In the context of the Cybersecurity Maturity Model Certification (CMMC) 2.0, particularly at Level 2, organizations are required to implement stringent controls to protect Controlled Unclassified Information (CUI). This includes adhering to specific practices related to media protection and physical security.
Media Protection (MP):
MP.L2-3.8.1 – Media Protection:Organizations must protect (i.e., physically control and securely store) system media containing CUI, both paper and digital. This ensures that sensitive information is not accessible to unauthorized individuals.
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MP.L2-3.8.3 – Media Disposal:It is imperative to sanitize or destroy information system media containing CUI before disposal or release for reuse. This practice prevents potential data breaches from discarded or repurposed media.
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Physical Protection (PE):
PE.L2-3.10.2 – Monitor Facility:Organizations are required to protect and monitor the physical facility and support infrastructure for organizational systems. This includes ensuring that areas where CUI is processed or stored are secure and access is controlled.
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Application to the Scenario:
Given that the Organization Seeking Certification (OSC) operates within a shared, multi-tenant building and utilizes a common conference room for assessments, the following considerations are crucial:
Reviewing the Evidence File:The evidence file, which contains CUI, should be reviewed on a secure, authorized device to prevent unauthorized access or potential data leakage.
Printing the Evidence File:If printing is necessary, ensure that the printer is located in a secure area, and the printed documents are retrieved immediately to prevent unauthorized viewing.
Making Notes:Any notes derived from the evidence file should be treated with the same level of security as the original document, especially if they contain CUI.
Disposal of Printed Materials:After the assessment, all printed materials and notes containing CUI must be destroyed using a cross-cut shredder. Cross-cut shredding ensures that the information cannot be reconstructed, thereby maintaining confidentiality.
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Options A and D are inadequate as they involve leaving sensitive information in unsecured locations, which violates CMMC physical security requirements. Option B, while secure in terms of digital handling, does not address the proper disposal of any physical copies that may have been made. Therefore, Option C is the best practice, aligning with CMMC 2.0 guidelines by ensuring that all physical media containing CUI are properly reviewed, securely stored during use, and thoroughly destroyed when no longer needed.
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