Proven Human Capital Management Solutions

Proven Human Capital Management Solutions

Proven Human Capital Management Solutions

We handle payroll, benefits, compliance and risk so you can focus on your business.

We handle payroll, benefits,

compliance and risk. You can focus on your business.

We handle payroll, benefits, compliance and risk so you can focus on your business.

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Businesses that outsource HR grow faster, achieve higher profitability, experience lower turnover, and foster happier employees. Stay focused on your business.

C2 will, too.

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Whether you need full-service co-employment or flexible admin support,
C2 offers the model that fits your growth stage and compliance needs.

Whether you need full-service co-employment or flexible admin support, C2 offers the model that fits your growth stage and compliance needs.

PEO - Professional Employer Organization

PEO Support — Make C2 Your Employer of Record

Let C2 become your Employer of Record so you can share liability, simplify HR, and access big-company benefits.

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PEO - Professional Employer Organization

PEO Support — Make C2 Your Employer of Record

Let C2 become your Employer of Record so you can share liability, simplify HR, and access big-company benefits.

What’s Included:

Employer of Record: C2

Shared liability protection

Large-group health, dental, vision, and retirement benefits

Payroll & tax administration

Recruiting & HR support

ASO – Administrative Services Organization

Proof & Trust

Trusted by Businesses Nationwide

“C2 helped us capture new contracts and scale our organization not only through its robust HR services, but especially because of its expertise in the government contracting space.”

Erica Robertson, CEO

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James Smith - CEO

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What a Shark, a Comedian and a Nobel Laureate Taught Me About Breaking Barriers

When people talk about breaking the glass ceiling, they often focus on the moment someone finally breaks through. The promotion. The title. The company. The accomplishment. What we don't talk about enough are all the moments that come before it. 


The moments when you're told you aren't qualified enough. When you're the only woman in the room. When someone speaks over you. When you're underestimated. When you watch an opportunity go to someone else because you don't have the right degree or background. When you begin wondering whether the things that make you different are going to keep you from becoming the person you know you can be. I know those moments because I lived them. 


And when I think about Women's Equality Day, I think not only about my own journey, but about the women whose stories have influenced me along the way. Some came before me. Some built their careers alongside my generation. And one is young enough to remind me that inspiration and mentorship don't always come from those who are older than us. They are entrepreneurs, journalists, entertainers, executives and advocates. Their lives could hardly be more different. 


But every one of them encountered a ceiling that told her, in one way or another, this is as far as you are supposed to go. And every one of them kept going and so did I. 

The Girl Hiding Behind the Door 

I grew up in a military family without much money. My father's career as an Army Infantry officer meant our family moved around the world, usually every few years. I was born in Georgia while he was stationed at Fort Benning, and moving became a normal part of childhood. 


Long before I knew what adaptability meant in business, I learned it through life. New schools. New communities. New countries. New people. Every few years, I had to learn how to walk into an unfamiliar environment and find my place. That ability to adapt would eventually become one of my greatest strengths in business. 


But there was another part of my childhood that took much longer to understand. School was difficult for me. This was during a time when children who learned differently weren't necessarily given the understanding or resources available today. I struggled academically and was separated from the other students and sent to another classroom. 


I remember being so embarrassed about being placed with the "slow kids" that I would hide behind the door because I didn't want the other children to see that I was in there. Think about what that teaches a little girl. Before you even understand why you're different, you begin believing that being different is something you should hide. 


For years, I didn't have an explanation for why certain things were harder for me. I simply believed I wasn't as good at them as everyone else. It wasn't until I was around 30, after a family member was diagnosed with dyslexia, that I decided to be evaluated myself. I was dyslexic. Suddenly, so much of my childhood made sense. But something else had happened during all those years when I didn't know. 


I adapted. I learned how to compensate for the things that were difficult by becoming exceptionally good at other things. I learned to remember information. I learned to read people. I learned to communicate. I learned to build relationships. I learned how to understand what someone needed, sometimes before they knew how to articulate it themselves. The thing I had once believed was holding me back had forced me to develop some of the exact abilities that would eventually make me successful in human resources and business. 

Barbara Corcoran: What School Couldn’t Measure 

That's one of the reasons I have always felt such a strong connection to Barbara Corcoran. 


Millions of people know Barbara today as one of the original investors on Shark Tank. They see a confident entrepreneur evaluating businesses and deciding which founders deserve her investment. But Barbara's story didn't begin in a boardroom. 


She has spoken openly about struggling academically because of dyslexia. She moved through numerous jobs as a young woman before eventually finding her place in real estate. With a $1,000 loan, Barbara started a tiny real estate company in New York City. That business eventually became The Corcoran Group, one of the best-known names in New York real estate. She would later sell the company and build another chapter of her career as an investor, author and television personality. 


What Barbara broke through wasn't simply the traditional glass ceiling facing women in business. She also broke through assumptions about what intelligence and potential are supposed to look like. For someone who grew up with dyslexia, that means something to me. When you struggle in school, it can be very easy to confuse learning differently with being less capable. I spent part of my childhood believing that. 


Barbara's story demonstrates the opposite. She figured out what she did exceptionally well and built around those strengths. So did I. Our careers and businesses are very different, but I recognize something in her journey. 


Neither of us followed the traditional roadmap people associate with becoming successful businesswomen. Neither of us allowed dyslexia to write the ending of our stories. And both of us ultimately built companies from very humble beginnings. 


Barbara broke a glass ceiling by proving that the girl who struggled in the classroom could eventually become the woman sitting on the other side of the table investing in other people's dreams. Sometimes the first ceiling you have to break is the one the world taught you to place over yourself. 

Finding the Work That Fit Me 

My career didn't follow a straight line either. I didn't complete college. I originally thought I might become a pediatric nurse because I loved children and helping people. But academics continued to be difficult, particularly in areas like math and chemistry, and eventually I changed direction. 


Like a lot of young people, I moved between possibilities before realizing where I belonged. That place was human resources. I had actually gotten an early glimpse of HR while my family was stationed in Germany. During a summer job in the Civilian Personnel Office, I watched a woman who genuinely loved helping people solve problems. I remember the joy she got from her work. People would walk in with problems, and she wanted to help fix them. I could see myself doing that. 


Eventually, I found my way back to HR professionally and into the government contracting world. And I discovered that I was good at it. I understood people. I built relationships. People trusted me. I could walk into different environments and adapt, something I had been practicing without realizing it since childhood. But being good at your job and being allowed to advance weren't always the same thing. I was told I was talented,  was told I did great work. But I was also told that because I didn't have a college degree, there were positions I couldn't reach. 


Then there was another reality. I was a woman building a career in the government contracting world of the late 1980s and early 1990s. It was overwhelmingly male. I knew what it felt like to be underestimated. I knew what it was like not to have a voice. I was ignored. I was talked over. I was excluded. 


There were rooms where you understood very quickly that some of the men around the table did not necessarily see you as their equal. I began to understand that there really was a glass ceiling above me. But there was another message I had grown up hearing that eventually became part of how I approached business and life: 


Failure is not an option. 


If someone else had already decided how high I was allowed to go, perhaps I needed to stop asking for permission to go higher. 

Barbara Walters: A Voice That Changed Who Got to Ask the Questions 

During those years, women like Barbara Walters mattered to me. Today, it is easy to turn on the television and see women anchoring major news programs, interviewing presidents and leading conversations about politics, culture and world events. 


That was not always the case. Barbara Walters built her career in an era when broadcast journalism, particularly its most prestigious positions, was overwhelmingly controlled by men. She began working behind the scenes in television before joining NBC's Today show in the early 1960s. Even as her role grew, women in television news were often expected to cover lighter stories while their male colleagues were given the most serious assignments.  


Barbara kept pushing beyond those expectations. She became the first female co-host of Today. Then, in 1976, she made television history when she joined ABC Evening News and became the first woman to co-anchor a network evening news program. Later, she became a longtime presence on 20/20 and, in 1997, created The View, building a program around women having direct, sometimes difficult conversations about the issues of the day. 


Over the course of her career, Barbara interviewed presidents, heads of state, celebrities and some of the most recognizable figures in the world. Her ability to secure important interviews became one of the defining characteristics of her career. But what I admired most wasn't simply who she interviewed. It was the authority she earned to ask the questions. For generations, the person sitting across from a president, a world leader or another powerful figure was usually a man. 


Barbara changed that image. She demonstrated that a woman could control the conversation. She could be persistent. She could challenge someone powerful. She could ask an uncomfortable question and wait for the answer. And she could do all of it without becoming someone else in order to be taken seriously. 


Most importantly to me, people trusted her. That was the part of Barbara's career that stayed with me. I was learning professionally that having something valuable to contribute didn't necessarily mean someone would automatically give me the opportunity to contribute it. Barbara's career demonstrated something different: authority doesn't always have to be given to you. Sometimes you build it until people can no longer ignore it. 


And she did more than break through for herself. By becoming the first woman to co-anchor   network evening newscast, she changed what millions of Americans saw when they imagined a person with authority. Later, with The View, she helped create a table specifically built around women having opinions, disagreeing, asking questions and shaping conversations themselves. There is something important about that progression. 


