CMMC MP.2.119 - Protect System Media Containing CUI

CMMC MP.2.119 - Protect System Media Containing CUI

Requirement text: MP.2.119: Protect (i.e., physically control and securely store) system media
containing CUI, both paper and digital.

DISCUSSION FROM SOURCE: DRAFT NIST SP 800-171 R2
System media includes digital and non-digital media. Digital media includes diskettes,
magnetic tapes, external and removable hard disk drives, flash drives, compact disks, and
digital video disks. Non-digital media includes paper and microfilm. Protecting digital media
includes limiting access to design specifications stored on compact disks or flash drives in
the media library to the project leader and any individuals on the development team.
Physically controlling system media includes conducting inventories, maintaining
accountability for stored media, and ensuring procedures are in place to allow individuals to
check out and return media to the media library. Secure storage includes a locked drawer,
desk, or cabinet, or a controlled media library.

Access to CUI on system media can be limited by physically controlling such media, which
includes conducting inventories, ensuring procedures are in place to allow individuals to
check out and return media to the media library, and maintaining accountability for all
stored media.

NIST SP 800-111 provides guidance on storage encryption technologies for end user devices.

CMMC CLARIFICATION
Physical CUI includes two types of items:
      • hardcopy (e.g., paper, microfilm); and
      • digital devices (e.g., CD drives, flash drives, video).

You should store physical CUI in a secure location. This location should be accessible only to
those people with the proper permissions. All who access CUI should follow the process for
checking out and returning it.

Example
Your organization has CUI for a specific Army contract. The Army gave you the CUI on a CD.
You store the CD in a locked drawer and you log the CUI CD in an inventory. You also
establish a procedure to check out the CD when your employees need to use it.

References
• NIST SP 800-171 Rev 1 3.8.1
• NIST CSF v1.1 PR.PT-2
• CERT RMM v1.2 KIM:SG2.SP2
• NIST SP 800-53 Rev 4 MP-4
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