Navigating CMMC Compliance: The Crucial Intersection of NIST 800-88 and DCSA CUI Data Sanitization Guidance

As cybersecurity becomes increasingly integral to national security, especially within the defense sector, the U.S. Department of Defense (DoD) has introduced several frameworks to ensure that contractors and suppliers safeguard sensitive data. One of the key standards in this regard is the Cybersecurity Maturity Model Certification (CMMC), a system designed to evaluate and enhance the cybersecurity practices of companies within the DoD supply chain.

As part of the broader effort to protect sensitive information, CMMC compliance also integrates best practices from established standards such as NIST Special Publication 800-88 and DCSA CUI Data Sanitization Guidance. Both of these guidelines are focused on ensuring that sensitive data is security sanitized preventing unauthorized access or recovery.

In this blog post, we will explore the CMMC framework and how it aligns with NIST 800-88 and DCSA CUI data sanitization guidance to ensure organizations handle sensitive data securely, from storage to disposal.

What is CMMC?

The Cybersecurity Maturity Model Certification (CMMC) is a set of standards introduced by the U.S. Department of Defense (DoD) to improve and standardize the cybersecurity practices of organizations within the defense industrial base (DIB). The CMMC framework consists of three levels of certification, ranging from Level 1 (Foundational) to Level 3 (Expert).

For defense contractors, achieving the appropriate level of CMMC certification is essential for securing contracts involving sensitive DoD data, such as Controlled Unclassified Information (CUI). As CMMC expands across the DIB, organizations must adhere to a variety of security protocols, including data sanitization processes, to safeguard CUI throughout its lifecycle.

Why is Data Sanitization Important for CMMC Compliance?

As you go up the CMMC security levels additional controls are added. Media protection at disposition is a Level 1 control and impacts every organization seeking CMMC compliance. 

Media Protection: MP.L1-3.8.3 

"Media Disposal: Sanitize or Destroy information systems media containing Federal Contract Information before disposal or release for reuse."

Assessment Objectives: Determine if systems media containing Federal Contract Information (FCI) is sanitized or destroyed before disposal and system media containing FCI is sanitized before it is released for reuse.

But CMMC does not describe how to sanitize or destroy this data. Even the CMMC references (FAR 52 & NIST 800-171) do not describe how to sanitize or destroy data. They just repeat that contractors should sanitize or destroy information systems media containing FCI. This is where NIST 800-88 guidance and DCSA guidance are useful.

How Does NIST 800-88 Fit into CMMC Compliance?

This is where additional industry standards should be leveraged. NIST Special Publication 800-88 (often referred to as NIST 800-88) is a key guideline for organizations seeking to meet security and data sanitization requirements. NIST 800-88 provides detailed methods for securely sanitizing information from storage devices. It is recognized as the authoritative standard for data sanitization, and its principles are integrated into several compliance frameworks, including CMMC.

Key Elements of NIST 800-88:

1. Clear: Ensures that data is logically overwritten or erased so it can no longer be read or accessed, but without physically destroying the storage medium. NIST recommends this option for media which will be reused within an organization or for organizations with low security obligations.
   
   
   

2. Purge: Involves more aggressive methods, ensuring that the data is rendered irretrievable by using methods such as cryptographic erasure or overwriting. It is important to note that NIST Purge guidance is media specific and using general read-write commands does not qualify. NIST recommends these methods of sanitization for organizations of medium security obligations.
   
   
   

3. Destroy: Involves physically destroying the storage device (e.g., shredding, crushing, or incinerating hard drives) to make data recovery impossible. NIST recommends destruction for organizations with with high security obligations.
   
   
   

4. NIST 800-88 does not define organization's security categorization. It is up to each organization to review their legal and contractual obligations and make their own sanitization decisions. For example, at higher levels (e.g., Level 2 and above), contractors are expected to adopt robust practices of data sanitization to ensure CUI data cannot be accessed post decommissioning of obsolete devices.

5. DCSA CUI Data Sanitization Guidance and CMMC

6. The Defense Counterintelligence and Security Agency (DCSA) provides specific guidelines for the protection and sanitization of Controlled Unclassified Information (CUI), which directly aligns with the broader CMMC framework. The DCSA’s CUI data sanitization guidance emphasizes the importance of ensuring that CUI is not only properly handled but also securely disposed of when it is no longer needed. DCSA's guidance describes destruction methods in great detail and directs organizations to review NIST 800-88 and NSA PM 9-12 for media sanitization decisions.

