DISCUSSION [NIST SP 800-171 R2]

In accordance with laws, Executive Orders, directives, policies, regulations, or standards, the public is not authorized access to nonpublic information (e.g., information protected under the Privacy Act, FCI, and proprietary information). This requirement addresses systems that are controlled by the organization and accessible to the public, typically without identification or authentication. Individuals authorized to post FCI onto publicly accessible systems are designated. The content of information is reviewed prior to posting onto publicly accessible systems to ensure that nonpublic information is not included.

Further Discussion

Do not allow FCI to become public – always safeguard the confidentiality of FCI by controlling the posting of FCI on company-controlled websites or public forums, and the exposure of FCI in public presentations or on public displays. It is important to know which users are allowed to publish information on publicly accessible systems, like your company website, and implement a review process before posting such information. If FCI is discovered on a publicly accessible system, procedures should be in place to remove that information and alert the appropriate parties.

Example 1

Your company decides to start issuing press releases about its projects in an effort to reach more potential customers. Your company receives FCI from the government as part of its DoD contract. Because you recognize the need to manage controlled information, including FCI, you meet with the employees who write the releases and post information to establish a review process [c]. It is decided that you will review press releases for FCI before posting it on the company website [a,d]. Only certain employees will be authorized to post to the website [a].

Potential Considerations

Does information on externally facing systems (i.e., publicly accessible) have a documented approval chain for public release [c]?

Copyright

Copyright 2020, 2021 Carnegie Mellon University and The Johns Hopkins University Applied Physics Laboratory LLC.

Copyright 2021 Futures, Inc.

This material is based upon work funded and supported by the Department of Defense under Contract No. FA8702-15-D-0002 with Carnegie Mellon University for the operation of the Software Engineering Institute, a federally funded research and development center, and under Contract No. HQ0034-13-D-0003 and Contract No. N00024-13-D-6400 with the Johns Hopkins University Applied Physics Laboratory LLC, a University Affiliated Research Center.

The view, opinions, and/or findings contained in this material are those of the author(s) and should not be construed as an official Government position, policy, or decision, unless designated by other documentation.

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