Overview
  1. 03.01: Access Control
  2. 03.02: Awareness and Training
  3. 03.03: Audit and Accountability
  4. 03.04: Configuration Management
  5. 03.05: Identification and Authentication
  6. 03.06: Incident Response
  7. 03.07: Maintenance
  8. 03.08: Media Protection
  9. 03.09: Personnel Security
  10. 03.10: Physical Protection
  11. 03.11: Risk Assessment
  12. 03.12: Security Assessment
  13. 03.13: System and Communications Protection
  14. 03.14: System and Information Integrity

Security Requirements for 03.08.04 Media Markings

The term security marking refers to the application or use of human-readable security attributes. System media includes digital and non-digital media. Marking of system media reflects applicable federal laws, Executive Orders, directives, policies, and regulations. See [NARA MARK].

Assessment GuidanceExamine 0/7

How an assessor determines this requirement is met. Source: CMMC Assessment Guide – Level 2, Version 2.13 (NIST SP 800-171 Rev. 2).

Discussion

All media, hardcopy and digital, must be properly marked to alert individuals to the presence of CUI stored on the media. The National Archives and Records Administration (NARA) has published guidelines for labeling media of different sizes. 146 MP.L2-3.8.8 requires that media have an identifiable owner, so organizations may find it desirable to include ownership information on the device label as well.

146 NARA, CUI Notice 2019-01: Controlled Unclassified Information (CUI) Coversheets and Labels

Example You were recently contacted by the project team for a new DoD program. The team said they wanted the CUI in use for the program to be properly protected. When speaking with them, you realize that most of the protections will be provided as part of existing enterprise cybersecurity capabilities. They also mentioned that the project team will use several USB drives to share specific data. You explain that the team must ensure the USB drives are externally marked to indicate the presence of CUI [a]. The project team labels the outside of each USB drive with an appropriate CUI label following NARA guidance [a]. Further, the labels indicate that distribution is limited to those employees supporting the DoD program [a].

Assessment Methods

Examine
The process of reviewing, inspecting, observing, studying, or analyzing assessment objects (e.g., policies, procedures, plans, system designs, mechanisms) to facilitate understanding, achieve clarification, or obtain evidence.Example: An assessor reads the access control policy and inspects system configuration settings to confirm they match.

Not all of the evidence listed is required to meet this requirement — check the items your organization has collected.

Interview
The process of holding discussions with individuals or groups within an organization to facilitate understanding, achieve clarification, or identify the location of evidence.Example: An assessor asks a system administrator to describe how user accounts are approved, reviewed, and disabled.
  • Personnel with system media protection and marking responsibilities
  • Personnel with information security responsibilities
Test
The process of exercising assessment objects (e.g., activities, mechanisms) under specified conditions to compare actual behavior with expected behavior.Example: An assessor attempts to sign in with a disabled account to confirm that access is denied.
  • Organizational processes for marking information media
  • Mechanisms supporting or implementing media marking

Potential Assessment Considerations

  • Are all media containing CUI identified [a, b]?

Key References

NIST SP 800-171 Rev. 2 3.8.4

Evidence

  1. 03.08.04.a

    Media containing cui is marked with applicable cui markings

  1. 03.08.04.b

    Media containing cui is marked with distribution limitations