Early in our careers, so much of our energy can be spent trying to prove that we deserve a seat at someone else's table. Eventually, leadership becomes about creating a bigger table. Looking back, I think that is one of the lessons I took from Barbara without fully realizing it at the time. I was reaching a point in my own career where I had demonstrated what I could do. I knew I was good at my work. I knew I understood people. I knew I understood government contractors. And I was beginning to recognize an opportunity that other people weren't seeing.  


The question was whether I was going to continue waiting for someone else to decide what I was qualified to do. Or whether I was finally going to decide for myself. 

When I Stopped Waiting for Permission 

As my career progressed, I started noticing an opportunity. I was working in HR for government contractors and developing relationships throughout the federal contracting community. Small businesses were competing for significant government work, but many didn't have the internal infrastructure of the larger companies they were competing against. They needed sophisticated HR support, but many couldn't justify building entire HR departments. 


There was a gap. And I couldn't stop thinking about it. 


Eventually, I went to the Library of Congress to research an idea I genuinely thought I had invented. What if one organization could provide these businesses with the HR infrastructure and services they needed? Then I discovered something slightly humbling. I hadn't invented it. The PEO model already existed. But what I had identified was still important. The model wasn't being widely used to serve the Washington-area federal contracting community in the way I envisioned. So instead of being discouraged that someone had gotten there first, I started asking a different question: 


Why couldn't I be the one to bring it to the market I knew? 


In 1996, at 32 years old, I started C2. There was no beautiful corporate headquarters. There wasn't a large staff waiting for me. There wasn't a giant pool of investment capital. 


There was my townhouse. There was me. And there were my parents. 


My parents weren't wealthy investors. After my father retired from the military, they invested their retirement money into a chicken farm. When I needed funding to start my company, they took a loan against that farm and gave me $100,000. I agreed to repay every dollar with interest. 


I remember asking my father what would happen if I failed. The answer, underneath a joke about him and my mother having to walk chickens for the rest of their lives, was the same message he had taught me throughout my life. Failure wasn't an option. So I got to work. 


When I say I ran the company, I mean I ran the company. HR, payroll, accounting, sales, client relationships, research, and operations. If something needed to happen, there wasn't another department I could send it to, I was the department. 


Entrepreneurship looks very different when you're living through it than it does when someone tells the success story decades later. The beginning wasn't glamorous. It was long hours, uncertainty, responsibility, and knowing my parents had put their own financial security behind their belief in me. 


But slowly, the things I had imagined started becoming real. I hired my first employee. We added clients. We hired more people. And eventually, C2 had an office. I remember what that represented to me. I could physically walk through a door and see what all of those years of work had created. C2 wasn't an idea being run out of my basement anymore. It was a company. And one of the accomplishments that meant the most to me had nothing to do with an award or title. 


It was that I paid my parents back every dollar including the interest. 

Joan Rivers: Never Make Yourself Smaller  

As C2 grew, I faced a different challenge. Starting a company is one thing. Deciding what kind of leader you're going to become is another. That is one of the reasons I have always admired Joan Rivers. 


Joan entered American comedy during the 1960s, when stand-up and late-night television were overwhelmingly male worlds. She spent years performing in clubs before receiving a major break on The Tonight Show. She eventually became Johnny Carson's permanent guest host and, in 1986, became the first woman to host a late-night network television talk show. Think about the significance of that. A chair historically occupied by men suddenly had a woman sitting in it. That was a glass-ceiling moment. But Joan's career wasn't a straight line upward. Her late-night show ended. Professional relationships collapsed. She experienced rejection, criticism and periods when many people might have assumed her career was finished. Joan rebuilt again and again. She returned to television. She performed. She wrote. She reinvented herself for new audiences. And she continued working for decades.  


But what I admire most is that through all those reinventions, Joan remained unmistakably Joan. She was outspoken. She was sharp. She was fearless. She worked relentlessly. She took risks. She could laugh at herself. And she didn't ask permission to take up space. That was another ceiling she helped break. 


Women entering male-dominated spaces have historically been expected to adapt themselves to make everyone else comfortable. Be confident, but not intimidating. Be ambitious, but not too ambitious. Speak up, but don't be difficult. Lead, but make sure everyone still likes you.  


Joan refused to become smaller. That matters to me because I didn't build C2 by trying to become a female version of the men around me. I built it by understanding what I did well. I knew people. I built relationships. I trusted my instincts. And I refused to believe being different made me less capable.  


Joan showed that breaking through a glass ceiling doesn't mean very much if you have to leave your authentic self underneath it. 

Sheila Johnson: One Success Was Never Going to Be Enough 

Over time, my definition of success changed. At first, success meant survival. Then it meant getting another client. Then hiring an employee. Then getting an office. Then paying my parents back. Eventually, I realized that success wasn't one milestone. It was continuing to build. That is one of the reasons I admire Sheila Johnson. 


Sheila's professional story began far away from the hospitality empire people may associate with her today. She trained as a musician and worked as a music teacher before becoming an entrepreneur. In 1979, she co-founded Black Entertainment Television, or BET, helping build a television network created specifically for Black audiences at a time when both media ownership and corporate leadership offered very few seats at the table to Black women. BET grew into a major media company. That accomplishment alone represented an extraordinary ceiling being broken. Sheila was navigating barriers of both race and gender in an industry where the people controlling networks, investment and executive decisions rarely looked like her. 


But the part of Sheila's story that particularly inspires me is what happened afterward. She didn't decide that one enormous success was enough. She reinvented herself. She moved into hospitality and built Salamander Collection. She expanded her business interests into real estate, entertainment and professional sports ownership. She broke through one ceiling and then walked into another room and started breaking the next one. 


My connection to Sheila is also personal. Salamander Middleburg is close to where I live, and I frequent the property. I have many fond memories there. I've experienced what Sheila built not simply as another entrepreneur studying her career, but as a guest enjoying something another woman had the vision to create. I've also had the privilege of being a guest at her home in Tampa during the Global SOF conference. When I look at Salamander, I see more than a beautiful property. I see reinvention and I understand that instinct. C2 could have been the end of my entrepreneurial story but it wasn't. 


I also built Valorous, applying my experience to another part of the government, defense and intelligence world. There is courage in starting your first company. There is another kind of courage in having already succeeded and deciding you're still not finished.  That's what Sheila represents to me. She broke barriers in media, then hospitality, then sports ownership. Her career reminds me that a glass ceiling isn't always the end of the building. 


Sometimes you break through one floor only to discover how much higher you still want to climb. That's the difference between achieving success and building a legacy. 

Phebe Novakovic: A Woman at the Head of the Table 

There is something different about admiring a woman whose world overlaps with your own. For me, that woman is Phebe Novakovic. Before entering corporate leadership, Phebe built a career that included work in intelligence and senior positions within the federal government. She joined General Dynamics in 2001 and steadily rose through increasingly senior leadership positions before becoming chairman and CEO in 2013. 


That career means something very specific to me. Defense. Government. National security. Federal contracting. Those are worlds I understand. And historically, they have been overwhelmingly male worlds. 


When I was establishing my own career in government contracting in the late 1980s and early 1990s, I remember what those rooms looked like. I remember how few women were sitting at the head of the table. I remember being underestimated. Ignored. Talked over. I remember realizing that being good at my job wasn't always enough to be viewed as an equal. 


Phebe broke through that ceiling in an extraordinary way. She didn't simply find success in a traditionally male industry. 


She became one of the people leading it. 


Today, a woman sits at the top of one of America's largest aerospace and defense companies. That matters. I look to Phebe as a mentor from afar because representation becomes much more powerful when you see someone succeeding within an environment you personally understand. You know the culture. You know the personalities. You understand the pressures. You know how difficult those rooms can be. And then you see a woman sitting at the head of the table. It changes what you believe is possible. 


When I started my career, examples like that were much harder to find. Today, a young woman entering government contracting, defense or national security can look at Phebe and understand that there is no position within this industry that inherently belongs to a man. 


Women need those examples. I needed them. And I hope, in my own much smaller corner of this industry, another woman can look at what I've built and see another example. Because sometimes you never meet the women whose ambitions became a little bigger because they saw what you did first. 

CEO. Entrepreneur. Single Mother. 

Building a company is one accomplishment. Keeping it alive is another. C2 has lived through multiple recessions, economic uncertainty, tremendous changes in government contracting and a global pandemic. 


I've watched companies that once seemed permanent disappear yet C2 continued. That word, continued, means a lot to me. Longevity doesn't happen accidentally. You adapt. You make difficult decisions. You learn. You get things wrong. You fix them. And you keep moving. And while all of that was happening professionally, life wasn't waiting patiently on the sidelines. 


I raised two children as a single mother while running C2 and Valorous. There wasn't one version of me who was the CEO and another who was the mother. Both responsibilities came home with me. Employees depended on me. Clients depended on me. And, most importantly, my children depended on me. 


Women are often told that we can "have it all." I've always thought that phrase makes it sound much easier than it actually is. Sometimes having it all also means carrying it all. There are sacrifices. There are days when you're exhausted. There are business problems you're solving while simultaneously thinking about something one of your children needs. There are moments when you wonder whether you're giving enough to either side. 


