Putting the NIST 800-171 Regulation in Context
Today the federal government relies extensively on external contractors and service providers to perform a wide variety of missions and federal business functions. Federal contractors routinely possess and process sensitive information in their systems to deliver the products and services federal agencies require. Information may also be passed from one nonfederal organization to another, such as sharing information with state and local governments or research universities.
From hosting email servers and websites to developing the next generation of equipment for our war fighters, protecting the federal government’s data is critical to the success with which the federal government can carry out its essential functions.
With cybercrime and data breaches continuing to grow, standardization of the methods utilized to protect Controlled Unclassified Information (CUI) were needed. National Institute of Standards and Technology (NIST) Special Publication 800-171 focuses on protecting the confidentiality of CUI in nonfederal systems. CUI is information which is not classified, but according to a law, regulation or government policy, must be protected—or have access controlled. The CUI program addresses many issues, including consistency in marking and identifying CUI, proper safeguarding of the information, and too many restrictions on the availability of certain data.
NIST SP 800-171 re-enforces the point that CUI has the same value and (if compromised) the same impact, regardless of whether the information is handled by a federal or nonfederal organization. Therefore, the security requirements for protecting CUI were developed with the following assumptions:
- Statutory and regulatory requirements for the protection of controlled unclassified information (CUI) are consistent for both federal and nonfederal systems.
- Steps taken to protect CUI are consistent between federal and nonfederal systems.
- The confidentiality impact value for CUI is no less than moderate.
The requirements are derived from Federal Information Processing Standards (FIPS) Publication 200 and the moderate security control baseline of NIST Publication 800-53 (The moderate security control baseline must be used due to the confidentiality impact value of moderate). These requirements have been proven over time to provide an effective means of protecting the confidentiality of federal information and systems. The requirements have been tailored specifically for nonfederal systems and organizations to minimize adverse consequences while allowing them to comply with statutory regulations and consistently implement the required safeguards for protecting CUI. This is not intended to dilute the security requirements but to express them in a manner that allows for and facilitates the application of equivalent safeguarding measures in nonfederal organizations.
Key Provisions of NIST Special Publication 800-171
NIST 800-171 contains fourteen groupings (referred to as “families”) of basic security requirements obtained from FIPS Publication 200. FIPS 200 provides high-level fundamental security requirements for federal information and systems. These families are defined as follows:
Security Families |
|
Access Control |
Media Protection |
Awareness and Training |
Personnel Security |
Auditing and Accountability |
Physical Protection |
Configuration Management |
Risk Assessment |
Identification and Authentication |
Security Assessment |
Incident Response |
System and Communications Policy |
Maintenance |
System and Information Integrity |
Each of these fourteen families may contain one or more derived security requirements taken from the controls in NIST Publication 800-53 which supplement the basic security requirements.
The requirements and controls have been tailored to eliminate:
- Unique federal government items (i.e. primarily the responsibility of the government)
- Items not directly related to protecting the confidentiality of CUI
- Controls expected to be routinely satisfied in the normal course of an organization’s business
Two points to note:
- While NIST SP 800-171 recommends specific security requirements meant to protect CUI residing in these nonfederal systems, it does not alter any Federal Information Security Management Act (FISMA) or NIST security requirements or guidelines that apply to federal agencies.
- A distinction is made between nonfederal organizations that are processing information or operating systems not on the behalf of federal agencies and those that are working on the government’s behalf. Nonfederal agencies collecting data, maintaining data, using systems or operating systems on behalf of a federal agency must comply with FISMA including FIPS Publication 200 and the security controls in NIST Publication 800-53.
Implementing NIST Special Publication 800-171
SP 800-171 does not dictate exactly how the security requirements are to be met. Organizations have the freedom to implement the requirements using software, services or managed services or to implement compensating controls—if the requirement is satisfied.
Once the organization determines how each security family will be addressed, it should create a system security plan which describes how the specified security requirements have been met, or how they are planned to be met. The system security plan should specify system boundaries, operational environments, how the requirements are implemented, and relationships with other systems. In addition, nonfederal organizations should develop a Plan of Actions & Milestones (POA&M) to detail how unfulfilled security requirements and compensating controls will be implemented.
The following section provides a checklist to assist with the implementation of NIST 800-171.
NIST 800-171 Compliance Checklist
Find out what each requirement of NIST 800-171 means and how Fortra solutions can help you comply in the table below or by downloading the checklist.
Requirement |
What It Means |
Access Control |
Limit system access to only authorized users and the processes acting on the behalf of authorized users. Limit system access to the types of transactions and functions that authorized users are permitted to execute. Limitations should include:
How Fortra can assist:
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Awareness and Training |
Ensure managers, system administrators, and users of an organization’s IT assets are made aware of the security risks associated with their activities. Ensure that organizational personnel are adequately trained to carry out their information security-related duties including providing security awareness training on potential indicators of threats. How Fortra can assist:
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Audit and Accountability |
Create, protect, and retain system audit records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful, unauthorized, or inappropriate system activity. Ensure that the actions of individual system users can be uniquely traced to those users so they can be held accountable for their actions. This includes:
How Fortra can assist:
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Configuration Management |
Establish and maintain baseline configurations and inventories of organizational systems (including hardware, software, firmware, and documentation) throughout the respective system development life cycles. Establish and enforce security configuration settings for information technology products employed in organizational systems. This includes ensuring that you can:
How Fortra can assist:
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Identification and Authentication |
Identify system users or processes acting on behalf of users or devices. Authenticate (or verify) the identities of those users, processes, or devices, as a prerequisite to allowing access to organizational systems. This includes the ability to:
How Fortra can assist:
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Incident Response |
Establish an operational incident-handling capability for organizational systems that includes adequate preparation, detection, analysis, containment, recovery, and user response activities. Track, document, and report incidents to appropriate officials and/or authorities both internal and external to the organization. This includes testing the organizational incident response policy. How Fortra can assist:
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Maintenance |
Perform maintenance on organizational systems. Provide effective controls on the tools, techniques, mechanisms, and personnel used to conduct system maintenance, including:
How Fortra can assist:
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Media Protection |
Protect (e.g. physically control and securely store) system media containing CUI, both paper and digital. Limit access to CUI on system media to authorized users. Sanitize or destroy system media containing CUI before disposal or release for reuse, including:
How Fortra can assist:
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Personnel Security |
Screen individuals prior to authorizing access to organizational systems containing CUI. Ensure that CUI and organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers. Fortra can assist:
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Physical Protection |
Limit physical access to organizational systems, equipment, and the respective operating environments to authorized individuals. Protect and monitor the physical facility and support infrastructure for organizational systems, including:
How Fortra can assist:
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Risk Assessment |
Periodically assess the risk to organizational operations (including mission, functions, image, or reputation), organizational assets, and individuals, resulting from the operation of organizational systems and the associated processing, storage, or transmission of CUI. This includes ensuring that you can:
How Fortra can assist:
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Systems and Communications Protection |
Monitor, control, and protect communications (i.e. information transmitted or received by organizational systems) at the external boundaries and key internal boundaries of organizational systems. Employ architectural designs, software development techniques, and systems engineering principles that promote effective information security within organizational systems. This includes:
How Fortra can assist:
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System and Information Integrity |
Identify, report, and correct information and system flaws in a timely manner. Provide protection from malicious code at appropriate locations within organizational systems. Monitor system security alerts and advisories and take appropriate actions in response, such as:
How Fortra can assist:
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→ Download the checklist ←
Take the Next Step
Take the next step toward NIST 800-171 compliance. Our IT and cybersecurity experts would love to talk to you to assess your current needs and help you find the right solution.