What It Is

NIST SP 800-171r3, "Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations," is a U.S. NIST security framework providing recommended requirements for safeguarding CUI confidentiality. It applies to nonfederal systems processing, storing, or transmitting CUI, using a tailored, control-based approach derived from SP 800-53 Moderate baseline emphasizing risk-commensurate protections.

Key Components

• 97 requirements across 17 families (e.g., Access Control, Audit, Supply Chain Risk Management).
• Core artifacts: System Security Plan (SSP) and Plan of Action and Milestones (POA&M).
• Assessment via SP 800-171A r3 using examine/interview/test methods.
• Supports tailoring, ODPs, and cloud equivalency (FedRAMP Moderate).

Why Organizations Use It

Federal contractors implement for contractual mandates (e.g., DFARS 252.204-7012), CMMC Level 2 eligibility, and SPRS scoring. Benefits include risk reduction, supply chain trust, procurement competitiveness, and incident reporting readiness.

Implementation Overview

Phased approach: scope CUI enclaves, gap analysis, implement controls, document SSP/POA&M, continuous monitoring. Applies to contractors/subcontractors; requires self/third-party assessments. Timelines 6-18+ months depending on size.

What It Is

ISO/IEC 27018:2025 is a code of practice extending ISO 27001 and ISO 27002 for protecting personally identifiable information (PII) in public clouds where providers act as PII processors. Its primary purpose is to provide privacy-specific controls and guidance for cloud environments, focusing on multi-tenancy, cross-border data flows, and processor obligations. It uses a risk-based, control-oriented approach integrated into an Information Security Management System (ISMS).

Key Components

• Core domains: transparency, contractual obligations, data subject rights, breach management, security safeguards.
• Approximately 25-30 additional privacy controls mapped to ISO 27001 Annex A.
• Built on principles like consent, purpose limitation, data minimization, accountability.
• Assessed via ISO 27001 audits; no standalone certification.

Why Organizations Use It

• Builds customer trust and accelerates procurement.
• Aligns with GDPR, HIPAA for processor compliance.
• Mitigates privacy risks in cloud outsourcing.
• Differentiates CSPs in competitive markets.

Implementation Overview

• Conduct gap analysis against existing ISMS.
• Integrate controls into Statement of Applicability, update policies/contracts.
• Applicable to CSPs of all sizes; global geography.
• Requires third-party audits during ISO 27001 certification/surveillance.