On August 26, 2015, the Department of Defense (DoD) issued an interim rule that imposes expanded obligations on defense contractors and subcontractors with regard to the protection of “covered defense information” and the reporting of cyber incidents occurring on unclassified information systems that contain such information. Nearly three years in the making, this interim rule replaces the DoD’s prior Unclassified Controlled Technical Information (“UCTI”) Rule, imposing new baseline security standards and expanding the information that is subject to safeguarding and can trigger the reporting requirements. Additionally, the interim rule implements policies and procedures for safeguarding data and reporting cyber incidents when contracting for cloud computing services.
© 2015 Covington & Burling LLP
