LLMPrompt MP.L2-3.8.2
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 MP.L2-3.8.2 – MEDIA ACCESS. 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: Limit access to CUI on system media to authorized users.
B. ASSESSMENT OBJECTIVES: Determine if [a] access to CUI on system media is limited to authorized users.
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 media protection policy; procedures addressing media storage; physical and environmental protection policy and procedures; access control policy and procedures; system security plan; system media; designated controlled areas; other relevant documents or records].
D2. Interview: [SELECT FROM: Personnel with system media protection and storage responsibilities; personnel with information security responsibilities].
D3. Test: [SELECT FROM: Organizational processes for storing media; mechanisms supporting or implementing secure media storage and media protection].
E. DISCUSSION: Access can be limited by physically controlling system media and secure storage areas. Physically controlling system media includes conducting inventories, ensuring procedures are in place to allow individuals to check out and return system media to the media library, and maintaining accountability for all stored media. Secure storage includes a locked drawer, desk, or cabinet, or a controlled media library.
F. FURTHER DISCUSSION: Limit physical access to CUI to people permitted to access CUI. Use locked or controlled storage areas and limit access to only those allowed to access CUI. Keep track of who accesses physical CUI in an audit log.
G. Example: Your company has CUI for a specific Army contract contained on a USB drive. In order to control the data, you establish specific procedures for handling the drive. You designate the project manager as the owner of the data and require anyone who needs access to the data to get permission from the data owner [a]. The data owner maintains a list of users that are authorized to access the information. Before an authorized individual can get access to the USB drive that contains the CUI they have to fill out a log and check out the drive. When they are done with the data, they check in the drive and return it to its secure storage location.
H. Potential Assessment Considerations: Is a list of users who are authorized to access the CUI contained on system media maintained [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 3.8.2