7. The DCSA’s guidelines reinforce the need to implement both physical and logical sanitization methods to protect CUI throughout its lifecycle, including when it is stored on hard drives, flash drives, and other storage devices. These requirements overlap with the principles outlined in NIST 800-88 and are vital for organizations aiming to meet CMMC standards.

8. Key Elements of DCSA’s CUI Data Sanitization Guidance:

9. Media Sanitization Protocols: DCSA recommends that contractors use industry-standard sanitization tools and practices, ensuring compliance with NIST 800-88 guidelines. While destruction is not required, DCSA CUI guidance does not provide detailed guidance about non-physical destruction techniques.
   
   
   

10. Destruction of Physical Media: When devices such as hard drives or storage media are no longer in use, DCSA goes into detail about methods of physical destruction such as shredding, crushing, or incinerating the devices to ensure that data cannot be reconstructed or recovered. While we can't say destruction is mandated for CUI, DCSA does appear to have a preference.
    
    
    

11. Audit and Documentation: DCSA requires contractors to maintain records of the sanitization process to demonstrate compliance during audits. These records should include details such as the methods used, the date of sanitization, and the personnel involved.
    
    
    

12. Third-Party Data Disposal: If a third-party vendor is used for sanitizing data or destroying media, DCSA requires that the vendor be vetted and adhere to the same standards set by NIST 800-88 and DCSA guidance.
    
    
    

13. The Synergy Between CMMC, NIST 800-88, and DCSA CUI Guidance

14. The interaction between CMMC, NIST 800-88, and DCSA CUI data sanitization guidance creates a robust framework for ensuring that sensitive information, especially CUI, is securely handled and disposed of throughout its lifecycle. Organizations seeking CMMC certification must align their data sanitization practices with these standards to demonstrate that they are taking all necessary precautions to protect sensitive data.

15. Here’s a summary of how these standards work together:

16. CMMC ensures a broad cybersecurity framework, covering the handling, storage, access control, and disposal of sensitive information. Understanding CMMC and staying compliant will become important for companies seeking to do business with the DOD. CMMC provided different levels of guidance for increasing levels of sensitivity; level 1 for any FCI, level 2 for CUI, and level 3 for organizations needing access to classified information. 

17. NIST 800-88 provides the technical guidelines for securely erasing data, focusing on methodologies for clearing, purging, and destroying data on storage devices. NIST 800-88 provides these options, but individual organizations have the obligation to choose appropriate methods depending upon their security categorization and legal obligations.

18. DCSA CUI Data Sanitization Guidance enforces specific data protection and sanitization practices for CUI, ensuring that defense contractors and subcontractors meet the DoD’s data security requirements. While it doesn't say destruction is required, DCSA's guidance goes into destruction methods in great detail.

19. Together, these frameworks help establish a comprehensive approach to protecting sensitive defense information, ensuring that organizations not only implement cybersecurity controls but also adopt effective and verifiable data sanitization practices to protect CUI from unauthorized access or recovery.

20. Conclusion and our Recommendation

21. We specialize in high security on-site data destruction. We have a bias towards destruction but this is our best effort at a recommendation. Get with your organizational leadership and determine what methods of data destruction they are comfortable with. 

22. CMMC Level 1: At minimum follow NIST 800-88 guidance for medium security categorization organizations. Consider physical destruction methods as defined by NIST 800-88. 

23. CMMC Level 2: This is where contractor organizations strongly need to consider physically destroying their data due to now having access to CUI. DCSA's guidance for CUI does not require destruction, but they appear to communicate a preference. We recommend organizations with access to CUI that you play it safe and destroy your old IT hardware.

24. CMMC Level 3: This is where contractor organizations get access to classified hardware. This is when your organization almost certainly will be considered a high security categorization. We strongly recommend you destroy all your old IT hardware and you will certainly have a contractual obligation to destroy classified hardware in accordance with NSA PM 9-12. 

For businesses in the defense industrial base (DIB), achieving CMMC compliance is not just about meeting minimum cybersecurity standards; it’s about demonstrating a serious commitment to data protection, particularly when it comes to sensitive information like CUI. By following the principles outlined in NIST 800-88 and DCSA CUI data sanitization guidance, organizations can ensure that they are taking the necessary steps to meet both CMMC and DoD expectations for data sanitization, protecting against data breaches, and maintaining the trust of their government clients.

Written by Christopher McDevitt with AI assistance.