Protecting CUI: Don't Relegate Responsibility to IT or Cyber

Send us Fan MailProtecting CUI Beyond CMMC: Security Managers, Program Teams, and Consistent MarkingIn this NISPOM Central episode, the host argues that protecting Controlled Unclassified Information (CUI) is primarily a security manager/FSO responsibility that requires active involvement from program managers, engineers, and contract staff to identify, mark, document, and protect CUI and all derived products throughout workflows and the supply chain. He warns against relying on CMMC or technical cyber/IT controls alone, comparing it to a bank that stores valuables without accounting for deposits or growth, and notes inconsistent CUI identification and marking as a common failure. He describes how CUI may arrive as marked source documents (designs, drawings, slides, reports, PII used for government purposes) without a marking guide, requiring contract review and requirement analysis. When CUI status is unclear or unmarked, he advises seeking clarification internally, then from primes or the government program office. He announces forthcoming training on his Teachable LMS.00:00 Welcome to NISPOM Central00:08 CMMC Fatigue and Focus01:02 Bank Analogy for CUI01:51 Ownership Beyond IT02:31 Supply Chain Consistency03:47 Why CUI Became Cyber06:52 Wake Up Call on CUI07:16 Define Roles and Accountability07:54 How CUI Shows Up08:52 Derived Products and Markings11:04 When CUI Is Unclear13:06 Wrap Up and Training OfferSupport the showFSO Consulting:https://thriveanalysis.comNISPOM Compliancehttps://www.nispomcentral.comhttps://www.nispom.comThe Trusted Advisor for Technology Protection, FSO and NISPOM consulting. After dialing in my craft and many years of honing program protection experiences, I became a trusted advisor. I am currently supporting customers with technology protection and NISPOM compliance topics.INDUSTRIAL SECURITY TRUSTED ADVISORWhat Trusted Advisor Involves:I partner with executive leadership to design and operate security programs that meet and exceed NISPOM requirements. Results you can measure immediately:Prepared commercial organizations for defense contracting and NISPOM complianceDesigned ready to implement security programs before, during and after facility clearance awardRescued high risk security programs with quick turnaround; usually within 30 daysAchieved Commendable and Superior DCSA review ratingsDeveloped compliant FOCI mitigation programs