What Level Of System And Network Configuration Is Required For Cui

Understanding the ISOO CUI Registry

The Information Security Oversight Office (ISOO) maintains a registry of document types considered Controlled Unclassified Information (CUI). The purpose of the ISOO CUI registry is to establish uniform definitions and responsibilities for CUI across government agencies and their contractors. The registry categorizes CUI into groups such as Critical Infrastructure, which includes information like chemical terrorism vulnerability data and SAFETY Act information. All government entities and contractors must adhere to the same rules for marking and protecting documents within these categories to avoid enforcement actions.

Additionally, there is a separate DoD CUI registry that closely mirrors the ISOO registry, with the exception of Immigration-related categories. The DoD registry outlines specific rules and responsibilities for DoD personnel and contractors when handling CUI.

Significance of DoD Instruction 5200.48

DoD Instruction 5200.48 serves as the cornerstone of DoD guidance on safeguarding CUI. It lays out the fundamental structure of the CUI program and highlights key government departments that organizations must be familiar with for reporting and oversight purposes. The instruction details the essential purposes and functions of CUI protection, including rules for marking CUI to indicate the type of information, authorized access, and controlling entities.

Organizations are required to ensure accurate marking of CUI and control access and dissemination as specified. For instance, documents marked “FEDCON” can be shared with federal employees and contractors, while “FED ONLY” files are restricted to employees only. All staff handling CUI must undergo mandatory training, including a comprehensive understanding of DODI 5200.48 and related documents.

NIST SP 800-171 for CUI Protection

In addition to DODI 5200.48, compliance with the National Institute of Standards and Technology (NIST) Special Publication 800-171 is crucial for safeguarding CUI as per DoD guidelines. NIST SP 800-171 provides guidance on network security controls that organizations must implement to mitigate threats and vulnerabilities affecting CUI. It outlines 110 individual requirements across 14 families, covering aspects like access control, incident response, and system protection.

Adhering to NIST SP 800-171 is essential for protecting CUI in alignment with Defense Federal Acquisition Regulation Supplement (DFARS) requirements, which are applicable to most DoD entities and contractors.

Role of CMMC in CUI Protection

While DODI 5200.48 and NIST SP 800-171 are vital frameworks for CUI protection, compliance with the Cybersecurity Maturity Model Certification (CMMC) is also mandatory for DoD contractors. CMMC ensures that contractors are well-equipped to safeguard CUI and other sensitive data when engaging with the US military. Contracts with the DoD necessitate contractors to achieve a specific CMMC level based on their exposure to CUI:

• Level 1: Foundational
• Level 2: Advanced
• Level 3: Expert

Implementing the appropriate framework controls and undergoing assessments as per the designated CMMC level requirements is crucial for complying with DoD guidelines on CUI protection.

System and Network Configuration for CUI

As of 2024, a moderate level of system and network configuration is required for handling CUI. Organizations operating within the Defense Industrial Base (DIB) must attain CMMC certification at Level 3 through a Certified Third-Party Assessment Organization (C3PAO). This mandate, outlined in DFARS clauses, ensures that CUI is classified at a moderate level of confidentiality and aligns with DoD instructions.

Compliance with DoDI 8500.01 and 8510.01 is essential for maintaining secure systems and networks that handle CUI effectively.

Conclusion

Ensuring compliance with DoD guidelines for safeguarding Controlled Unclassified Information (CUI) demands a comprehensive understanding of frameworks like the ISOO CUI registry, DODI 5200.48, NIST SP 800-171, and CMMC. Organizations must prioritize training their workforce on these complex systems and seek assistance from DoD compliance advisors like RSI Security to navigate the intricacies of CUI protection.

By adhering to the prescribed regulations and implementing robust system and network configurations, organizations can enhance their cybersecurity posture, mitigate risks, and streamline their compliance with DoD requirements related to CUI protection.