But my children were never an obstacle to what I wanted to accomplish. They became part of why accomplishing it mattered. I wanted them to see perseverance. My parents had shown me what it looked like to believe in someone so completely that you were willing to bet your own future on them. 


I wanted my children to understand something similar. Circumstances don't get to decide your future for you. 

Malala Yousafzai: The Future Can Mentor Us Too 

And then there is Malala Yousafzai. Her story reminds me that the glass ceiling doesn't begin in a boardroom. For millions of women and girls around the world, the first ceiling can be far more fundamental. 


The right to learn. 


Malala grew up in Pakistan's Swat Valley and loved school. When the Taliban gained control of the region, girls increasingly lost access to education. Malala refused to quietly accept that future. While she was still a child, she began speaking publicly about girls' right to attend school. In 2012, when she was 15 years old, a Taliban gunman boarded her school bus and shot her in an attempt to silence her. 


She survived. And instead of becoming quieter, she became louder. Her voice became global. She continued advocating for girls' education around the world and, at 17, became the youngest Nobel Peace Prize laureate in history. Malala broke through perhaps the most fundamental glass ceiling of all: 


The belief that being born a girl should determine which opportunities you are allowed to have. 


Her story puts conversations about equality into perspective for me. I think about myself as a little girl hiding behind the classroom door because I was embarrassed to be seen in a different class. Then I think about girls around the world fighting simply for the right to walk through the classroom door. 


Those experiences are worlds apart, but the contrast makes me think deeply about education, opportunity and dignity. What I admire most about Malala isn't simply what she survived. It's what she chose to do afterward. She refused to allow the worst thing that happened to her to become the only thing that defined her. And she challenges another assumption I've had about mentorship. 


We tend to look backward for our mentors. Someone older. Someone more experienced. Someone who has already traveled the road. Malala makes me look forward. She reminds me that today's youth can mentor us too. Young women can challenge the assumptions we've carried for decades. They can ask why something still has to be done a certain way. They can refuse to accept compromises previous generations were forced to make. They can demand progress faster than we were taught to expect it. My generation has lessons to give the women coming behind us. But we also need the humility to understand that they have lessons to give us. 


Women should look backward and honor the women who opened doors for us. But we should also look forward. The woman who inspires you next may not be older than you. She may be young enough to be your daughter. 

Breaking Through Is No Longer Enough 

When I was younger, breaking the glass ceiling meant proving I belonged. I wanted to prove that dyslexia didn't determine my intelligence. That not finishing college didn't determine the height of my career. That being a woman didn't determine whether my voice mattered. That starting without wealth didn't determine whether I could become an entrepreneur. That being a single mother didn't mean I had to choose between being there for my children and continuing to build the companies I had created. 


I spent years proving those things. At this stage of my life, I don't feel the same need to prove that I belong in the room. I've spent decades in the room. Now I'm much more interested in the woman walking into it after me. That is what Women's Equality Day means to me today. The women I admire didn't simply achieve impressive things. Each one expanded what another woman could imagine for herself. 


Barbara Corcoran reminds a dyslexic girl struggling in school that she may think differently, but that doesn't mean she should dream smaller. 


Barabra Walters reminds a young woman finding her voice that credibility and authority don't belong to one gender. 


Joan Rivers reminds women that they shouldn't have to erase themselves to succeed in spaces that weren't built for them. 


Sheila Johnson shows that breaking one barrier doesn't mean you've reached the boundary of your ambition. 


Phebe Novakovic reminds women that no corner of the defense industry is too powerful, too established or too traditionally male for a woman to lead 


And Malala reminds all of us that the next generation isn't simply waiting for us to teach them. They are already teaching us. 


Every woman who breaks a ceiling leaves a crack behind. Every woman who walks through makes the opening a little wider. And every woman who reaches the other side has a decision to make. Do we simply celebrate that we made it? Or do we turn around and make it easier for the next woman? I've spent much of my life breaking ceilings. Now I believe my responsibility is different. I want to help remove them. Because the greatest measure of progress won't be how many women become exceptionally good at breaking through glass ceilings. 


It will be whether, someday, the women coming behind us look up and discover that the ceiling is no longer there. That is the legacy I want to leave. And that is what Women's Equality Day means to me. 

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What a Shark, a Comedian and a Nobel Laureate Taught Me About Breaking Barriers

When people talk about breaking the glass ceiling, they often focus on the moment someone finally breaks through. The promotion. The title. The company. The accomplishment. What we don't talk about enough are all the moments that come before it. 


The moments when you're told you aren't qualified enough. When you're the only woman in the room. When someone speaks over you. When you're underestimated. When you watch an opportunity go to someone else because you don't have the right degree or background. When you begin wondering whether the things that make you different are going to keep you from becoming the person you know you can be. I know those moments because I lived them. 


And when I think about Women's Equality Day, I think not only about my own journey, but about the women whose stories have influenced me along the way. Some came before me. Some built their careers alongside my generation. And one is young enough to remind me that inspiration and mentorship don't always come from those who are older than us. They are entrepreneurs, journalists, entertainers, executives and advocates. Their lives could hardly be more different. 


But every one of them encountered a ceiling that told her, in one way or another, this is as far as you are supposed to go. And every one of them kept going and so did I. 

The Girl Hiding Behind the Door 

I grew up in a military family without much money. My father's career as an Army Infantry officer meant our family moved around the world, usually every few years. I was born in Georgia while he was stationed at Fort Benning, and moving became a normal part of childhood. 


Long before I knew what adaptability meant in business, I learned it through life. New schools. New communities. New countries. New people. Every few years, I had to learn how to walk into an unfamiliar environment and find my place. That ability to adapt would eventually become one of my greatest strengths in business. 


But there was another part of my childhood that took much longer to understand. School was difficult for me. This was during a time when children who learned differently weren't necessarily given the understanding or resources available today. I struggled academically and was separated from the other students and sent to another classroom. 


I remember being so embarrassed about being placed with the "slow kids" that I would hide behind the door because I didn't want the other children to see that I was in there. Think about what that teaches a little girl. Before you even understand why you're different, you begin believing that being different is something you should hide. 


For years, I didn't have an explanation for why certain things were harder for me. I simply believed I wasn't as good at them as everyone else. It wasn't until I was around 30, after a family member was diagnosed with dyslexia, that I decided to be evaluated myself. I was dyslexic. Suddenly, so much of my childhood made sense. But something else had happened during all those years when I didn't know. 


I adapted. I learned how to compensate for the things that were difficult by becoming exceptionally good at other things. I learned to remember information. I learned to read people. I learned to communicate. I learned to build relationships. I learned how to understand what someone needed, sometimes before they knew how to articulate it themselves. The thing I had once believed was holding me back had forced me to develop some of the exact abilities that would eventually make me successful in human resources and business. 

Barbara Corcoran: What School Couldn’t Measure 

That's one of the reasons I have always felt such a strong connection to Barbara Corcoran. 


Millions of people know Barbara today as one of the original investors on Shark Tank. They see a confident entrepreneur evaluating businesses and deciding which founders deserve her investment. But Barbara's story didn't begin in a boardroom. 


She has spoken openly about struggling academically because of dyslexia. She moved through numerous jobs as a young woman before eventually finding her place in real estate. With a $1,000 loan, Barbara started a tiny real estate company in New York City. That business eventually became The Corcoran Group, one of the best-known names in New York real estate. She would later sell the company and build another chapter of her career as an investor, author and television personality. 


What Barbara broke through wasn't simply the traditional glass ceiling facing women in business. She also broke through assumptions about what intelligence and potential are supposed to look like. For someone who grew up with dyslexia, that means something to me. When you struggle in school, it can be very easy to confuse learning differently with being less capable. I spent part of my childhood believing that. 


Barbara's story demonstrates the opposite. She figured out what she did exceptionally well and built around those strengths. So did I. Our careers and businesses are very different, but I recognize something in her journey. 


Neither of us followed the traditional roadmap people associate with becoming successful businesswomen. Neither of us allowed dyslexia to write the ending of our stories. And both of us ultimately built companies from very humble beginnings. 


Barbara broke a glass ceiling by proving that the girl who struggled in the classroom could eventually become the woman sitting on the other side of the table investing in other people's dreams. Sometimes the first ceiling you have to break is the one the world taught you to place over yourself. 

Finding the Work That Fit Me 

My career didn't follow a straight line either. I didn't complete college. I originally thought I might become a pediatric nurse because I loved children and helping people. But academics continued to be difficult, particularly in areas like math and chemistry, and eventually I changed direction. 


Like a lot of young people, I moved between possibilities before realizing where I belonged. That place was human resources. I had actually gotten an early glimpse of HR while my family was stationed in Germany. During a summer job in the Civilian Personnel Office, I watched a woman who genuinely loved helping people solve problems. I remember the joy she got from her work. People would walk in with problems, and she wanted to help fix them. I could see myself doing that. 


Eventually, I found my way back to HR professionally and into the government contracting world. And I discovered that I was good at it. I understood people. I built relationships. People trusted me. I could walk into different environments and adapt, something I had been practicing without realizing it since childhood. But being good at your job and being allowed to advance weren't always the same thing. I was told I was talented,  was told I did great work. But I was also told that because I didn't have a college degree, there were positions I couldn't reach. 


