NIST 800-171 and Data Security, Privacy

NIST 800-171, provides a framework for protecting Controlled Unclassified Information (CUI). Certain controls within NIST 800-171 can be interpreted as requiring businesses to carefully manage and secure data exchanges with third parties. Here are the key sections that are relevant:

1. 3.1 Access Control (AC)

- 3.1.2: Limit system access to authorized users, processes acting on behalf of authorized users, or devices (including other systems).

- This requires organizations to ensure that only authorized third parties (e.g., vendors, subcontractors) have access to CUI, necessitating the monitoring and control of such exchanges.

- 3.1.5: Limit the use of organizational systems to process, store, or transmit CUI to authorized locations.

- This control involves ensuring that CUI is only shared with authorized third parties, implying the need to identify and manage third parties who process or store sensitive data.

2. 3.8 Media Protection (MP)

- 3.8.3: Sanitize or destroy information system media containing CUI before disposal or release for reuse.

- When third-party contractors handle media containing CUI, companies must ensure proper data handling and disposal, thus understanding which third parties are involved is crucial.

3. 3.13 System and Communications Protection (SC)

- 3.13.1: Monitor, control, and protect communications (i.e., information transmitted or received by the system) at the external boundaries and key internal boundaries of the information system.

- This implies the need for companies to track the data exchanged with third parties, as those communications must be monitored and controlled.

- 3.13.5: Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks.

- If a third party is involved in accessing public networks or parts of the company's network, proper monitoring and control of their access is required.

4. 3.12 Security Assessment (CA)

- 3.12.1: Periodically assess the security controls in organizational systems to determine if the controls are effective in their application.

- When a company shares CUI with a third party, it must assess the third party’s security controls, which implies the need to disclose and manage the relationship with the third party.

While NIST 800-171 does not mandate explicit disclosure of third-party relationships, it does require stringent controls on how sensitive data is accessed, shared, and processed. Organizations must manage who has access to their systems and data, which effectively implies a need to document and control third-party data exchanges.

To comply with NIST 800-171, companies may find it necessary to track third-party relationships in their data protection strategies, especially where CUI is involved.

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