Did you know there are 125 categories of controlled unclassified information (CUI)? With so much data that is now under the umbrella of CUI, ensuring your business recognizes which data to protect is essential. But what exactly is CUI data? Read on to learn about this type of data, how to recognize if you use it in your business, and how you can protect it.
What Is CUI Data?
CUI, or controlled unclassified information, is information that needs safeguarding. It is data that needs to be disseminated in a manner that follows the laws and regulations the government has in place, but that does not fit under Executive Order 13526 “Classified National Security Information”.
CUI is part of a government program that strives to standardize this type of data and ensure it is protected. CUI replaces the old For Official Use Only (FOUO) programs and offers more efficient and consistent policies. If a document had a label of “Proprietary” or “For Official Use Only” in the past, now it needs the CUI label.
CUI is a term that encompasses other kinds of data: Covered Defense Information (CDI) and Controlled Technical Information (CTI). They refer to technical information that applies to a military or space context and which has a distribution statement. The data can be labeled as CUI Basic or CUI Specified, which is more restrictive in its uses and the safeguards it needs.
Examples of CUI Data
Within the 125 categories of data that fit into the CUI label, you can find many subsets of information that need to be protected, but are not classified. The CUI Registry has a list of what type of data must be safeguarded following government policies, laws, and regulations. Some examples include:
- Personally Identifiable Information (PII), which is information that can identify a particular person
- Sensitive Personally Identifiable Information (SPII), which is information that if disclosed without permission could substantially harm or embarrass the person
- Unclassified Controlled Technical Information (UCTI), which refers to data that has a military or space application
- Sensitive But Unclassified (SBU), which is information that does not meet the standards for National Security classification
- Law Enforcement Sensitive (LES), which is data that if disseminated without permission could cause harm to law enforcement procedures
There are many more forms of CUI, and you can expect everything from health records, intellectual property, technical drawings and blueprints, and much more to fall under the label of CUI data.
Identifying CUI Data
If you are an IT professional or are a government contractor of any kind, you will likely have CUI data to worry about. Most of the time, the Department of Defense will label data as CTI or CDI, as needed, but there are instances when the contractor will be creating this kind of data as they complete a project. How do you identify it, then?
Let us look at some of the things to watch for.
Contracts
Does your site have a US government contract or does it supply a US federal contract? If it does, then you most likely have CUI data you will need to safeguard.
Labeled Information
Some data will have a CUI label on it already or will be easy to identify. If you see “Export Control”, which includes information that needs monitoring, such as Export Administration Regulations (EAR) or International Traffic in Arms Regulations (ITAR), then you can expect CUI data. Labeled information refers to non-classified data that has legacy or agency designations, and that is CUI.
Defense Projects
Many Defense Federal Acquisition Regulations (DFAR) deal with CUI. If projects related to aerospace manufacturing have details that are noncommercial and technical, they are CUI. Technical information can refer to engineering and research data. It can also be engineering drawings and plans, technical orders, process sheets, manuals, datasets, studies, and much more. For defense projects that have technical information related to a military or space application, you need the label of CUI.
Non-Defense Projects
Whether there is CUI data in a non-defense federal project depends on the specifics of the project and of the contract. Federal contract information, which is CUI, is information that the government does not want released to the public, and that has been created for the government or provided by the government during a contract.
Protecting CUI Data
There are government policies and guidelines to help you protect CUI data. You have to physically protect the data using key card access or other similar locks. The data and all its backups need labeling and securing when not in use.
At the network layer, the data also needs protection. Firewalls, switches, and routers all have to protect against unauthorized access. You need OSI layers two through four. You have to have session controls in place, as well. The data has to be protected with authentication and authorization mechanisms, and it all has to take place within the control of the data owner. There are also infrastructure controls that can secure CUI data. They can be virtual machines, storage area networks, physical servers, and backup systems.
You will need to have a risk assessment completed, and there must be network scans done periodically. If there are any configuration changes needed to the system that provides access to the CUI, the process needs a documented review and an approval process. Any logs need a third-party audit on a regular basis.
Keep CUI Secure
If you work with CUI data and need the best security, we can help. At Buda Consulting, we deliver secure and reliable database systems, ensuring even the most sensitive data is safe. Contact us now to speak with an expert!
