CUI Scoping

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Controlled Unclassified Information (CUI) Scoping Guidance

Cybersecurity and data protection controls only work if they are applied to the correct assets. That is where scoping comes into play. 

The Unified Scoping Guide (USG) is a free resource that is intended to help organizations define the scope of the sensitive data where it is stored, transmitted and/or processed. This guide will refer to both sensitive and regulated data as “sensitive data” to simplify the concept this document is focused on. This model categorizes system components according to several factors:

  • Whether sensitive data is being stored, processed or transmitted;
  • The functionality that the system component provides (e.g. access control, logging, antimalware, etc.); and
  • The connectivity between the system and the sensitive data environment

The USG can be used to help companies define what is in scope to comply with NIST SP 800-171 and appropriately prepare for a CMMC assessment, since a significant step towards becoming NIST SP 800-171 compliant and being able to pass a CMMC assessment is understanding the scope of the Controlled Unclassified Information (CUI)environment. The USG includes the DoD's CMMC 2.0 Level 2 Scoping Guidance that addresses CUI scoping considerations, but is also useful to address s a broader category of sensitive and regulated data. Why is this important? For many organizations, protecting CUI is just one of many data types that it is legally obligated to protect. 

The Unified Scoping Guide (USG) is intended to help organizations define the scope of the sensitive data where it is stored, transmitted and/or processed. This guide will refer to both sensitive and regulated data as “sensitive data” to simplify the concept this document is focused on. This approach is applicable to the following sensitive data types:

  • Controlled Unclassified Information (CUI)
  • Personally Identifiable Information (PII)
  • Cardholder Data (CHD)
  • Attorney-Client Privilege Information (ACPI)
  • Export-Controlled Data (ITAR / EAR)
  • Federal Contract Information (FCI)
  • Protected Health Information (PHI)
  • Intellectual Property (IP)
  • Student Educational Records (FERPA)
  • Critical Infrastructure Information (CII)
Unified Scoping Guide | CUI Scoping Guide | CMMC Scoping Guide | NIST 800-171 Scoping Guide

 

Understanding The Difference Between "Classified" and "Unclassified" Information

It is important to start out by level-setting the understanding that NIST 800-171 and CMMC focus entirely on UNCLASSIFIED data. Where there is common confusion is that UNCLASSIFIED data is broken down into two types and several sub-types, as shown below. 

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Take A Zone-Based Approach To Implementing Data-Centric Security

The Unified Scoping Guide (USG) takes a zone-based approach to scoping, where there are eight (8) zones for sensitive/regulated data compliance purpose.

Unified Scoping Guide (USG) - sensitive and regulated data CUI scoping guide

  1. Sensitive Data Assets: The first zone contains systems, services and applications that directly store, transmit and/or process sensitive data.
  2. Segmenting: The second zone contains “segmenting systems” that provide access (e.g., firewall, hypervisors, etc.).
  3. Security Tools: The third zone contains “security tools” that directly impact the integrity of category 1 and 2 assets (e.g., Active Directory, centralized antimalware, vulnerability scanners, IPS/IDS, etc.).
  4. Connected. The fourth zone contains connected systems. These are systems, embedded technologies, applications or services that have some direct or indirect connection into the sensitive data environment. Systems, embedded technologies, applications and services that may impact the security of (for example, name resolution or web redirection servers) the sensitive data environment are always in scope. Essentially, it something can impact the security of sensitive data, it is in scope.
  5. Out-of-Scope. The fifth zone contains out-of-scope systems that are completely isolated from the sensitive data systems.
  6. Enterprise-Wide. The sixth zone addresses the organization’s overall corporate security program (cyber and physical).
  7. External Service Provider. The seventh zone addresses supply-chain security with the “flow down” of contractual requirements to External Service Providers (ESPs) that can directly or indirectly influence the sensitive data environment. ESPs are third-party organizations that provide services to the organizations.
  8. Subcontractors. The eighth zone addresses subcontractors, which are third-party organizations that are party to the actual execution of the contract where the subcontractor may create, access, receive, store and/or transmit regulated data (sensitive data).

CUI Scoping Tree

The Unified Scoping Guide (USG) includes a "decision tree" to help identify how to categorize your assets, according to CMMC scoping requirements:

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