Controlled Unclassified Information (CUI)

What is Controlled Unclassified Information (CUI)?

CUI – Controlled Unclassified Information is information that is owned by the government and is required to be protected from unauthorized access by implementing controls. Whilst this kind of data isn’t classified, the government requires that it is protected according to government standards. 

Previously, information of this type was termed “Sensitive Information” or “For Official Use Only”, and there was no standardization that could provide guidelines on assessing the information. All ambiguity was eliminated when the government defined and introduced the singular term of “CUI”. What was needed was an open and uniform program to manage all unclassified information within the Federal system that requires safeguarding and security controls as required by law, regulation, and policy. 

FISMA tasked NIST with the responsibility to establish non-product specific guidelines and standards to ensure government information is protected properly. NIST responded by publishing NIST 800-53 for Federal Systems and NIST 800- 171 for non-Federal Systems. NIST 800-171 and NIST 800-53 have both received regular updates in line with emerging cyber threats and changing technologies. The NIST 800-171 designates a set of best practices to protect CUI and establish effective cybersecurity programs for non-federal entities. Compliance laws, regulations, and requirements like the CMMC: Cybersecurity Maturity Model Certification, are closely aligned with the NIST SP 800 framework.

CUI compliance (and controlled technical information) strengthens the security of the whole federal supply chain.

CUI is divided into 2 categories: 

• Basic – meaning the authorizing law, regulation, or government-wide policy does not set out specific handling or controls. (Agencies handle CUI Basic according to the uniform set of controls set forth in DoDI 5200.48 and the DoD CUI Registry.)
• Specified – means that a law, policy, or regulation stipulates more than a general requirement to “protect” the information. 

The CUI data is defined in Executive Order 13556;
https://www.govinfo.gov/content/pkg/FR-2010-11-09/pdf/2010-28360.pdf

Who needs to be in compliance with Controlled Unclassified Information? 

All the contractors and subcontractors that are working with the government are contractually obligated to be in compliance with the Defense Federal Acquisition Regulation Supplement (DFARS) 7012 and NIST SP 800-171, controlled unclassified information compliance. If you process or store sensitive unclassified information then the CUI requirements and guidelines must be followed.

How does CUI relate to DFARS and DoD?

CUI that relates directly to the Department of Defense (DoD) is also known as Covered Defense Information. The main purpose of DFARS is to protect the confidentiality of Controlled Unclassified Information (CUI) and these regulations apply to all DoD contractors.

Controlled Unclassified Information Requirements

These are the recommended security requirements for nonfederal systems that process, store, or transmit CUI or that provide protection for such components. NIST 800-171 is made up of 14 control families containing 110 controls. They are concerning a mixture of policies, processes, and configurations, hardware and software. 

1. ACCESS CONTROL 

• Limit information system access to authorized users, processes acting on behalf of authorized users, or devices (including other information systems). 
• Limit information system access to the types of transactions and functions that authorized users are permitted to execute. 
• Control the flow of CUI in accordance with approved authorizations. 
• Separate the duties of individuals to reduce the risk of malevolent activity without collusion. 
• Employ the principle of least privilege, including for specific security functions and privileged accounts. 
• Use non-privileged accounts or roles when accessing nonsecurity functions. 
• Prevent non-privileged users from executing privileged functions and audit the execution of such functions.
• Limit unsuccessful logon attempts. 
• Provide privacy and security notices consistent with applicable CUI rules. 
• Use session lock with pattern-hiding displays to prevent access/viewing of data after a period of inactivity. 
• Terminate (automatically) a user session after a defined condition. 
• Monitor and control remote access sessions. 
• Employ cryptographic mechanisms to protect the confidentiality of remote access sessions. 
• Route remote access via managed access control points. 
• Authorize remote execution of privileged commands and remote access to security-relevant information. 
• Authorize wireless access prior to allowing such connections. 
• Protect wireless access using authentication and encryption. 
• Control connection of mobile devices. 
• Encrypt CUI on mobile devices. 
• Verify and control/limit connections to and use of external information systems. 
• Limit use of organizational portable storage devices on external information systems. 3.1.22 Control information posted or processed on publicly accessible information systems.

2. AWARENESS AND TRAINING 

• Ensure that managers, systems administrators, and users of organizational information systems are made aware of the security risks associated with their activities and of the applicable policies, standards, and procedures related to the security of organizational information systems. 
• Ensure that organizational personnel are adequately trained to carry out their assigned information security-related duties and responsibilities. 
• Provide security awareness training on recognizing and reporting potential indicators of insider threat

3. AUDIT AND ACCOUNTABILITY 

• Create, protect, and retain information system audit records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful, unauthorized, or inappropriate information system activity.
• Ensure that the actions of individual information system users can be uniquely traced to those users so they can be held accountable for their actions. 
• Review and update audited events. 
• Alert in the event of an audit process failure. 
• Correlate audit review, analysis, and reporting processes for investigation and response to indications of inappropriate, suspicious, or unusual activity. 
• Provide audit reduction and report generation to support on-demand analysis and reporting. 
• Provide an information system capability that compares and synchronizes internal system clocks with an authoritative source to generate timestamps for audit records. 
• Protect audit information and audit tools from unauthorized access, modification, and deletion. 
• Limit management of audit functionality to a subset of privileged users.

