Is your organization struggling with NIST SP 800-171’s Security Requirement 3.1.22, Publicly Accessible Content?
Did you know this is one requirement applies to normally out-of-scope components while the remaining 109 apply to internal components?
This As the CMMC Churns Understanding the Requirements focuses on 3.1.22, Publicly Accessible Content. The video will lay out the requirement, artifacts you will need to pass a CMMC assessment, and the underlying process we use at Peak InfoSec to support this procedure.
It is HIGHLY recommended everyone watch this video. This is one of the most, misunderstood and falsely skipped over requirements, such that during a Joint Surveillance Voluntary Assessment, the Defense Industrial Base Cybersecurity Assessment Center (DIBCAC) complimented a client when they got this right on the first time and how rare that is.
This As the CMMC Churns was originally recorded live at CMMC Day 2024. Unfortunately, the audio was bad as two audio inputs happened.
3.1.22, Publicly Accessible Content
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3.1.22 |
SECURITY REQUIREMENT Control CUI posted or processed on publicly accessible systems. |
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DISCUSSION In accordance with laws, Executive Orders, directives, policies, regulations, or standards, the public is not authorized access to nonpublic information (e.g., information protected under the Privacy Act, CUI, and proprietary information). This requirement addresses systems that are controlled by the organization and accessible to the public, typically without identification or authentication. Individuals authorized to post CUI onto publicly accessible systems are designated. The content of information is reviewed prior to posting onto publicly accessible systems to ensure that nonpublic information is not included. |
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ASSESSMENT OBJECTIVE Determine if: |
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3.1.22[a] |
individuals authorized to post or process information on publicly accessible systems are identified. |
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3.1.22[b] |
procedures to ensure CUI is not posted or processed on publicly accessible systems are identified. |
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3.1.22 |
a review process is in place prior to posting of any content to publicly accessible systems. |
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3.1.22[d] |
content on publicly accessible systems is reviewed to ensure that it does not include CUI. |
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3.1.22[e] |
mechanisms are in place to remove and address improper posting of CUI. |
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POTENTIAL ASSESSMENT METHODS AND OBJECTS |
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Examine |
[SELECT FROM: Access control policy; procedures addressing publicly accessible content; system security plan; list of users authorized to post publicly accessible content on organizational systems; training materials and/or records; records of publicly accessible information reviews; records of response to nonpublic information on public websites; system audit logs and records; security awareness training records; other relevant documents or records]. |
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Interview |
[SELECT FROM: Personnel with responsibilities for managing publicly accessible information posted on organizational systems; personnel with information security responsibilities]. |
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Test |
[SELECT FROM: Mechanisms implementing management of publicly accessible content]. |
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Social Contact