Cybersecurity Maturity Model Certification (CMMC) Level 2 requires organizations to implement robust measures to control the flow of Controlled Unclassified Information (CUI). Practice AC.L2-3.1.3, entitle Control CUI Flow, is crucial for achieving compliance with the framework as well as actually achieving the goal of protecting sensitive data to protect the warfighter. Here are key strategies to effectively control CUI flow in accordance with CMMC Level 2:
1. The first step in controlling CUI flow is to accurately identify and classify all CUI within your organization. This involves:
Mapping out how CUI is received, processed, stored, and transmitted
Scanning for and identifying CUI within your environment today
Implementing a data classification framework
Training employees to recognize and handle CUI properly
2. Restrict access to CUI based on the principle of least privilege:
Use role-based access control (RBAC) and Data Loss Prevention (DLP) technologies to limit CUI access to authorized personnel only
Implement multi-factor authentication for accessing systems containing CUI
Continuously review and update access permissions
3. Only authorized locations may contain CUI and this requires CMMC environments to isolate CUI from non-CUI information systems. Doing so requires the following:
Create separate network segments, enclaves, and systems for CUI processing and storage
Use firewalls and other boundary protection devices to control traffic between segments
Leverage DLP and Access Control mechanisms to manage access to CUI
4. Protection is required for CUI both at rest and in transit:
FIPS 140-2 encryption algorithms must be utilized for CUI at rest and in transit
Implement secure protocols like TLS 1.2 or higher for transmitting CUI over networks
Ensure proper key management practices are in place
5. DLP solutions greatly improve the effectiveness of and reduce the administrative overhead to monitor and control CUI movement. This includes:
Implementing content inspection and filtering at network egress points
Use of endpoint DLP to prevent unauthorized copying or transfer of CUI
Setting up alerts for potential CUI exfiltration attempts
6. Establish secure methods for sharing CUI internally and with authorized external parties:
Use FedRAMP authorized products for cloud based storage or transmission of CUI
Ensure FIPS 140-2 compliant encrypted email solutions are in place for sending CUI via email
Utilize secure collaboration platforms with granular access controls for sharing within collaborative platforms such as Microsoft Teams.
7. Control CUI access on mobile devices:
Implement MDM solutions to enforce security policies on mobile devices
Use containerization to separate CUI from personal data on BYOD devices
Enable remote wiping capabilities for lost or stolen devices
8. Maintain comprehensive audit trails of CUI access and movement:
Implement system-wide logging for all CUI-related activities
Regularly review audit logs for suspicious activities
Ensure log integrity and protect against tampering
9. Implement technical measures to control information flow:
Use proxies, gateways, and routers to enforce approved data paths
Implement web content filters to prevent unauthorized CUI transmission
Deploy data loss prevention tools at network boundaries
10. Educate employees on CUI handling procedures:
Conduct regular training sessions on CUI identification and protection
Implement an insider threat awareness program
Provide clear guidelines on approved methods for CUI transmission and storage
11. Develop and maintain an incident response plan specific to CUI breaches:
Define procedures for containing and mitigating CUI-related incidents
Establish a communication plan for reporting CUI breaches to relevant authorities
Conduct regular drills to test and improve the incident response process
By implementing these strategies, organizations can effectively control the flow of CUI and meet CMMC Level 2 requirements. It's important to note that controlling CUI flow is an ongoing process that requires regular assessment and adjustment as threats evolve and organizational needs change. Continuous monitoring, periodic audits, and staying informed about the latest cybersecurity best practices are essential for maintaining robust CUI protection and CMMC compliance.
If you are struggling with the complexities associated with controlling the flow of CUI within your environment, please do not hesitate to reach out to us to speak with an expert today.
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