Industries and Sectors Impacted 

While originally designed for critical infrastructure, the NIST Cybersecurity Framework has broad applicability across virtually all industry sectors: 

Critical Infrastructure Sectors 

• Energy: Electric utilities, oil and gas companies, renewable energy providers 

• Financial Services: Banks, credit unions, insurance companies, payment processors 

• Healthcare: Hospitals, clinics, pharmaceutical companies, medical device manufacturers 

• Transportation: Airlines, railways, shipping companies, logistics providers 

• Communications: Telecommunications providers, internet service providers, satellite operators 

• Water and Wastewater: Municipal water systems, treatment facilities, distribution networks 

• Manufacturing: Critical manufacturing facilities, defense contractors, chemical plants 

• Government Facilities: Federal, state, and local government operations 

Expanding Adoption 

• Small and Medium Enterprises: Scalable implementation for resource-constrained organizations 

• Technology Companies: Software developers, cloud service providers, cybersecurity vendors 

• Professional Services: Consulting firms, legal practices, accounting companies 

• Educational Institutions: Universities, schools, research organizations 

• Non-Profit Organizations: Charitable organizations, foundations, advocacy groups 

Consequences of Non-Compliance with NIST CSF

Since the NIST Cybersecurity Framework is voluntary, there are no direct fines or penalties for non-adoption. However, consequences may arise indirectly through various channels. 

Indirect Consequences 

• Regulatory Violations: Failure to meet sector-specific regulations that reference the framework 

• Contract Losses: Inability to secure government contracts or partnerships requiring framework implementation 

• Insurance Issues: Higher premiums or coverage exclusions from cyber insurance providers 

• Legal Liability: Potential negligence claims following data breaches or security incidents 

• Reputational Damage: Loss of customer trust and market confidence following security incidents 

• Competitive Disadvantage: Inability to demonstrate cybersecurity maturity to stakeholders 

Due Diligence Standard 

Increasingly, courts and regulators view adherence to recognized frameworks like NIST CSF as evidence of reasonable cybersecurity practices. Organizations that fail to implement basic framework elements may face greater liability in the event of a breach. 

Employee Responsibilities and Compliance 

Successful implementation of the NIST Cybersecurity Framework requires active participation from employees at all levels of the organization: 

Leadership and Governance Responsibilities 

• Executive Oversight: Senior leadership must establish cybersecurity as an organizational priority and allocate necessary resources 

• Policy Development: Management should develop and communicate clear cybersecurity policies aligned with framework outcomes 

• Risk Tolerance: Leadership must define the organization’s risk appetite and acceptable levels of cybersecurity risk 

• Performance Monitoring: Regular assessment and measurement of cybersecurity program effectiveness 

Technical and Operational Staff Responsibilities 

• Asset Management: Maintain accurate inventories of systems, devices, software, and data assets 

• Security Controls: Implement and maintain protective measures according to organizational policies 

• Monitoring and Detection: Actively monitor systems for cybersecurity events and anomalies 

• Incident Response: Respond promptly and effectively to detected cybersecurity incidents 

• Recovery Planning: Develop and test business continuity and disaster recovery procedures 

General Employee Responsibilities 

• Security Awareness: Participate in cybersecurity training and stay informed about current threats 

• Policy Compliance: Follow established cybersecurity policies and procedures consistently 

• Incident Reporting: Report suspected security incidents or violations promptly to appropriate personnel 

• Data Protection: Handle sensitive information according to classification and protection requirements 

• Access Management: Use access credentials responsibly and report suspicious account activity 

Best Practices for NIST CSF Implementation 

Organizations seeking to implement the NIST Cybersecurity Framework effectively should consider the following best practices: 

Getting Started: A 6-Step Roadmap 

Follow this structured approach to launch your CSF 2.0 implementation: 

Step 1: Inventory Assets (IDENTIFY) – Create a comprehensive inventory of systems, data, people, devices, and organizational assets that support critical business functions. 

Step 2: Create Current Profile (All Functions) – Document your existing cybersecurity posture by assessing which CSF outcomes you currently achieve and at what Implementation Tier. 

Step 3: Define Target Profile (GOVERN) – Develop your desired future state based on business requirements, risk tolerance, threat environment, and available resources. 

Step 4: Identify Quick Wins (PROTECT & DETECT) – Compare Current and Target Profiles to prioritize high-impact, low-cost improvements such as multi-factor authentication, data backups, or security awareness training. 