Then there was another reality. I was a woman building a career in the government contracting world of the late 1980s and early 1990s. It was overwhelmingly male. I knew what it felt like to be underestimated. I knew what it was like not to have a voice. I was ignored. I was talked over. I was excluded. 


There were rooms where you understood very quickly that some of the men around the table did not necessarily see you as their equal. I began to understand that there really was a glass ceiling above me. But there was another message I had grown up hearing that eventually became part of how I approached business and life: 


Failure is not an option. 


If someone else had already decided how high I was allowed to go, perhaps I needed to stop asking for permission to go higher. 

Barbara Walters: A Voice That Changed Who Got to Ask the Questions 

During those years, women like Barbara Walters mattered to me. Today, it is easy to turn on the television and see women anchoring major news programs, interviewing presidents and leading conversations about politics, culture and world events. 


That was not always the case. Barbara Walters built her career in an era when broadcast journalism, particularly its most prestigious positions, was overwhelmingly controlled by men. She began working behind the scenes in television before joining NBC's Today show in the early 1960s. Even as her role grew, women in television news were often expected to cover lighter stories while their male colleagues were given the most serious assignments.  


Barbara kept pushing beyond those expectations. She became the first female co-host of Today. Then, in 1976, she made television history when she joined ABC Evening News and became the first woman to co-anchor a network evening news program. Later, she became a longtime presence on 20/20 and, in 1997, created The View, building a program around women having direct, sometimes difficult conversations about the issues of the day. 


Over the course of her career, Barbara interviewed presidents, heads of state, celebrities and some of the most recognizable figures in the world. Her ability to secure important interviews became one of the defining characteristics of her career. But what I admired most wasn't simply who she interviewed. It was the authority she earned to ask the questions. For generations, the person sitting across from a president, a world leader or another powerful figure was usually a man. 


Barbara changed that image. She demonstrated that a woman could control the conversation. She could be persistent. She could challenge someone powerful. She could ask an uncomfortable question and wait for the answer. And she could do all of it without becoming someone else in order to be taken seriously. 


Most importantly to me, people trusted her. That was the part of Barbara's career that stayed with me. I was learning professionally that having something valuable to contribute didn't necessarily mean someone would automatically give me the opportunity to contribute it. Barbara's career demonstrated something different: authority doesn't always have to be given to you. Sometimes you build it until people can no longer ignore it. 


And she did more than break through for herself. By becoming the first woman to co-anchor   network evening newscast, she changed what millions of Americans saw when they imagined a person with authority. Later, with The View, she helped create a table specifically built around women having opinions, disagreeing, asking questions and shaping conversations themselves. There is something important about that progression. 


Early in our careers, so much of our energy can be spent trying to prove that we deserve a seat at someone else's table. Eventually, leadership becomes about creating a bigger table. Looking back, I think that is one of the lessons I took from Barbara without fully realizing it at the time. I was reaching a point in my own career where I had demonstrated what I could do. I knew I was good at my work. I knew I understood people. I knew I understood government contractors. And I was beginning to recognize an opportunity that other people weren't seeing.  


The question was whether I was going to continue waiting for someone else to decide what I was qualified to do. Or whether I was finally going to decide for myself. 

When I Stopped Waiting for Permission 

As my career progressed, I started noticing an opportunity. I was working in HR for government contractors and developing relationships throughout the federal contracting community. Small businesses were competing for significant government work, but many didn't have the internal infrastructure of the larger companies they were competing against. They needed sophisticated HR support, but many couldn't justify building entire HR departments. 


There was a gap. And I couldn't stop thinking about it. 


Eventually, I went to the Library of Congress to research an idea I genuinely thought I had invented. What if one organization could provide these businesses with the HR infrastructure and services they needed? Then I discovered something slightly humbling. I hadn't invented it. The PEO model already existed. But what I had identified was still important. The model wasn't being widely used to serve the Washington-area federal contracting community in the way I envisioned. So instead of being discouraged that someone had gotten there first, I started asking a different question: 


Why couldn't I be the one to bring it to the market I knew? 


In 1996, at 32 years old, I started C2. There was no beautiful corporate headquarters. There wasn't a large staff waiting for me. There wasn't a giant pool of investment capital. 


There was my townhouse. There was me. And there were my parents. 


My parents weren't wealthy investors. After my father retired from the military, they invested their retirement money into a chicken farm. When I needed funding to start my company, they took a loan against that farm and gave me $100,000. I agreed to repay every dollar with interest. 


I remember asking my father what would happen if I failed. The answer, underneath a joke about him and my mother having to walk chickens for the rest of their lives, was the same message he had taught me throughout my life. Failure wasn't an option. So I got to work. 


When I say I ran the company, I mean I ran the company. HR, payroll, accounting, sales, client relationships, research, and operations. If something needed to happen, there wasn't another department I could send it to, I was the department. 


Entrepreneurship looks very different when you're living through it than it does when someone tells the success story decades later. The beginning wasn't glamorous. It was long hours, uncertainty, responsibility, and knowing my parents had put their own financial security behind their belief in me. 


But slowly, the things I had imagined started becoming real. I hired my first employee. We added clients. We hired more people. And eventually, C2 had an office. I remember what that represented to me. I could physically walk through a door and see what all of those years of work had created. C2 wasn't an idea being run out of my basement anymore. It was a company. And one of the accomplishments that meant the most to me had nothing to do with an award or title. 


It was that I paid my parents back every dollar including the interest. 

Joan Rivers: Never Make Yourself Smaller  

As C2 grew, I faced a different challenge. Starting a company is one thing. Deciding what kind of leader you're going to become is another. That is one of the reasons I have always admired Joan Rivers. 


Joan entered American comedy during the 1960s, when stand-up and late-night television were overwhelmingly male worlds. She spent years performing in clubs before receiving a major break on The Tonight Show. She eventually became Johnny Carson's permanent guest host and, in 1986, became the first woman to host a late-night network television talk show. Think about the significance of that. A chair historically occupied by men suddenly had a woman sitting in it. That was a glass-ceiling moment. But Joan's career wasn't a straight line upward. Her late-night show ended. Professional relationships collapsed. She experienced rejection, criticism and periods when many people might have assumed her career was finished. Joan rebuilt again and again. She returned to television. She performed. She wrote. She reinvented herself for new audiences. And she continued working for decades.  


But what I admire most is that through all those reinventions, Joan remained unmistakably Joan. She was outspoken. She was sharp. She was fearless. She worked relentlessly. She took risks. She could laugh at herself. And she didn't ask permission to take up space. That was another ceiling she helped break. 


Women entering male-dominated spaces have historically been expected to adapt themselves to make everyone else comfortable. Be confident, but not intimidating. Be ambitious, but not too ambitious. Speak up, but don't be difficult. Lead, but make sure everyone still likes you.  


Joan refused to become smaller. That matters to me because I didn't build C2 by trying to become a female version of the men around me. I built it by understanding what I did well. I knew people. I built relationships. I trusted my instincts. And I refused to believe being different made me less capable.  


Joan showed that breaking through a glass ceiling doesn't mean very much if you have to leave your authentic self underneath it. 

Sheila Johnson: One Success Was Never Going to Be Enough 

Over time, my definition of success changed. At first, success meant survival. Then it meant getting another client. Then hiring an employee. Then getting an office. Then paying my parents back. Eventually, I realized that success wasn't one milestone. It was continuing to build. That is one of the reasons I admire Sheila Johnson. 


Sheila's professional story began far away from the hospitality empire people may associate with her today. She trained as a musician and worked as a music teacher before becoming an entrepreneur. In 1979, she co-founded Black Entertainment Television, or BET, helping build a television network created specifically for Black audiences at a time when both media ownership and corporate leadership offered very few seats at the table to Black women. BET grew into a major media company. That accomplishment alone represented an extraordinary ceiling being broken. Sheila was navigating barriers of both race and gender in an industry where the people controlling networks, investment and executive decisions rarely looked like her. 


But the part of Sheila's story that particularly inspires me is what happened afterward. She didn't decide that one enormous success was enough. She reinvented herself. She moved into hospitality and built Salamander Collection. She expanded her business interests into real estate, entertainment and professional sports ownership. She broke through one ceiling and then walked into another room and started breaking the next one. 


My connection to Sheila is also personal. Salamander Middleburg is close to where I live, and I frequent the property. I have many fond memories there. I've experienced what Sheila built not simply as another entrepreneur studying her career, but as a guest enjoying something another woman had the vision to create. I've also had the privilege of being a guest at her home in Tampa during the Global SOF conference. When I look at Salamander, I see more than a beautiful property. I see reinvention and I understand that instinct. C2 could have been the end of my entrepreneurial story but it wasn't. 


I also built Valorous, applying my experience to another part of the government, defense and intelligence world. There is courage in starting your first company. There is another kind of courage in having already succeeded and deciding you're still not finished.  That's what Sheila represents to me. She broke barriers in media, then hospitality, then sports ownership. Her career reminds me that a glass ceiling isn't always the end of the building. 


Sometimes you break through one floor only to discover how much higher you still want to climb. That's the difference between achieving success and building a legacy. 