4. CONFIGURATION MANAGEMENT  

• Establish and maintain baseline configurations and inventories of organizational information systems (including hardware, software, firmware, and documentation) throughout the respective system development life cycles.
• Establish and enforce security configuration settings for information technology products employed in organizational information systems. 
• Track, review, approve/disapprove, and audit changes to information systems. 
• Analyze the security impact of changes prior to implementation. 
• Define, document, approve, and enforce physical and logical access restrictions associated with changes to the information system. 
• Employ the principle of least functionality by configuring the information system to provide only essential capabilities. 
• Restrict, disable, and prevent the use of nonessential programs, functions, ports, protocols, and services. 
• Apply deny-by-exception (blacklist) policy to prevent the use of unauthorized software or denyall, permit-by-exception (whitelisting) policy to allow the execution of authorized software.
• Control and monitor user-installed software.

5. IDENTIFICATION AND AUTHENTICATION 

• Identify information system users, processes acting on behalf of users, or devices. 
• Authenticate (or verify) the identities of those users, processes, or devices, as a prerequisite to allowing access to organizational information systems. 
• Use multi-factor authentication for local and network access to privileged accounts and for network access to non privileged accounts. 
• Ensure that security policies and operational procedures for protecting systems against malware are documented, in use, and known to all affected parties. 
• Prevent reuse of identifiers for a defined period. 
• Disable identifiers after a defined period of inactivity. 
• Enforce a minimum password complexity and change of characters when new passwords are created. 
• Prohibit password reuse for a specified number of generations. 
• Allow temporary password use for system logons with an immediate change to a permanent password. 
• Store and transmit only encrypted representation of passwords.
• Obscure feedback of authentication information.

6. INCIDENT RESPONSE 

• Establish an operational incident-handling capability for organizational information systems that includes adequate preparation, detection, analysis, containment, recovery, and user response activities.
• Track, document, and report incidents to appropriate officials and/or authorities both internal and external to the organization. 
• Test the organizational incident response capability

7. MAINTENANCE 

• Perform maintenance on organizational information systems. 
• Provide effective controls on the tools, techniques, mechanisms, and personnel used to conduct information system maintenance. 
• Ensure equipment removed for off-site maintenance is sanitized of any CUI. 
• Check media containing diagnostic and test programs for malicious code before the media are used in the information system. 
• Require multi factor authentication to establish nonlocal maintenance sessions via external network connections and terminate such connections when nonlocal maintenance is complete. 
• Supervise the maintenance activities of maintenance personnel without required access authorization.

8. MEDIA PROTECTION 

• Protect (i.e., physically control and securely store) information system media containing CUI, both paper and digital. 
• Limit access to CUI on information system media to authorized users. 
• Sanitize or destroy information system media containing CUI before disposal or release for reuse. 
• Mark media with necessary CUI markings and distribution limitations.
• Control access to media containing CUI and maintain accountability for media during transport outside of controlled areas. 
• Implement cryptographic mechanisms to protect the confidentiality of CUI stored on digital media during transport unless otherwise protected by alternative physical safeguards. 
• Control the use of removable media on information system components.
• Prohibit the use of portable storage devices when such devices have no identifiable owner. 
• Protect the confidentiality of backup CUI at storage locations.

9. PERSONNEL SECURITY 

• Ensure that CUI and organizational systems containing CUI are protected.

10. PHYSICAL PROTECTION 

• Limit physical access to organizational information systems.
• Managing Physical Access Devices.
• Enforce safeguarding measures for CUI at alternate work sites.

11. RISK ASSESSMENT 

• Periodically assess the risk to organizational operations (including mission, functions, image, or reputation), organizational assets, and individuals, resulting from the operation of organizational information systems and the associated processing, storage, or transmission of CUI. 
• Scan for vulnerabilities in the information system and applications periodically and when new vulnerabilities affecting the system are identified.
• Remediate vulnerabilities in accordance with assessments of risk

12. SECURITY ASSESSMENT 

• Periodically assess the security controls in organizational information systems to determine if the controls are effective in their application. 
• Develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in organizational information systems.
• Monitor information system security controls on an ongoing basis to ensure the continued effectiveness of the controls.

13. SYSTEM AND COMMUNICATIONS PROTECTION 

• Monitor, control, and protect organizational communications (i.e., information transmitted or received by organizational information systems) at the external boundaries and key internal boundaries of the information systems.
• Employ architectural designs, software development techniques, and systems engineering principles that promote effective information security within organizational information systems. 
• Separate user functionality from information system management functionality. 
• Prevent unauthorized and unintended information transfer via shared system resources.
• Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks. 
• Deny network communications traffic by default and allow network communications traffic by exception (i.e., deny all, permit by exception).
• Prevent remote devices from simultaneously establishing non-remote connections with the information system and communicating via some other connection to resources in external networks.
• Implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission unless otherwise protected by alternative physical safeguards.
• Terminate network connections associated with communications sessions at the end of the sessions or after a defined period of inactivity.
• Establish and manage cryptographic keys for cryptography employed in the information system.
• Employ FIPS-validated cryptography when used to protect the confidentiality of CUI. 
• Prohibit remote activation of collaborative computing devices and provide indication of devices in use to users present at the device. 
• Control and monitor the use of mobile code. 
• Control and monitor the use of Voice over Internet Protocol (VoIP) technologies. 
• Protect the authenticity of communications sessions. 
• Protect the confidentiality of CUI at rest. 

14. SYSTEM AND INFORMATION INTEGRITY

• Identify, report, and correct information and information system flaws in a timely manner. 
• Provide protection from malicious code at appropriate locations within organizational information systems.
• Monitor information system security alerts and advisories and take appropriate actions in response.
• Update malicious code protection mechanisms when new releases are available. 
• Perform periodic scans of the information system and real-time scans of files from external sources as files are downloaded, opened, or executed. 
• Monitor the information system including inbound and outbound communications traffic, to detect attacks and indicators of potential attacks. 
• Identify unauthorized use of the information system.

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