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Guidance for NIST 800-171 Assessment & Compliance

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The Need To Assess Security And Privacy Control Effectiveness

Today, more than at any time in history, the federal government is relying on external service providers to help carry out a wide range of federal missions and business functions using state-of-the-practice information systems.1 Many federal contractors, for example, routinely process, store, and transmit sensitive federal information in their systems to support the delivery of essential products and services to federal agencies (e.g., providing credit card and other financial services; providing Web and electronic mail services; conducting background investigations for security clearances; processing healthcare data; providing cloud services; and developing communications, satellite, and weapons systems). Additionally, federal information is frequently provided to or shared with entities such as State and local governments, colleges and universities, and independent research organizations. The protection of sensitive federal information while residing in nonfederal systems2 and organizations is of paramount importance to federal agencies and can directly impact the ability of the federal government to successfully carry out its designated missions and business operations, including those missions and functions related to the critical infrastructure.

The protection of unclassified federal information in nonfederal systems and organizations is dependent on the federal government providing a disciplined and structured process for identifying the different types of information that are routinely used by federal agencies. On November 4, 2010, the President signed Executive Order 13556, Controlled Unclassified Information. The Executive Order established a governmentwide Controlled Unclassified Information (CUI)3 Program to standardize the way the executive branch handles unclassified information that requires protection and designated the National Archives and Records Administration (NARA) as the Executive Agent4 to implement that program. Only information that requires safeguarding or dissemination controls pursuant to federal law, regulation, or governmentwide policy may be designated as CUI.

The CUI Program is designed to address several deficiencies in managing and protecting unclassified information to include inconsistent markings, inadequate safeguarding, and needless restrictions, both by standardizing procedures and by providing common definitions through a CUI Registry. The CUI Registry is the online repository for information, guidance, policy, and requirements on handling CUI, including issuances by the CUI Executive Agent. Among other general descriptions for each, identifies the basis for controls, and sets out procedures for the use of CUI, including but not limited to marking, safeguarding, transporting, disseminating, reusing, and disposing of the information.

Executive Order 13556 also required that the CUI Program emphasize openness, transparency, and uniformity of governmentwide practices, and that the implementation of the program take place in a manner consistent with applicable policies established by the Office of Management and Budget (OMB) and federal standards and guidelines issued by the National Institute of Standards and Technology (NIST). The federal CUI regulation,5 developed by the CUI Executive Agent, provides guidance to federal agencies on the designation, safeguarding, dissemination, marking, decontrolling, and disposition of CUI, establishes self-inspection and oversight requirements, and delineates other facets of the program.

1)An information system is a discrete set of information resources organized expressly for the collection, processing, maintenance, use, sharing, dissemination, or disposition of information. Information systems also include specialized systems for example, industrial/process control systems, cyber-physical systems, embedded systems, and devices. The term system is used throughout this publication to represent all types of computing platforms that can process, store, or transmit CUI.

2)A federal information system is a system that is used or operated by an executive agency, by a contractor of an executive agency, or by another organization on behalf of an executive agency. A system that does not meet such criteria is a nonfederal system.

3)Controlled Unclassified Information is any information that law, regulation, or governmentwide policy requires to have safeguarding or disseminating controls, excluding information that is classified under Executive Order 13526, Classified National Security Information, December 29, 2009, or any predecessor or successor order, or the Atomic Energy Act of 1954, as amended.

4)NARA has delegated this authority to the Information Security Oversight Office, which is a component of NARA.  

5)32 CFR Part 2002, Controlled Unclassified Information, issued September 14, 2016; effective November 14, 2016.  

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