Phebe Novakovic: A Woman at the Head of the Table 

There is something different about admiring a woman whose world overlaps with your own. For me, that woman is Phebe Novakovic. Before entering corporate leadership, Phebe built a career that included work in intelligence and senior positions within the federal government. She joined General Dynamics in 2001 and steadily rose through increasingly senior leadership positions before becoming chairman and CEO in 2013. 


That career means something very specific to me. Defense. Government. National security. Federal contracting. Those are worlds I understand. And historically, they have been overwhelmingly male worlds. 


When I was establishing my own career in government contracting in the late 1980s and early 1990s, I remember what those rooms looked like. I remember how few women were sitting at the head of the table. I remember being underestimated. Ignored. Talked over. I remember realizing that being good at my job wasn't always enough to be viewed as an equal. 


Phebe broke through that ceiling in an extraordinary way. She didn't simply find success in a traditionally male industry. 


She became one of the people leading it. 


Today, a woman sits at the top of one of America's largest aerospace and defense companies. That matters. I look to Phebe as a mentor from afar because representation becomes much more powerful when you see someone succeeding within an environment you personally understand. You know the culture. You know the personalities. You understand the pressures. You know how difficult those rooms can be. And then you see a woman sitting at the head of the table. It changes what you believe is possible. 


When I started my career, examples like that were much harder to find. Today, a young woman entering government contracting, defense or national security can look at Phebe and understand that there is no position within this industry that inherently belongs to a man. 


Women need those examples. I needed them. And I hope, in my own much smaller corner of this industry, another woman can look at what I've built and see another example. Because sometimes you never meet the women whose ambitions became a little bigger because they saw what you did first. 

CEO. Entrepreneur. Single Mother. 

Building a company is one accomplishment. Keeping it alive is another. C2 has lived through multiple recessions, economic uncertainty, tremendous changes in government contracting and a global pandemic. 


I've watched companies that once seemed permanent disappear yet C2 continued. That word, continued, means a lot to me. Longevity doesn't happen accidentally. You adapt. You make difficult decisions. You learn. You get things wrong. You fix them. And you keep moving. And while all of that was happening professionally, life wasn't waiting patiently on the sidelines. 


I raised two children as a single mother while running C2 and Valorous. There wasn't one version of me who was the CEO and another who was the mother. Both responsibilities came home with me. Employees depended on me. Clients depended on me. And, most importantly, my children depended on me. 


Women are often told that we can "have it all." I've always thought that phrase makes it sound much easier than it actually is. Sometimes having it all also means carrying it all. There are sacrifices. There are days when you're exhausted. There are business problems you're solving while simultaneously thinking about something one of your children needs. There are moments when you wonder whether you're giving enough to either side. 


But my children were never an obstacle to what I wanted to accomplish. They became part of why accomplishing it mattered. I wanted them to see perseverance. My parents had shown me what it looked like to believe in someone so completely that you were willing to bet your own future on them. 


I wanted my children to understand something similar. Circumstances don't get to decide your future for you. 

Malala Yousafzai: The Future Can Mentor Us Too 

And then there is Malala Yousafzai. Her story reminds me that the glass ceiling doesn't begin in a boardroom. For millions of women and girls around the world, the first ceiling can be far more fundamental. 


The right to learn. 


Malala grew up in Pakistan's Swat Valley and loved school. When the Taliban gained control of the region, girls increasingly lost access to education. Malala refused to quietly accept that future. While she was still a child, she began speaking publicly about girls' right to attend school. In 2012, when she was 15 years old, a Taliban gunman boarded her school bus and shot her in an attempt to silence her. 


She survived. And instead of becoming quieter, she became louder. Her voice became global. She continued advocating for girls' education around the world and, at 17, became the youngest Nobel Peace Prize laureate in history. Malala broke through perhaps the most fundamental glass ceiling of all: 


The belief that being born a girl should determine which opportunities you are allowed to have. 


Her story puts conversations about equality into perspective for me. I think about myself as a little girl hiding behind the classroom door because I was embarrassed to be seen in a different class. Then I think about girls around the world fighting simply for the right to walk through the classroom door. 


Those experiences are worlds apart, but the contrast makes me think deeply about education, opportunity and dignity. What I admire most about Malala isn't simply what she survived. It's what she chose to do afterward. She refused to allow the worst thing that happened to her to become the only thing that defined her. And she challenges another assumption I've had about mentorship. 


We tend to look backward for our mentors. Someone older. Someone more experienced. Someone who has already traveled the road. Malala makes me look forward. She reminds me that today's youth can mentor us too. Young women can challenge the assumptions we've carried for decades. They can ask why something still has to be done a certain way. They can refuse to accept compromises previous generations were forced to make. They can demand progress faster than we were taught to expect it. My generation has lessons to give the women coming behind us. But we also need the humility to understand that they have lessons to give us. 


Women should look backward and honor the women who opened doors for us. But we should also look forward. The woman who inspires you next may not be older than you. She may be young enough to be your daughter. 

Breaking Through Is No Longer Enough 

When I was younger, breaking the glass ceiling meant proving I belonged. I wanted to prove that dyslexia didn't determine my intelligence. That not finishing college didn't determine the height of my career. That being a woman didn't determine whether my voice mattered. That starting without wealth didn't determine whether I could become an entrepreneur. That being a single mother didn't mean I had to choose between being there for my children and continuing to build the companies I had created. 


I spent years proving those things. At this stage of my life, I don't feel the same need to prove that I belong in the room. I've spent decades in the room. Now I'm much more interested in the woman walking into it after me. That is what Women's Equality Day means to me today. The women I admire didn't simply achieve impressive things. Each one expanded what another woman could imagine for herself. 


Barbara Corcoran reminds a dyslexic girl struggling in school that she may think differently, but that doesn't mean she should dream smaller. 


Barabra Walters reminds a young woman finding her voice that credibility and authority don't belong to one gender. 


Joan Rivers reminds women that they shouldn't have to erase themselves to succeed in spaces that weren't built for them. 


Sheila Johnson shows that breaking one barrier doesn't mean you've reached the boundary of your ambition. 


Phebe Novakovic reminds women that no corner of the defense industry is too powerful, too established or too traditionally male for a woman to lead 


And Malala reminds all of us that the next generation isn't simply waiting for us to teach them. They are already teaching us. 


Every woman who breaks a ceiling leaves a crack behind. Every woman who walks through makes the opening a little wider. And every woman who reaches the other side has a decision to make. Do we simply celebrate that we made it? Or do we turn around and make it easier for the next woman? I've spent much of my life breaking ceilings. Now I believe my responsibility is different. I want to help remove them. Because the greatest measure of progress won't be how many women become exceptionally good at breaking through glass ceilings. 


It will be whether, someday, the women coming behind us look up and discover that the ceiling is no longer there. That is the legacy I want to leave. And that is what Women's Equality Day means to me. 

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When Your Eyewear Can Record: What Government Contractors Need to Know About AI Wearables 

Smart glasses and AI-enabled wearables are moving from novelty to mainstream technology. For government contractors, that raises an important workplace question: Do your security and acceptable-use policies account for devices that can see, hear, record, transmit, and process information without looking like traditional recording equipment? 


Smart glasses are no longer a futuristic concept. Millions of consumers are using AI-enabled glasses for hands-free photography and video, music, phone calls, and interaction with AI assistants. Now, the technology is expanding beyond glasses. Recent reports indicate Apple is developing AirPods with integrated cameras designed to provide visual information to Siri and support AI features.


Although the reported AirPods are not intended to function as conventional cameras for taking photographs or video—and their release timing remains uncertain—the development illustrates where wearable technology is headed. For employers, particularly government contractors, this is more than a consumer technology story. 

The Workplace Security Question Is Changing 

Government contractors frequently operate in environments where employees may have access to sensitive government, client, company, or employee information. Some employees also work at government or military facilities where cameras, recording devices, personal electronic devices, or other equipment may be prohibited altogether. 


Traditionally, an employer could identify a camera relatively easily: a smartphone, digital camera, or video recorder. 


That becomes more difficult when a camera is incorporated into something that looks like ordinary eyewear—or potentially a pair of wireless earbuds. The issue is not necessarily whether an employee intends to record. The more important question may be: Is the employee bringing or using a device capable of capturing, transmitting, storing, or processing information in an environment where that capability is prohibited? 


That distinction matters. An employee may reasonably believe, “I wasn't taking pictures.” But a facility's security requirement may prohibit cameras or recording-capable devices regardless of whether the employee actually pressed a record button. 

AI Adds Another Layer of Risk 

The concern also extends beyond traditional recording. AI-enabled wearables can potentially use cameras and microphones to interact with the user's surroundings. Meta describes its AI glasses as capable of using the camera to answer questions about what the wearer sees, including identifying objects and translating text. Apple's reported camera-equipped AirPods take the concept in a similar direction: the cameras would reportedly provide information about the wearer's surroundings to Siri rather than simply serving as a conventional camera. 


For a government contractor, that creates a broader information-security question: Can an employee use a wearable AI device to analyze, interpret, translate, summarize, or otherwise process information encountered in a restricted workplace? Even when a device is not designed to save a traditional photograph or video, it may still interact with information that the employee is not authorized to capture or transmit. 

