Locating Controlled Unclassified Information (CUI) within a CMMC environment is a critical step for organizations seeking compliance with the Cybersecurity Maturity Model Certification (CMMC) framework. CUI is sensitive but unclassified information that requires protection from unauthorized access, disclosure, or misuse. Failure to properly identify and secure CUI can result in significant risks, including potential data breaches and non-compliance penalties.
THE IMPORTANCE OF LOCATING CUI
Identifying and locating CUI is essential for several reasons:
Scoping the CMMC Assessment: The scope of a CMMC assessment is dictated by the flow of CUI throughout an organization's environment. Properly identifying all locations where CUI resides is crucial for defining the assessment scope and ensuring comprehensive coverage.
Implementing Appropriate Security Controls: Once CUI is located, organizations can implement the necessary security controls and safeguards required by the CMMC framework to protect that information adequately. This includes routing CUI to secure enclaves when that strategy is utilized.
Demonstrating Compliance: During a CMMC assessment, organizations must demonstrate their ability to identify, locate, and protect CUI within their environment. Failure to do so can result in non-compliance findings and potential loss of DoD contracts.
STRATEGIES FOR LOCATING CUI
There are several strategies organizations can employ to locate CUI within their CMMC environment:
Data Discovery and Classification: Utilizing data discovery and classification tools can help organizations identify and categorize CUI across their systems, networks, and storage locations. These tools can scan for specific keywords, data patterns, or metadata that indicate the presence of CUI.
Content Search and Analysis: Organizations can leverage content search and analysis capabilities within their existing systems and applications to locate CUI. For example, Microsoft Purview Content Search can be used to search for CUI within Microsoft 365 environments, including SharePoint, OneDrive, and Exchange.
Manual Identification and Mapping: In some cases, a manual approach may be necessary, particularly for organizations with complex or legacy systems. This involves identifying and mapping the flow of CUI through various processes, systems, and personnel, and documenting the locations where CUI is stored, processed, or transmitted.
Collaboration with Stakeholders: Locating CUI often requires collaboration across different departments and stakeholders within an organization. Engaging with subject matter experts, data owners, and personnel who handle CUI can provide valuable insights and help identify potential CUI repositories.
BEST PRACTICES FOR CUI IDENTIFICATION
To ensure a comprehensive and effective CUI identification process, organizations should consider the following best practices:
Develop a CUI Identification Plan: Establish a structured plan that outlines the scope, methodology, tools, and resources required for locating CUI within the organization.
Provide Training and Awareness: Educate employees on the importance of CUI identification, the types of information that constitute CUI, and their roles and responsibilities in protecting CUI.
Implement Access Controls: Once CUI is located, implement appropriate access controls to ensure that only authorized personnel can access and handle that information.
Continuously Monitor and Update: CUI identification is an ongoing process. Organizations should continuously monitor for changes in their environment and update their CUI inventory accordingly.
By effectively locating CUI within their CMMC environment, organizations can better protect sensitive information, demonstrate compliance with CMMC requirements, and mitigate the risks associated with data breaches and non-compliance.
If you are struggling to find or unconfident in the CUI identification processes, Convergent is here to help! We have helped companies as large as Global 100 firms develop CUI Maintenance Programs to find and manage CUI within their environment and can quickly get your firm on to path to compliance.
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