What 3.8.1 means in practice

Paper and portable digital media that hold CUI stay under control and are locked away when not in use, for example in locked cabinets or a secure room. That covers printouts, external drives, USB sticks, discs and backup tapes.

SPRS points and the CMMC POA&M

CMMC Level 2 practice
MP.L2-3.8.1
SPRS points
3 points. When it is not met, the DoD Assessment Methodology subtracts 3 from the score of 110.
CMMC POA&M
Not allowed. It is worth 3 points, and 32 CFR 170.21(a)(2)(ii) admits only requirements worth 1 point, with one exception: 3.13.11 when encryption is used but not FIPS validated.

Sources: NIST SP 800-171 DoD Assessment Methodology, version 1.2.1 (June 24, 2020), Annex A; 32 CFR 170.21, Plan of Action and Milestones requirements.

What an assessor checks for 3.8.1

NIST SP 800-171A gives 4 determination statements for 3.8.1, each found satisfied or other than satisfied. Determine if:

  1. 3.8.1[a] paper media containing CUI is physically controlled.
  2. 3.8.1[b] digital media containing CUI is physically controlled.
  3. 3.8.1[c] paper media containing CUI is securely stored.
  4. 3.8.1[d] digital media containing CUI is securely stored.

NIST SP 800-171A (June 2018), assessment objectives for 3.8.1

Evidence that shows 3.8.1 is met

  • The media protection procedure.
  • Locked storage for paper and digital media, and a record of who holds the keys.
  • Media inventories or logs.

How PolicyCortex gathers the evidence

No PolicyCortex collector reads the evidence for 3.8.1. Your team provides the evidence listed above.

Meet the requirement once. Keep the evidence current.

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