Overview

Security Requirements for 03.08.05 Media Accountability

Controlled areas are areas or spaces for which organizations provide physical or procedural controls to meet the requirements established for protecting systems and information. Controls to maintain accountability for media during transport include locked containers and cryptography. Cryptographic mechanisms can provide confidentiality and integrity protections depending upon the mechanisms used. Activities associated with transport include the actual transport as well as those activities such as releasing media for transport and ensuring that media enters the appropriate transport processes. For the actual transport, authorized transport and courier personnel may include individuals external to the organization. Maintaining accountability of media during transport includes restricting transport activities to authorized personnel and tracking and obtaining explicit records of transport activities as the media moves through the transportation system to prevent and detect loss, destruction, or tampering.

Assessment GuidanceExamine 0/8

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

Discussion

CUI is protected in both physical and digital formats. Physical control can be accomplished using traditional concepts like restricted access to physical locations or locking papers in a desk or filing cabinet. The digitization of data makes access to CUI much easier. CUI can be stored and transported on magnetic disks, tapes, USB drives, CD-ROMs, and so on. This makes digital CUI data very portable. It is important for an organization to apply mechanisms to prevent unauthorized access to CUI due to ease of transport.

Examples

  1. Example 1

    Your team has recently completed configuring a server for a DoD customer. The customer has asked that it be ready to plug in and use. An application installed on the server contains data that is considered CUI. You box the server for shipment using tamper-evident packaging and label it with the specific recipient for the shipment [b]. You select a reputable shipping service so you will get a tracking number to monitor the progress. Once the item is shipped, you send the recipients the tracking number so they can monitor and ensure prompt delivery at their facility.

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 storage responsibilities
  • Personnel with information security responsibilities
  • System or network administrators
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 storing media
  • Mechanisms supporting or implementing media storage and media protection

Potential Assessment Considerations

  • Do only approved individuals have access to media containing CUI [a]?
  • Is access to the media containing CUI recorded in an audit log [b]?
  • Is all CUI data on media encrypted or physically locked prior to transport outside of secure locations [b]?

Key References

NIST SP 800-171 Rev. 2 3.8.5

Evidence

  1. 03.08.05.a

    Access to media containing cui is controlled

  1. 03.08.05.b

    Accountability for media containing cui is maintained during transport outside of controlled areas