This Is Already Becoming a Workplace Issue 

The concern is not hypothetical. In August 2026, U.S. Immigration and Customs Enforcement reportedly warned employees against using Meta smart glasses while on duty because of concerns that the devices could capture, record, or transmit sensitive information. 


Courts and other organizations have also begun addressing smart glasses specifically. Courts in England and Wales have prohibited their use in courtrooms, and UK cinema operators are implementing restrictions because of concerns about unauthorized recording. The takeaway for government contractors is not that a particular brand of glasses or earbuds should automatically be prohibited. The takeaway is that workplace policies need to keep pace with the technology. 

Are Your Policies Technology-Neutral? 

Many employee handbooks and acceptable-use policies were written when the primary concern was a smartphone camera. Employers should review whether their policies address: 

  • Personal electronic devices in restricted or secure areas 


  • Cameras and recording devices 


  • Smart glasses and other wearable technology 


  • Devices with microphones or cameras 


  • AI-enabled personal devices 


  • Unauthorized recording or photography 


  • Transmission or processing of company, client, or government information 


  • CUI, FCI, classified information, and other controlled information, as applicable 


  • Government-furnished equipment and client-specific security requirements 


  • Requirements imposed by government facilities or contracts 


The goal is not to create a policy that names every new consumer product. Instead, policies should be written broadly enough to address capabilities, not just product names. For example, a policy that says employees may not bring “cameras” into a restricted area may not be as effective as one addressing personal devices capable of recording, capturing, transmitting, storing, or processing information. 

What Should Employers Do Now? 

Government contractors do not necessarily need to wait for the next generation of wearable technology to arrive before reviewing their policies. 

  1. Coordinate with facility and contract requirements - Where employees work at government or military facilities, the facility's requirements should control. Employers should not assume that a device is acceptable simply because it is commercially available or marketed as privacy-conscious. 


  2. Educate employees - Employees may not realize that a pair of glasses or earbuds can contain cameras, microphones, AI functionality, or other capabilities that create security concerns. Training should explain that personal technology restrictions are based on the capabilities of the device—not simply what the employee intends to do with it. 


  3. Make the policy technology-neutral - Avoid relying solely on product names such as “smart glasses,” “Meta glasses,” or “camera-equipped AirPods.” New devices will continue to emerge. Policies should address the underlying risk. 


A New Kind of Workplace Awareness 

Technology is increasingly making cameras, microphones, connectivity, and AI capabilities nearly invisible. 


That does not mean every wearable device represents a security threat. Manufacturers are adding privacy features, including recording indicators and other safeguards. Meta, for example, says its AI glasses use a capture LED to indicate when content is being captured and that newer models disable the camera if the LED is blocked or tampered with.


But an employer's security requirements do not have to depend on a manufacturer's privacy features. For government contractors, the better approach is to establish clear rules based on where employees work, what information they access, and what devices are authorized in that environment. 

The Bottom Line 

For years, workplace security policies asked a relatively simple question: “Are you recording?” 


As AI-enabled wearables become more common, employers may need to ask a broader question: “Can this device capture, transmit, store, or process information that the employee is not authorized to share?” 


For government contractors working with sensitive information or operating in secure facilities, now is a good time to review employee handbooks, acceptable-use policies, information-security policies, and facility-specific procedures. The next workplace recording device may not look like a camera. It may look like a pair of glasses—or a pair of earbuds. 


C2 Essentials helps government contractors navigate the evolving HR, employment, and workplace-compliance landscape. For questions about updating workplace policies or employee communications, contact your C2 HR team. 

Read more

When Your Eyewear Can Record: What Government Contractors Need to Know About AI Wearables 

Smart glasses and AI-enabled wearables are moving from novelty to mainstream technology. For government contractors, that raises an important workplace question: Do your security and acceptable-use policies account for devices that can see, hear, record, transmit, and process information without looking like traditional recording equipment? 


Smart glasses are no longer a futuristic concept. Millions of consumers are using AI-enabled glasses for hands-free photography and video, music, phone calls, and interaction with AI assistants. Now, the technology is expanding beyond glasses. Recent reports indicate Apple is developing AirPods with integrated cameras designed to provide visual information to Siri and support AI features.


Although the reported AirPods are not intended to function as conventional cameras for taking photographs or video—and their release timing remains uncertain—the development illustrates where wearable technology is headed. For employers, particularly government contractors, this is more than a consumer technology story. 

The Workplace Security Question Is Changing 

Government contractors frequently operate in environments where employees may have access to sensitive government, client, company, or employee information. Some employees also work at government or military facilities where cameras, recording devices, personal electronic devices, or other equipment may be prohibited altogether. 


Traditionally, an employer could identify a camera relatively easily: a smartphone, digital camera, or video recorder. 


That becomes more difficult when a camera is incorporated into something that looks like ordinary eyewear—or potentially a pair of wireless earbuds. The issue is not necessarily whether an employee intends to record. The more important question may be: Is the employee bringing or using a device capable of capturing, transmitting, storing, or processing information in an environment where that capability is prohibited? 


That distinction matters. An employee may reasonably believe, “I wasn't taking pictures.” But a facility's security requirement may prohibit cameras or recording-capable devices regardless of whether the employee actually pressed a record button. 

AI Adds Another Layer of Risk 

The concern also extends beyond traditional recording. AI-enabled wearables can potentially use cameras and microphones to interact with the user's surroundings. Meta describes its AI glasses as capable of using the camera to answer questions about what the wearer sees, including identifying objects and translating text. Apple's reported camera-equipped AirPods take the concept in a similar direction: the cameras would reportedly provide information about the wearer's surroundings to Siri rather than simply serving as a conventional camera. 


For a government contractor, that creates a broader information-security question: Can an employee use a wearable AI device to analyze, interpret, translate, summarize, or otherwise process information encountered in a restricted workplace? Even when a device is not designed to save a traditional photograph or video, it may still interact with information that the employee is not authorized to capture or transmit. 

This Is Already Becoming a Workplace Issue 

The concern is not hypothetical. In August 2026, U.S. Immigration and Customs Enforcement reportedly warned employees against using Meta smart glasses while on duty because of concerns that the devices could capture, record, or transmit sensitive information. 


Courts and other organizations have also begun addressing smart glasses specifically. Courts in England and Wales have prohibited their use in courtrooms, and UK cinema operators are implementing restrictions because of concerns about unauthorized recording. The takeaway for government contractors is not that a particular brand of glasses or earbuds should automatically be prohibited. The takeaway is that workplace policies need to keep pace with the technology. 

Are Your Policies Technology-Neutral? 

Many employee handbooks and acceptable-use policies were written when the primary concern was a smartphone camera. Employers should review whether their policies address: 

  • Personal electronic devices in restricted or secure areas 


  • Cameras and recording devices 


  • Smart glasses and other wearable technology 


  • Devices with microphones or cameras 


  • AI-enabled personal devices 


  • Unauthorized recording or photography 


  • Transmission or processing of company, client, or government information 


  • CUI, FCI, classified information, and other controlled information, as applicable 


  • Government-furnished equipment and client-specific security requirements 


  • Requirements imposed by government facilities or contracts 


The goal is not to create a policy that names every new consumer product. Instead, policies should be written broadly enough to address capabilities, not just product names. For example, a policy that says employees may not bring “cameras” into a restricted area may not be as effective as one addressing personal devices capable of recording, capturing, transmitting, storing, or processing information. 

What Should Employers Do Now? 

Government contractors do not necessarily need to wait for the next generation of wearable technology to arrive before reviewing their policies. 

  1. Coordinate with facility and contract requirements - Where employees work at government or military facilities, the facility's requirements should control. Employers should not assume that a device is acceptable simply because it is commercially available or marketed as privacy-conscious. 


  2. Educate employees - Employees may not realize that a pair of glasses or earbuds can contain cameras, microphones, AI functionality, or other capabilities that create security concerns. Training should explain that personal technology restrictions are based on the capabilities of the device—not simply what the employee intends to do with it. 


  3. Make the policy technology-neutral - Avoid relying solely on product names such as “smart glasses,” “Meta glasses,” or “camera-equipped AirPods.” New devices will continue to emerge. Policies should address the underlying risk. 


A New Kind of Workplace Awareness 

Technology is increasingly making cameras, microphones, connectivity, and AI capabilities nearly invisible. 


That does not mean every wearable device represents a security threat. Manufacturers are adding privacy features, including recording indicators and other safeguards. Meta, for example, says its AI glasses use a capture LED to indicate when content is being captured and that newer models disable the camera if the LED is blocked or tampered with.


But an employer's security requirements do not have to depend on a manufacturer's privacy features. For government contractors, the better approach is to establish clear rules based on where employees work, what information they access, and what devices are authorized in that environment. 

The Bottom Line 

For years, workplace security policies asked a relatively simple question: “Are you recording?” 


As AI-enabled wearables become more common, employers may need to ask a broader question: “Can this device capture, transmit, store, or process information that the employee is not authorized to share?” 


For government contractors working with sensitive information or operating in secure facilities, now is a good time to review employee handbooks, acceptable-use policies, information-security policies, and facility-specific procedures. The next workplace recording device may not look like a camera. It may look like a pair of glasses—or a pair of earbuds. 


