On Wed, May 27, 2015 at 7:56 PM, PeterK <[log in to unmask]> wrote:

> Agencies will have an easier time managing the dissemination of controlled
> unclassified information (CUI), thanks to new guidance published by the
> National Archives and Records Administration's Information Security
> Oversight Office.
>
> CUI is unclassified information that a law, regulation or govermentwide
> policy has given an agency the authority to safeguard or control access to.
> Over time, agencies have developed a myriad of rules an long-held practices
> of how to handle and label this type of information
>

This 'guidance' is presently in Draft form and like many rush to release
things, there are many holes in this.

If the guidance were to be issued as written, I can guarantee you the vast
majority of people handling "CUI" as part of their regular work would
completely ignore it.  The concept of writing one set of guidance to be
used by ALL Federal Agencies in the management of "CUI" is rater
ludicrous.

There's controlled unclassified, and there's controlled unclassified.
Depending upon the reason/s it's 'controlled', the manner in which it is
handled, marked, protected, disseminated can be DRASTICALLY different.  In
part, because some of this information is managed offshore and the risks
it's subjected to are different, how you handle, protect and potentially
destroy it in the event of a crisis, is substantially different.

Also, some "CUI" is related to National Security issues, even though it's
unclassified... it can be extremely sensitive.  This type of information is
NOT handled in the same manner as other run-of-the-mill "CUI", like PFI,
PHI, PII.

A cursory review of this guidance sent some shivers up my spine in my role
here... and I'm not even exposed to the "big stuff"... and we're only a
Contractor.  First, the Agencies have to accept it, which would require
them to re-write multiple Orders, Directives and other Agency level
guidance, AND train their staff to implement it.

Then they would have to pass that along to their Contractors (who manage
the Lion's Share of their information assets), who would have to evaluate
it for impacts to efforts, determine cost to implement, then *IF* accepted,
would have to re-write their policies, procedures and guidance, AND Train
their staff to implement it for internal use.

It's hard to see where the benefits would outweigh the cost, especially
since it appears NARA hasn't done their due diligence to examine the scope
of "CUI" across ALL Agencies.

-- 
Larry
[log in to unmask]



*----Lawrence J. MedinaDanville, CARIM Professional since 1972*

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