LLMPrompt MA.L2-3.7.3

I am a cybersecurity manager working for an organization that is a DoD contractor. I need to implement various security practices that conform to DoD's CMMC program at level 2. The CMMC program stipulates security practices that are based on NIST Special Publication 800-171 R2. For each security practice of CMMC Level 2, I need to show evidence that my organization is in compliance with CMMC. Each security practice has a security requirement and several assessment objectives that support that high-level security requirement.

I am assessing one of the assessment objectives within the practice MA.L2-3.7.3 – EQUIPMENT SANITIZATION. The CMMC program has published the following assessment guidance, so take them into account as you formulate your response. Also refer to the attached CMMC Level 2 Assessment Guide, AssessmentGuideL2v2.pdf, for more context and information about the practice.

A. SECURITY REQUIREMENT: Ensure equipment removed for off-site maintenance is sanitized of any CUI.

B. ASSESSMENT OBJECTIVES: Determine if: [a] equipment to be removed from organizational spaces for off-site maintenance is sanitized of any CUI.

C. ASSESSMENT APPROACHES: I have three assessment approaches for assessing any security practice. They are listed as follows:

C1. Examine: The process of checking, inspecting, reviewing, observing, studying, or analyzing one or more assessment objectives to facilitate understanding, achieve clarification, or obtain evidence. The results are used to support the determination of security safeguard existence, functionality, correctness, completeness, and potential for improvement over time.

C2. Interview: The process of conducting discussion with individuals or groups of individuals in an organization to facilitate understanding, achieve clarification, or lead to the location of evidence. The results are used to support the determination of security safeguard existence, functionality, correctness, completeness, and potential for improvement over time.

C3. Test: The process of exercising one or more assessment objects under specified conditions to compare actual with expected behavior. The results are used to support the determination of security safeguard existence, functionality, correctness, completeness, and potential for improvement over time.

D. ASSESSMENT OBJECTS: Each assessment approach can yield potential assessment objects:

D1. Examine: [SELECT FROM: System maintenance policy; procedures addressing controlled system maintenance; maintenance records; manufacturer or vendor maintenance specifications; equipment sanitization records; media sanitization records; system security plan; other relevant documents or records].

D2. Interview: [SELECT FROM: Personnel with system maintenance responsibilities; personnel with information security responsibilities; personnel responsible for media sanitization; system or network administrators].

D3. Test: [SELECT FROM: Organizational processes for scheduling, performing, documenting, reviewing, approving, and monitoring maintenance and repairs for systems; organizational processes for sanitizing system components; mechanisms supporting or implementing controlled maintenance; mechanisms implementing sanitization of system components].

E. DISCUSSION: This requirement addresses the information security aspects of system maintenance that are performed off-site and applies to all types of maintenance to any system component (including applications) conducted by a local or nonlocal entity (e.g., in-contract, warranty, in-house, software maintenance agreement). NIST SP 800-88 provides guidance on media sanitization.

F. FURTHER DISCUSSION: Sanitization is a process that makes access to data infeasible on media such as a hard drive. The process may overwrite the entire media with a fixed pattern such as binary zeros. In addition to clearing the data an organization could purge (e.g., degaussing, secure erasing, or disassembling) the data, or even destroy the media (e.g., incinerating, shredding, or pulverizing). Performing one of these activities ensures that the data is extremely hard to recover, thus ensuring its confidentiality.

For additional guidance on which specific sanitization actions should be taken on any specific type of media, review the description of the Purge actions given in NIST SP 800-88 Revision 1 – Guidelines for Media Sanitization.

G. Example: You manage your organization’s IT equipment. A recent DoD project has been using a storage array to house CUI. Recently, the array has experienced disk issues. After troubleshooting with the vendor, they recommend several drives be replaced in the array. Knowing the drives may contain CUI, you reference NIST 800-88 Rev. 1 and determine a strategy you can implement on the defective equipment – processing the drives with a degaussing unit [a].Once all the drives have been wiped, you document the action and ship the faulty drives to the vendor.

H. Potential Assessment Considerations: Is there a process for sanitizing (e.g., erasing, wiping, degaussing) equipment that was used to store, process, or transmit CUI before it is removed from the facility for off-site maintenance (e.g., manufacturer or contracted maintenance support) [a]?

I. EVIDENCE TYPES: Finally, I have four evidence types that I can collect. The definitions of the evidence types are as follows:

I1. Artifacts: Tangible and reviewable records that are the direct outcome of a practice or process being performed by a system, person, or persons performing a role in that practice, control, or process. (See CAP Glossary for additional details.)

I2. Document: Any tangible thing which constitutes or contains information and means the original and any copies (whether different from the originals because of notes made on such copies or otherwise) of all writing of every kind and description over which an agency has authority. (See CAP Glossary for additional details.)

I3. Physical Review: An on-premise observation of Evidence.

I4. Screen Share: Live observation ""over the shoulder"" of a user as they share their computer screen while performing a task.

J. KEY REFERENCES: NIST SP 800-171 Rev 2 3.7.3