C2 Essentials helps government contractors navigate the evolving HR, employment, and workplace-compliance landscape. For questions about updating workplace policies or employee communications, contact your C2 HR team. 

Read more

Federal Contractor Cybersecurity Requirements: CMMC, NIST 800-171, FISMA and FedRAMP 

Federal contractors are increasingly subject to cybersecurity requirements designed to protect government information and systems especially if the contractor will handle Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). However, not every federal contractor is subject to every cybersecurity framework. 


The requirements that apply to your organization depend on your contracts, the type of government information you handle, and the systems or services you provide. 

Comparing the Major Requirements 



Requirement / Framework 



When It Generally Applies 



Who It Applies To 



Primary Focus 



Certification / Assessment 



What Contractors Should Do 



NIST SP 800-171 



Contract requires protection of CUI in a nonfederal system 



Contractors handling CUI 



Protecting CUI through specified cybersecurity controls 



Depends on contract; may involve self-assessment or other assessment 



Determine whether the company handles CUI and identify the contract clauses that apply 



CMMC 



Applicable DoD contracts require a CMMC level 



DoD contractors and subcontractors within CMMC scope 



Verification that required cybersecurity practices are implemented 



Level-dependent self-assessment or third-party assessment 



Review DoD contracts and determine whether CMMC requirements apply and what level is required 



FISMA 



Contractor operates a system for or on behalf of a federal agency and applicable federal security requirements apply 



Federal agencies and contractors operating covered federal systems 



Federal information-security programs and risk management 



Federal authorization/Risk Management Framework process, as applicable 



Determine whether the contractor operates a covered federal information system rather than simply performing services for the government 



FedRAMP 



Contractor provides a cloud service to a federal agency that requires FedRAMP authorization 



Cloud service providers 



Security authorization of cloud services used by federal agencies 



FedRAMP authorization 



Determine whether the company provides a cloud service to the federal government and whether the contract requires FedRAMP 



NIST SP 800-53 



Typically associated with federal information systems and federal security authorization 



Federal agencies and covered federal systems/service providers 



Detailed security and privacy controls 



Incorporated into federal authorization processes 



Do not assume 800-53 applies merely because the company is a federal contractor 

The Practical Difference 

Being a federal contractor does not automatically mean an organization is subject to CMMC, NIST SP 800-171, FISMA, or FedRAMP. Applicability depends on the specific contract requirements and the nature of the information, systems, or services involved. 

  • NIST SP 800-171: "We have CUI. What cybersecurity controls must we use to protect it?" 


  • CMMC: "We are a DoD contractor subject to CMMC. How do we demonstrate that we meet the required cybersecurity level?" 


  • FISMA: "We are operating a federal information system. How does the government manage and authorize its security?" 


  • FedRAMP: "We provide a cloud service to the federal government. Has the cloud environment been appropriately assessed and authorized?" 


  • NIST SP 800-53: "What security and privacy controls are used in the federal information-system authorization process?" 


Cost and Time Considerations 

Meeting federal cybersecurity requirements can require a significant investment of both money and internal resources. The actual cost varies substantially based on the organization's size, existing cybersecurity program, number of systems and users, amount of CUI handled, and whether significant technology or infrastructure changes are necessary. For perspective: 

  • CMMC Level 2: Department of Defense estimates indicate approximately $37,000–$49,000 for a Level 2 self-assessment and approximately $105,000–$118,000 for a third-party certification assessment. These figures primarily represent assessment-related costs and should not be viewed as the total cost of implementing the required cybersecurity controls. 


  • NIST SP 800-171: Federal estimates have placed assessment costs at approximately $25,000–$130,000, with remediation costs estimated at approximately $35,000–$115,000, depending on the organization's circumstances. 


  • CMMC Level 2 implementation: Industry and government-industry data indicate that organizations with significant gaps may spend $100,000 or more on implementation, technology, remediation and related costs. Some organizations may require 6–12 months or longer to reach readiness. 


  • FedRAMP: Costs can be substantially higher because FedRAMP involves authorization of an entire cloud service environment. Government studies have identified authorization costs ranging from tens of thousands of dollars to several hundred thousand dollars, with some cloud providers reporting infrastructure costs exceeding $1 million. 


These figures are provided for general planning purposes only. They are not quotes, required spending levels, or guarantees of the cost or time necessary for an individual organization to achieve compliance. The applicable contract requirements, existing security controls, system architecture and scope of the environment will significantly affect the actual cost and timeline.


Organizations considering a new federal contract or cybersecurity certification should evaluate these requirements early in the contracting process because implementation can require substantial IT resources, outside expertise, employee time, technology investments and ongoing maintenance. 

Can Cybersecurity Compliance Costs Be Included in a Proposal? 

Yes. Cybersecurity-related costs may generally be considered as part of a contractor's overall cost of doing business and proposal pricing, where appropriate.


However, including the costs in a proposal does not necessarily allow a contractor to defer compliance until after award. For requirements that are a condition of award, such as applicable CMMC requirements, the contractor may need to demonstrate the required status before receiving the contract.  


This can create a significant burden for small businesses because they may need to invest in cybersecurity technology, personnel, consultants, documentation and assessments before knowing whether they will win the contract. 


The same issue can arise with other federal cybersecurity requirements when compliance or authorization is required before contract performance. Before bidding, Contractors should 

  • Review the solicitation and contract for specific cybersecurity requirements; 


  • Determine whether compliance is a condition of award or a performance requirement; 


  • Identify one-time implementation and recurring compliance costs; 


  • Determine which systems and information are within scope; and 


  • Consult contracts, accounting and cybersecurity professionals regarding appropriate treatment of those costs in the proposal. 


Bottom line: A contractor may be able to account for appropriate cybersecurity costs in its proposal, but pricing those costs into a bid does not substitute for meeting a required cybersecurity or authorization standard before award. 

Recent CMMC Developments and Small Business Impact 

There has been significant discussion regarding the cost, administrative burden and potential impact of federal cybersecurity requirements on small and midsize businesses. Most recently, on July 13, 2026, the Department of War suspended the planned Phase 2 expansion of the CMMC program.


The suspension followed concerns raised by the U.S. Small Business Administration and small-business stakeholders that the cost and administrative burden of CMMC could discourage smaller and nontraditional businesses from participating in the Defense Industrial Base. 


The Department has established a CMMC Reform Task Force to review the program and identify ways to reduce compliance costs and barriers for small and midsize businesses while maintaining appropriate protection of federal information.  

Government Cybersecurity Resources 

The following official government resources may help organizations better understand and evaluate their federal cybersecurity obligations: 

  • NIST SP 800-171 Rev. 3 – Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations — Provides the security requirements for protecting CUI in nonfederal systems and organizations. 


  • NIST SP 800-171A Rev. 3 – Assessing Security Requirements for CUI — Provides assessment procedures and methodology that organizations and assessors can use to evaluate implementation of the NIST SP 800-171 requirements. 


  • NIST SP 1318 – SP 800-171 Rev. 3 Small Business Primer — A practical introduction designed to help small and medium-sized businesses understand and begin implementing the NIST SP 800-171 Rev. 3 requirements. It includes FAQs, implementation tips, examples and additional resources. 


  • NIST Small Business Cybersecurity Webinar – Protecting CUI — A recorded NIST webinar explaining the SP 800-171 Rev. 3 Small Business Primer, including implementation considerations and the relationship between SP 800-171 and SP 800-171A. 


  • NIST Small Business Quick-Start Guides — Provides additional practical cybersecurity guides for small and medium-sized businesses, including the SP 800-171 Rev. 3 Small Business Primer. 


  • FedRAMP.gov — The official federal website for the Federal Risk and Authorization Management Program, including program information, guidance and the FedRAMP Marketplace. 


  • FedRAMP 2026 Consolidated Rules — Provides the current 2026 FedRAMP rules, definitions, timelines and related source material. 


  • FedRAMP Marketplace — Searchable government database of FedRAMP-certified cloud services, authorizing agencies and recognized assessors. 


These resources are provided for informational purposes and are not a substitute for reviewing the cybersecurity requirements incorporated into an organization's specific federal contracts or obtaining advice from qualified cybersecurity or legal professionals. 

What Should Federal Contractors Do? 

Clients should review their current federal contracts and solicitations to determine whether they: 

  • Handle Federal Contract Information (FCI) or Controlled Unclassified Information (CUI); 


  • Perform work under a DoD contract; 


  • Have CMMC requirements incorporated into a contract; 


  • Operate systems on behalf of a federal agency; 


  • Provide cloud services to federal agencies; or 


  • Have specific NIST, FISMA, FedRAMP, or other cybersecurity requirements incorporated into their contracts. 


C2 Essentials’ Role 

C2 can assist clients with identifying HR-related considerations associated with applicable federal-contractor requirements. Cybersecurity compliance determinations—including whether an organization is subject to a particular cybersecurity framework or has satisfied its requirements—should be evaluated by the organization's IT, information-security, compliance, and/or legal professionals. 


Clients that are unsure whether a particular cybersecurity requirement applies to their organization should review the applicable contract provisions and consult with their cybersecurity or legal advisor. 

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Federal Contractor Cybersecurity Requirements: CMMC, NIST 800-171, FISMA and FedRAMP 

Federal contractors are increasingly subject to cybersecurity requirements designed to protect government information and systems especially if the contractor will handle Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). However, not every federal contractor is subject to every cybersecurity framework. 


