Requirement text:
MP.1.118: Sanitize or destroy information system media containing Federal Contract Information before disposal or release for reuse.
DISCUSSION FROM SOURCE: DRAFT NIST SP 800-171 R2
This requirement applies to all system media, digital and non-digital, subject to disposal or reuse. Examples include: digital media found in workstations, network components, scanners, copiers, printers, notebook computers, and mobile devices; and non-digital media such as paper and microfilm. The sanitization process removes information from the media such that the information cannot be retrieved or reconstructed. Sanitization techniques, including clearing, purging, cryptographic erase, and destruction, prevent the disclosure of information to unauthorized individuals when such media is released for reuse or disposal. Organizations determine the appropriate sanitization methods, recognizing that destruction may be necessary when other methods cannot be applied to the media requiring sanitization.
Organizations use discretion on the employment of sanitization techniques and procedures for media containing information that is in the public domain or publicly releasable or deemed to have no adverse impact on organizations or individuals if released for reuse or disposal. Sanitization of non-digital media includes destruction, removing CUI from documents, or redacting selected sections or words from a document by obscuring the redacted sections or words in a manner equivalent in effectiveness to removing the words or sections from the document. NARA policy and guidance control sanitization processes for controlled unclassified information. NIST SP 800-88 provides guidance on media sanitization.
CMMC CLARIFICATION
In this case, “media” can mean something as simple as paper, or storage devices like diskettes, disks, tapes, microfiche, thumb drives, CDs and DVDs, and even mobile phones. It is important to see what information is on these types of media. If there is Federal contract information (FCI)—information you or your company got doing work for the Federal government that is not shared publicly)—you or someone in your company should do one of two things before throwing the media away:
•clean or purge the information, if you want to reuse the device; or
•shred or destroy the device so it cannot be read.
See NIST Special Publication 800-88 Revision 1, Guidelines for Media Sanitization for more information.
Example
You are moving into a new office. As you pack for the move, you find some of your old CDs in a file cabinet. When you load the CDs into your computer drive, you see that one has information about an old project your company did for the Department of Defense (DoD). Rather than throw the CD in the trash, you make sure that it is shredded.
Get Audit Ready
How
to pass? Before letting a computer, mobile device, or thumb drive
leave your possession, work with an IT professional to destroy the data
on them. There are three safe ways to destroy hard drives: 1) by
hammering or crushing the data module, 2) by using a special program to
overwrite the data many times, or 3) encrypting the drive with a long
(16+ character) key. Make sure to shred documents and CDs before you
get rid of them.
How to fail? Selling your old work computers to
someone who uses IT forensic techniques to read the sensitive data
stored in them. Let someone borrow a thumb drive which previously stored
sensitive information (even if it was “deleted”). Throw any of these
devices in the trash without destroying the data first.
References
• FAR Clause 52.204-21 b.1.vii
• NIST SP 800-171 Rev 1 3.8.3
• NIST CSF v1.1 PR.DS-3
• CERT RMM v1.2 KIM:SG4.SP3
• NIST SP 800-53 Rev 4 MP-6