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

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Protecting CUI Beyond CMMC: Security Managers, Program Teams, and Consistent Marking

In 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 Central
00:08 CMMC Fatigue and Focus
01:02 Bank Analogy for CUI
01:51 Ownership Beyond IT
02:31 Supply Chain Consistency
03:47 Why CUI Became Cyber
06:52 Wake Up Call on CUI
07:16 Define Roles and Accountability
07:54 How CUI Shows Up
08:52 Derived Products and Markings
11:04 When CUI Is Unclear
13:06 Wrap Up and Training Offer

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