The requirements that apply to your organization depend on your contracts, the type of government information you handle, and the systems or services you provide. 

Comparing the Major Requirements 



Requirement / Framework 



When It Generally Applies 



Who It Applies To 



Primary Focus 



Certification / Assessment 



What Contractors Should Do 



NIST SP 800-171 



Contract requires protection of CUI in a nonfederal system 



Contractors handling CUI 



Protecting CUI through specified cybersecurity controls 



Depends on contract; may involve self-assessment or other assessment 



Determine whether the company handles CUI and identify the contract clauses that apply 



CMMC 



Applicable DoD contracts require a CMMC level 



DoD contractors and subcontractors within CMMC scope 



Verification that required cybersecurity practices are implemented 



Level-dependent self-assessment or third-party assessment 



Review DoD contracts and determine whether CMMC requirements apply and what level is required 



FISMA 



Contractor operates a system for or on behalf of a federal agency and applicable federal security requirements apply 



Federal agencies and contractors operating covered federal systems 



Federal information-security programs and risk management 



Federal authorization/Risk Management Framework process, as applicable 



Determine whether the contractor operates a covered federal information system rather than simply performing services for the government 



FedRAMP 



Contractor provides a cloud service to a federal agency that requires FedRAMP authorization 



Cloud service providers 



Security authorization of cloud services used by federal agencies 



FedRAMP authorization 



Determine whether the company provides a cloud service to the federal government and whether the contract requires FedRAMP 



NIST SP 800-53 



Typically associated with federal information systems and federal security authorization 



Federal agencies and covered federal systems/service providers 



Detailed security and privacy controls 



Incorporated into federal authorization processes 



Do not assume 800-53 applies merely because the company is a federal contractor 

The Practical Difference 

Being a federal contractor does not automatically mean an organization is subject to CMMC, NIST SP 800-171, FISMA, or FedRAMP. Applicability depends on the specific contract requirements and the nature of the information, systems, or services involved. 

  • NIST SP 800-171: "We have CUI. What cybersecurity controls must we use to protect it?" 


  • CMMC: "We are a DoD contractor subject to CMMC. How do we demonstrate that we meet the required cybersecurity level?" 


  • FISMA: "We are operating a federal information system. How does the government manage and authorize its security?" 


  • FedRAMP: "We provide a cloud service to the federal government. Has the cloud environment been appropriately assessed and authorized?" 


  • NIST SP 800-53: "What security and privacy controls are used in the federal information-system authorization process?" 


Cost and Time Considerations 

Meeting federal cybersecurity requirements can require a significant investment of both money and internal resources. The actual cost varies substantially based on the organization's size, existing cybersecurity program, number of systems and users, amount of CUI handled, and whether significant technology or infrastructure changes are necessary. For perspective: 

  • CMMC Level 2: Department of Defense estimates indicate approximately $37,000–$49,000 for a Level 2 self-assessment and approximately $105,000–$118,000 for a third-party certification assessment. These figures primarily represent assessment-related costs and should not be viewed as the total cost of implementing the required cybersecurity controls. 


  • NIST SP 800-171: Federal estimates have placed assessment costs at approximately $25,000–$130,000, with remediation costs estimated at approximately $35,000–$115,000, depending on the organization's circumstances. 


  • CMMC Level 2 implementation: Industry and government-industry data indicate that organizations with significant gaps may spend $100,000 or more on implementation, technology, remediation and related costs. Some organizations may require 6–12 months or longer to reach readiness. 


  • FedRAMP: Costs can be substantially higher because FedRAMP involves authorization of an entire cloud service environment. Government studies have identified authorization costs ranging from tens of thousands of dollars to several hundred thousand dollars, with some cloud providers reporting infrastructure costs exceeding $1 million. 


These figures are provided for general planning purposes only. They are not quotes, required spending levels, or guarantees of the cost or time necessary for an individual organization to achieve compliance. The applicable contract requirements, existing security controls, system architecture and scope of the environment will significantly affect the actual cost and timeline.


Organizations considering a new federal contract or cybersecurity certification should evaluate these requirements early in the contracting process because implementation can require substantial IT resources, outside expertise, employee time, technology investments and ongoing maintenance. 

Can Cybersecurity Compliance Costs Be Included in a Proposal? 

Yes. Cybersecurity-related costs may generally be considered as part of a contractor's overall cost of doing business and proposal pricing, where appropriate.


However, including the costs in a proposal does not necessarily allow a contractor to defer compliance until after award. For requirements that are a condition of award, such as applicable CMMC requirements, the contractor may need to demonstrate the required status before receiving the contract.  


This can create a significant burden for small businesses because they may need to invest in cybersecurity technology, personnel, consultants, documentation and assessments before knowing whether they will win the contract. 


The same issue can arise with other federal cybersecurity requirements when compliance or authorization is required before contract performance. Before bidding, Contractors should 

  • Review the solicitation and contract for specific cybersecurity requirements; 


  • Determine whether compliance is a condition of award or a performance requirement; 


  • Identify one-time implementation and recurring compliance costs; 


  • Determine which systems and information are within scope; and 


  • Consult contracts, accounting and cybersecurity professionals regarding appropriate treatment of those costs in the proposal. 


Bottom line: A contractor may be able to account for appropriate cybersecurity costs in its proposal, but pricing those costs into a bid does not substitute for meeting a required cybersecurity or authorization standard before award. 

Recent CMMC Developments and Small Business Impact 

There has been significant discussion regarding the cost, administrative burden and potential impact of federal cybersecurity requirements on small and midsize businesses. Most recently, on July 13, 2026, the Department of War suspended the planned Phase 2 expansion of the CMMC program.


The suspension followed concerns raised by the U.S. Small Business Administration and small-business stakeholders that the cost and administrative burden of CMMC could discourage smaller and nontraditional businesses from participating in the Defense Industrial Base. 


The Department has established a CMMC Reform Task Force to review the program and identify ways to reduce compliance costs and barriers for small and midsize businesses while maintaining appropriate protection of federal information.  

Government Cybersecurity Resources 

The following official government resources may help organizations better understand and evaluate their federal cybersecurity obligations: 

  • NIST SP 800-171 Rev. 3 – Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations — Provides the security requirements for protecting CUI in nonfederal systems and organizations. 


  • NIST SP 800-171A Rev. 3 – Assessing Security Requirements for CUI — Provides assessment procedures and methodology that organizations and assessors can use to evaluate implementation of the NIST SP 800-171 requirements. 


  • NIST SP 1318 – SP 800-171 Rev. 3 Small Business Primer — A practical introduction designed to help small and medium-sized businesses understand and begin implementing the NIST SP 800-171 Rev. 3 requirements. It includes FAQs, implementation tips, examples and additional resources. 


  • NIST Small Business Cybersecurity Webinar – Protecting CUI — A recorded NIST webinar explaining the SP 800-171 Rev. 3 Small Business Primer, including implementation considerations and the relationship between SP 800-171 and SP 800-171A. 


  • NIST Small Business Quick-Start Guides — Provides additional practical cybersecurity guides for small and medium-sized businesses, including the SP 800-171 Rev. 3 Small Business Primer. 


  • FedRAMP.gov — The official federal website for the Federal Risk and Authorization Management Program, including program information, guidance and the FedRAMP Marketplace. 


  • FedRAMP 2026 Consolidated Rules — Provides the current 2026 FedRAMP rules, definitions, timelines and related source material. 


  • FedRAMP Marketplace — Searchable government database of FedRAMP-certified cloud services, authorizing agencies and recognized assessors. 


These resources are provided for informational purposes and are not a substitute for reviewing the cybersecurity requirements incorporated into an organization's specific federal contracts or obtaining advice from qualified cybersecurity or legal professionals. 

What Should Federal Contractors Do? 

Clients should review their current federal contracts and solicitations to determine whether they: 

  • Handle Federal Contract Information (FCI) or Controlled Unclassified Information (CUI); 


  • Perform work under a DoD contract; 


  • Have CMMC requirements incorporated into a contract; 


  • Operate systems on behalf of a federal agency; 


  • Provide cloud services to federal agencies; or 


  • Have specific NIST, FISMA, FedRAMP, or other cybersecurity requirements incorporated into their contracts. 


C2 Essentials’ Role 

C2 can assist clients with identifying HR-related considerations associated with applicable federal-contractor requirements. Cybersecurity compliance determinations—including whether an organization is subject to a particular cybersecurity framework or has satisfied its requirements—should be evaluated by the organization's IT, information-security, compliance, and/or legal professionals. 


Clients that are unsure whether a particular cybersecurity requirement applies to their organization should review the applicable contract provisions and consult with their cybersecurity or legal advisor. 

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© 2026 C2 Essentials, All Rights Reserved

We handle payroll, benefits, compliance and risk so you can focus on your business.

C2 Essentials logo

© 2026 C2 Essentials, All Rights Reserved

We handle payroll, benefits, compliance and risk so you can focus on your business.

C2 Essentials logo

© 2026 C2 Essentials, All Rights Reserved

We handle payroll, benefits, compliance and risk so you can focus on your business.