Benefits:

Reduced Risk of Unauthorized Disclosure: By preventing CUI from being inadvertently uploaded or processed on public systems, organizations minimize the likelihood of unauthorized access and potential breaches. This safeguards sensitive information, protecting government interests and mitigating reputational damage.

Enhanced Compliance: Implementing this control demonstrates an organization's commitment to adhering to CUI protection requirements outlined in government contracts. This can streamline the contracting process and reduce the risk of non-compliance penalties.

Improved Information Security Posture: The control encourages a culture of information security awareness within an organization. By designating authorized individuals for handling CUI and implementing content review processes, organizations establish a robust first line of defense against potential security threats.

Accountability:

Senior Management: Sets the tone: Defines the organization's commitment to CUI protection and enforces compliance with Control 3.1.22 through policies and procedures. Allocates resources: Ensures adequate funding, personnel, and training to implement and maintain controls effectively. Reviews and approves procedures: Ensures designated individuals are authorized to post and review CUI for public platforms. Provides oversight: Monitors compliance and takes corrective actions when necessary.

IT Security Team: Develops and implements procedures: Creates clear guidelines for handling CUI on public systems, including CUI identification, review processes, and access controls. Provides training and guidance: Educates users on identifying CUI, adhering to procedures, and reporting any potential violations. Monitors and audits: Regularly reviews system activity to identify unauthorized CUI posting and implements corrective actions.

System Owners: Implement technical controls: Enforce access controls to restrict unauthorized CUI access on public systems. Identify and label CUI: Clearly identify CUI within systems to facilitate review and control. Maintain system logs: Track access and activity related to CUI on public systems to enable audit and investigation.

Individual Users: Adhere to policies and procedures: Understand their roles and responsibilities regarding CUI handling on public systems. Identify and report potential violations: Recognize unauthorized CUI access or attempts to post CUI and report them promptly. Exercise caution with CUI: Avoid downloading, uploading, or processing CUI on public systems unless explicitly authorized.

Implementation:

Identify Publicly Accessible Systems: Organizations must first define all systems under their control that are accessible to the public without requiring authentication. This includes websites, social media platforms, and any other public-facing portals.

Develop Content Review Processes: Implement procedures to review information before it is posted on publicly accessible systems. This includes training authorized individuals to identify and remove any CUI content, including personal identifiable information (PII) or government-specific details.

Designate Authorized Individuals: Clearly define who is authorized to post information on publicly accessible systems. This helps ensure accountability and prevents unauthorized individuals from inadvertently compromising CUI.

Monitor and Audit: Regularly monitor publicly accessible systems for potential leaks or unauthorized CUI exposure. Additionally, conduct audits to verify the effectiveness of implemented controls and identify areas for improvement.