In today’s rapidly evolving digital landscape, safeguarding Controlled Unclassified Information (CUI) is of paramount importance for organizations across the defense industrial base. Properly implementing robust controls is crucial for protecting sensitive information from unauthorized access, disclosure, and misuse. This CMMC nugget outlines controls that affect the personnel security posture of an organization. Each control is designed to mitigate risks associated with handling CUI and ensure compliance with regulatory requirements. By adopting these best practices, organizations can enhance their security posture and protect valuable information assets.
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PS.L2-3.9.1: Screen individuals prior to authorizing access to organizational systems containing CUI.
A comprehensive screening process for new employees, which encompasses background checks, employment history verification, and security clearance confirmation is a best practice.
Implementing comprehensive screening processes can be complex due to the need to balance thoroughness with privacy and legal considerations. Organizations must navigate various regulations and ensure that screening methods are effective without being overly intrusive.
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PS.L2-3.9.2: Ensure that organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers.
Upon employee termination, IT department’s should immediately revoke the employee’s access to all systems and recover any company-issued devices. For internal transfers, access rights should be updated to reflect the new role’s requirements. This ensures the employee only has access to information pertinent to their new position.
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AC.L1-3.1.22: Control information posted or processed on publicly accessible information systems.
An organization implements strict guidelines and approval processes for publishing content on public websites. To ensure no sensitive information is included, only authorized personnel should be allowed to post content and only after a review is completed.
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AC.L2-3.1.15: Employ the principle of least privilege, including for specific security functions and privileged accounts.
Companies should use role-based access controls (RBAC) to ensure employees only have access to the data and systems necessary for their jobs. Privileged accounts must be restricted to a few administrators and monitored for any unusual activity.
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AC.L2-3.1.4: Separate the duties of individuals to reduce the risk of malevolent activity without collusion.
For example, in a financial services firm, the person who processes transactions is not the same person who reconciles accounts. This segregation reduces the risk of fraud, as collusion would be required in order to bypass controls.
Ensuring proper segregation of duties can be challenging, especially in smaller organizations with limited staff. It requires careful role assignment and often additional personnel to effectively separate critical functions, which can impact operational efficiency and resource allocation.
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AC.L2-3.1.9: Limit unsuccessful logon attempts.
Organization may choose to configure IT systems to lock a user account after five unsuccessful login attempts. Requiring an administrator to unlock the account and investigate the cause of the failed attempts would ensure that malicious activity is promptly discovered.
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MP.L2-3.8.7: Control the use of removable media on system components.
Companies should restrict the use of USB drives by disabling USB ports on all workstations. Exceptions can be made for authorized personnel who must use encrypted USB drives registered with the IT department.
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MP.L2-3.8.8: Prohibit the use of portable storage devices when such devices have no identifiable owner.
An organization could implement a policy that only allows the use of company-issued and labeled USB drives. Any unidentified or personal USB drives should be automatically blocked by endpoint security software.
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PE.L2-3.10.6: Enforce safeguarding measures for CUI at alternate work sites (e.g., telework sites).
Companies may provide employees with encrypted laptops and mandate the use of a virtual private network (VPN) in order to access company resources remotely. Additionally, employees might be required to work in a secure environment and follow strict data handling procedures.
Protecting CUI at remote or telework locations can be difficult due to a myriad of reasons. Potential lack of direct control over the physical and network security of those sites. Ensuring consistent application of security measures across different locations requires robust policies, user training, and possibly additional security tools and measures.
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SI.L2-3.14.7: Identify unauthorized use of organizational systems.
A company deploys a security information and event management (SIEM) system that continuously monitors network traffic and user activities. The SIEM system generates alerts for any unusual or unauthorized access attempts, which are then investigated by the security team.
Detecting unauthorized use of systems involves implementing comprehensive monitoring and detection mechanisms. This can be resource-intensive and requires continuous updates and tuning to effectively identify and respond to potential threats without generating excessive false positives.
Implementing stringent Personnel Security controls across various domains is essential for the protection of Controlled Unclassified Information (CUI). From personnel screening to physical safeguards and media protection, each measure plays a vital role in mitigating risks to sensitive data. By adhering to these best practices and continuously evaluating and enhancing security protocols, organizations can effectively defend against potential threats. A proactive approach ensures regulatory compliance and fosters a secure environment where critical information remains protected.
Every organization should take immediate steps to boost security, rectify vulnerabilities, and implement controls essential for securing CUI. Prioritizing the protection of CUI is a fundamental responsibility in safeguarding the future of the defense industrial base, your organization and our national security.