How To Protect Cui

How To Protect Cui – Important information security contractors must pass through their company’s data network to protect Classified Uncontrolled Information (CUI).

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How To Protect Cui

In the alphabet soup that runs through US Department of Defense (DoD) contracts, there is an acronym that has wide implications across the board and yet is not always well understood.

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CUI is an acronym that stands for Classified Uncontrolled Information. CUI is defined as information stored or created by the government that must be protected and disseminated only using controls consistent with government laws, regulations and policies.

Prior to 2010, CUI was referred to as “official use only” or “sensitive but unclassified” information. At the time there were no standardized guidelines for CUI, so one company might call information “highly sensitive” and another might call it “less sensitive.” Fortunately, lax data security standards are becoming a thing of the past.

Over the past decade, DoD has made efforts to standardize and publish information security standards. It did this not only to keep contractors informed, but also to combat the dramatic increase in cybersecurity attacks on government agencies and companies that do business with the government.

This was the first significant attempt by the federal government to emphasize the importance of CUI and to standardize practice among government departments.

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In October 2009, a major data breach at the National Archives and Records Administration compromised the records of millions of military veterans.

The response was Executive Order 13556, “Unclassified Controlled Information”, issued in November 2010, which created the first program to manage unclassified controlled information.

In November 2011, The Washington Post reported on the accidental release of records from Tricare Health Systems and IT contractor Science Applications International Corporation that compromised the medical records of more than 4.9 million military personnel.

In November 2013 the Office of Government Personnel Management (OPM) was the target of another data hack by two government contractors, US Investigations Services LLC (USIS) and KeyPoint.

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These companies collected sensitive personal data during background checks conducted for OPM as part of the hiring process for new government employees.

The response to the OPM, USIS, and KeyPoint data breaches was Executive Order 13636, which the Obama White House issued in February 2013.

The order was titled “Improving Critical Infrastructure Cybersecurity” and was designed to revamp cyber risk management practices at critical infrastructure.

The order directs the National Institute of Standards and Technology (NIST) to work with the private sector to identify existing voluntary standards and build them into a cybersecurity framework. The plan was to encourage the private sector to voluntarily incorporate the new structure into its operations.

Cui: What You Need To Know

In 2014, OPM was once again the target of a serious data breach. The private sector IT contractor involved this time was Keystone Government Solutions. Millions of SF-86 forms including background checks and highly sensitive personal information and fingerprints were stolen

And creating the NIST Cybersecurity Framework 1.0, which established new and detailed information security protocols to be followed by government departments and their private sector contractors.

From 2015 to the first part of 2021, serious cyber security attacks on Uber have been confirmed.

Government responses include NIST SP 800-171, the Cybersecurity and Infrastructure Security Agency Act, the announcement of the Cybersecurity Maturity Model Certification (CMMC) program, the Defense Federal Acquisition Regulation Supplement interim rule, and the expansion of the official CMMC program.

Nist 800 171 R2

What is important to understand is that these responses to data breaches over the past 10 years represent a concerted effort to protect largely unclassified controlled information. CUI is not classified, but the government has determined that it must be monitored because its release of contaminants is considered a threat to national security.

Announced in November 2020, the CMMC program requires new cybersecurity requirements for the more than 350,000 organizations that make up the Defense Industrial Base (DIB). To continue doing business with DoD, contractors must be CMMC Level 2 and 3 certified by the CMMC Third Party Assessment Organization (C3PAO) by the end of 2025.

DoD launched the CMMC program in response to a significant increase in cybersecurity attacks in recent years. The department considers them a serious threat to the country’s economic and national security. Attacks against SolarWinds, Kaseya, Accenture and Colonial Pipeline are among the most recent examples.

“SolarWinds is a great example,” said Tony Giles, information security specialist at ISR “In December 2020, this large publicly traded company was breached. You can go through their incident response. There’s a lot involved. Information security seems to be on everyone’s mind these days.”

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According to a report by the Center for Strategic and International Studies and information security firm McAfee, cybercrime costs an estimated $600 billion a year, which is about 1% of global GDP. The estimate is up significantly from a 2014 study that estimated annual losses of about $445 billion.

The CMMC program is a key aspect of the Department of Defense’s overall response to emerging cybersecurity threats. It is designed as a verification process to ensure that DIB companies implement proven cybersecurity practices to protect CUI.

The CMMC will be held by the Department of Defense for five years. All contracts beginning in FY 2026 will see the CMMC requirement. This means that all DoD contractors and their supply chain partners must comply in order to bid on future defense contracts.

The CMMC model includes three levels of cybersecurity practices based on NIST SP 800-171 controls. Level 1 represents basic cyber hygiene and focuses on federal contract information security.

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Level 2 CUI focuses on protection. NIST SP 800-171 includes all controls specified at Level 3 for the proactive steps a company can take to detect and respond to threats and is based on a subset of the NIST 800-172 requirements.

One of the objectives of the CMMC program is to protect national information through the protection of controlled unclassified information within the defense industrial base. It is important for DoD contractors to understand the importance of CUI both in the context of the CMMC process and in their own internal operations.

Rhia Dancel, information security specialist at -ISR, describes CUI in these simple terms: “CUI is information created or provided by the government that requires protection and safeguards. CUI is a fundamental part of the CMMC initial assessment and drives the conversation that He does

“The main CUI categories we look at are controlled technical information (CTI) and proprietary manufacturers (MFC),” Dansel adds. “Plans or technical drawings will fall under the CTI category. Manufacturing a part or component based on technical drawings or specifications will fall under the MFC category.”

Implement And Maintain Nist Sp 800 171 Security Protections

For the DoD, creating a comprehensive information security protocol around CUI was a significant step forward. This means making it clear to all DIB companies that certain types of unclassified information are highly sensitive, valuable to the country and susceptible to adversary interception, and therefore require strong protection.

Compared to classified national security information, DoD personnel receive, manage, create, and disseminate CUI from all levels of responsibility and mission areas. Current DoD policy on CUI provides a uniform marking system across federal government departments with detailed instructions on how to mark documents.

DoD guidance describes classified unclassified information as a system for protecting unclassified information and emphasizes that CUI is not a classification between unclassified and secret. In fact, the preferred description is “regulated as CUI” as opposed to “classified as CUI.”

In the ongoing comparison between categorical data and CUI, categorical data gets all the attention. This is not surprising, as the former has been portrayed in successful Hollywood films dealing with espionage.

Dod Cui Categories To Protect For Nist And Dfars Compliance

Dancel suggests that companies ask themselves the following questions to help identify CUI within their organization: “Do you receive information flagged as CUI? Do you receive technical drawings for parts or components manufactured by the government or prime contractor?”

Giles offers this example: “Many CUIs have been created. This can be a part drawing, a stamp or something that can be marked as CUI. And they don’t always seal things. This is something that is communicated as controlled unclassified information.”

The three most sensitive categories of classified government information are classified, confidential, and top secret. These categories indicate the types of information that could cause harm, serious harm or exceptionally serious harm if released and fall into the hands of an adversary.

Controls on classified information are designed to protect various categories of government-owned information, including military plans, weapons systems, information about foreign governments, intelligence gathering activities, and valuable scientific, technical, and economic information.

Nist Compliant Encryption, Safeguarding Cui

Given the critical importance of classified information, it is not surprising that CUI has a low profile.

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