DISCUSSION [NIST SP 800-171 R2]
Limits on the use of organization-controlled portable storage devices in external systems include complete prohibition of the use of such devices or restrictions on how the devices may be used and under what conditions the devices may be used. Note that while “external” typically refers to outside of the organization’s direct supervision and authority that is not always the case. Regarding the protection of CUI across an organization, the organization may have systems that process CUI and others that do not. Among the systems that process CUI there are likely access restrictions for CUI that apply between systems. Therefore, from the perspective of a given system, other systems within the organization may be considered “external” to that system.
Further Discussion
A portable storage device is a system component that can be inserted or attached and easily removed from a system. It is used to store data or information. Examples of portable storage devices include:
compact/digital video disks (CDs/DVDs);
Universal Serial Bus (USB) drives;
external hard disk drives;
flash memory cards/drives; and
floppy disks.
This practice can be implemented in two ways:
identifying the portable storage device usage restrictions, identifying portable storage devices that may be used on external systems, identifying associated external systems on which a portable storage device may be used, and administratively (through the use of a written policy) limiting the usage of the devices to those systems; or
configuring devices to work only when connected to a system to which the portable storage device can authenticate, limiting the devices’ use on external systems to those that the contractor has the ability to manage.
Example
Your organization has a written portable device usage restriction policy. It states that users can only use external storage devices such as thumb dives or external hard disks that belong to the company. When needed for a specific business function, a user checks the device out from IT and returns it to IT when no longer needed [a,b].
Potential Considerations
Are the portable storage devices authorized for external use identified and documented [a]?
Are the circumstances defined in which portable storage devices containing CUI may be used on external systems (e.g., with management approval) [b]?
Are limitations stipulated for the use of portable storage devices containing CUI on external systems (e.g., authorized personnel only, encrypted drives required) [b]?
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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