NIST 800-171
U.S. framework protecting CUI in nonfederal systems
ISO 27701
International standard for privacy information management systems
Quick Verdict
NIST 800-171 protects CUI confidentiality for DoD contractors via contract-mandated controls, while ISO 27701 establishes certifiable PIMS for global PII processors. Companies adopt NIST for federal compliance, ISO for privacy assurance and market trust.
NIST 800-171
NIST SP 800-171r3: Protecting CUI in Nonfederal Systems
Key Features
- Scoped requirements for CUI in nonfederal systems
- 97 requirements across 17 control families
- Mandates SSP and POA&M documentation
- CUI enclave isolation for boundary control
- Assessment via examine/interview/test procedures
ISO 27701
ISO/IEC 27701:2025 Privacy Information Management
Key Features
- Role-specific controls for PII controllers and processors
- PDCA management system integrated with ISO 27001
- GDPR and regulatory mappings in annexes
- Risk-based privacy impact assessments (DPIAs)
- Three-year certification with surveillance audits
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
NIST 800-171 Details
What It Is
NIST SP 800-171 Revision 3 (r3) is a NIST framework defining security requirements to protect Controlled Unclassified Information (CUI) confidentiality in nonfederal systems. Targeted at federal contractors, it tailors controls from SP 800-53 Moderate baseline using a scoped, control-based approach for components processing, storing, or transmitting CUI.
Key Components
- 97 requirements in 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)
- Aligned with FIPS 200; SP 800-171A r3 provides assessment procedures
- Compliance model: self/third-party assessments, SPRS/CMMC scoring
Why Organizations Use It
- Contractually required via DFARS 252.204-7012 for DoD eligibility
- Mitigates breach risks, ensures procurement access
- Enables FedRAMP Moderate cloud inheritance, boosts maturity
- Builds federal agency and partner trust
Implementation Overview
- Phased: gap analysis, scoping enclaves, SSP/POA&M, controls, monitoring
- Suits contractors of all sizes handling CUI
- Assessments via examine/interview/test; no universal certification
ISO 27701 Details
What It Is
ISO/IEC 27701:2025 is the international standard for establishing, implementing, maintaining, and improving a Privacy Information Management System (PIMS). It provides requirements and guidance for managing privacy risks associated with personally identifiable information (PII), extending ISO 27001 with a risk-based, PDCA (Plan-Do-Check-Act) approach focused on controllers and processors.
Key Components
- Clauses 4–10 for management system structure (context, leadership, planning, operation, evaluation, improvement)
- Annex A (37 controls for PII controllers) and Annex B (24 controls for PII processors)
- Mappings to GDPR (Annex D), ISO 27002, and others
- Certification via accredited bodies with Statement of Applicability (SoA)
Why Organizations Use It
- Demonstrates accountability for global privacy laws like GDPR
- Reduces risks from PII processing, incidents, and supply chains
- Enables procurement differentiation and regulatory evidence
- Builds trust through auditable governance and continual improvement
Implementation Overview
- Phased: scope PII flows, gap analysis, controls, audits
- Suited for all sizes/industries handling PII; 6-12 months typical
- Integrated audits with ISO 27001; three-year cycle with surveillance
Key Differences
| Aspect | NIST 800-171 | ISO 27701 |
|---|---|---|
| Scope | CUI confidentiality in nonfederal systems | PII privacy management system (PIMS) |
| Industry | DoD contractors, federal supply chain | Any PII-processing organizations globally |
| Nature | Recommended security requirements via contracts | Certifiable privacy management standard |
| Testing | SP 800-171A assessments, CMMC audits | Stage 1/2 certification audits, surveillance |
| Penalties | Contract ineligibility, no direct fines | Loss of certification, no legal penalties |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about NIST 800-171 and ISO 27701
NIST 800-171 FAQ
ISO 27701 FAQ
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