Step 5: Integrate with Existing Programs (GOVERN) – Align CSF implementation with existing risk management, compliance, quality assurance, and business continuity programs to avoid duplication. 

Step 6: Measure Progress via KPIs (All Functions) – Establish key performance indicators aligned with business objectives and CSF outcomes to track improvement over time. 

Implementation Strategies 

• Phased Approach: Implement the framework gradually, starting with foundational elements and building complexity over time 

• Risk-Based Prioritization: Focus resources on areas of highest risk and greatest potential impact to the organization 

• Integration with Existing Programs: Align framework implementation with existing compliance, risk management, and quality programs 

• Stakeholder Engagement: Involve business units, IT teams, and leadership in framework development and implementation 

• Continuous Monitoring: Establish metrics and regular assessment processes to track progress and identify areas for improvement 

Organizational Excellence 

• Supply Chain Security: Extend cybersecurity requirements to third-party vendors and partners through contractual obligations 

• Threat Intelligence: Incorporate relevant threat intelligence into risk assessments and security planning 

• Security Automation: Leverage technology to automate routine security tasks and improve efficiency 

• Regular Testing: Conduct penetration testing, vulnerability assessments, and tabletop exercises to validate security controls 

• Documentation and Training: Maintain comprehensive documentation and provide regular training to ensure consistent implementation 

Measurement and Improvement 

• Key Performance Indicators (KPIs): Develop metrics that align with business objectives and framework outcomes 

• Maturity Assessment: Regularly evaluate your organization’s progress toward target implementation tiers 

• Benchmarking: Compare your cybersecurity posture with industry peers and best practices 

• Lessons Learned: Incorporate insights from incidents, exercises, and assessments into continuous improvement efforts 

Transitioning from NIST CSF 1.1 to 2.0 

If you’re coming from CSF 1.1, this is what moved and what changed: 

What Moved into GOVERN: 

• Business Environment (from IDENTIFY) 

• Governance (from IDENTIFY) 

• Risk Assessment (from IDENTIFY) 

• Supply Chain Risk Management (from IDENTIFY) 

Major Structural Changes: 

• Functions increased from 5 to 6 (GOVERN added) 

• Categories increased from 23 to 22 (consolidated and reorganized) 

• Subcategories/Outcomes expanded to 106 with clearer, more actionable language 

• Emphasis on Profiles and Tiers as implementation tools strengthened 

Essential NIST CSF 2.0 Resources 

To support your implementation journey, NIST provides several continuously updated resources: 

• CSF 2.0 Reference Tool: Browse the Core with search, filter, and export capabilities 

• CSF 2.0 PDF: Complete framework documentation available at csf.tools 

The NIST Cybersecurity Framework 2.0 represents a mature, flexible approach to managing cybersecurity risk in an increasingly complex threat landscape. By embracing its voluntary, outcome-based methodology, organizations of all sizes can build resilient cybersecurity programs that protect critical assets, enable business objectives, and demonstrate due diligence to stakeholders. 

How databrackets can help you comply with NIST CSF 

At databrackets, we are a team of certified and experienced security experts with over 14 years of experience across industries. We have helped organizations of all sizes comply with cybersecurity best practices and prove their compliance with a wide variety of security standards to enable them to expand their business opportunities and assure existing clients of their commitment to protecting sensitive information and maintaining high standards of security and privacy.  

We offer 3 Engagement Options to help you prove your compliance with NIST Cybersecurity Framework (CSF) – our DIY Toolkit (ideal for MSPs and mature in-house IT teams), and Hybrid or Consulting Services. Our Deliverables include:  

• Gap Assessment report 

• Policies and Procedures 

• User awareness training 

• Implementation design guidance 

• Vulnerability Assessment and Pen Testing 

• Ongoing support during remediation 

You can partner with us to prove your compliance on an annual basis and engage our team to support your organization. 

About databrackets   

Our team of security experts has supported organizations across a wide variety of industries to align their processes with security frameworks like  ISO 27001:2022, SOC 2, HIPAA, 21 CFR Part 11,   NIST SP 800-53, NIST Cybersecurity Framework, NIST SP 800-171, GDPR, CMMC etc. We are an authorized certifying body for ISO 27001 and a 3PAO for FedRAMP. We also have partnerships to help clients prepare for and obtain other security certifications. 

We are constantly expanding our library of assessments and services to serve organizations across industries. Schedule a Consultation if you would like to Connect with an Expert to understand how we can customize our services to meet your specific requirements.