by Michael Peters
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Information Flows, CMMC, and Zero-Trust Systems

Modern attackers come from any and every angle, but one thing they all want is access to data. But this doesn’t mean they just want to land in some database… more often than not, advanced attackers are looking for ways to monitor information flows to gain credentials and learn more about the systems and organizations they infiltrate. 

 

What is Information Flow?

Information flow is the movement or transfer of information within or between systems. It encompasses how data moves from one location to another—between devices, applications, users, or networks. 

In cybersecurity, information flow is crucial to understanding how data is accessed, transmitted, and managed throughout an organization’s IT environment.

  1. Internal Information Flow, or data movement within a single system or network.
  2. External Information Flow, or data transfer between systems or across network boundaries.
  3. Controlled Information Flow, or the movement of data that follows specific policies or restrictions.
  4. Uncontrolled Information Flow, or data movement without adequate monitoring or policy enforcement, often leads to vulnerabilities.

Information flow directly impacts how data is protected, monitored, and controlled within an organization. Mismanagement or lack of visibility into information flow can result in data breaches, unauthorized access, and loss of sensitive information.

 

Examples of Compromised Information Flow Attacks

  • In 2008, Heartland Payment Systems suffered a breach via an SQL injection attack. The attackers installed a packet sniffer that intercepted all traffic moving through their internal systems, explaining credit card information.
  • Discovered in 2009, GhostNet (a Chinese advanced persistent threat) gained access to several cloud systems across multiple countries. After using sophisticated spear phishing tactics, GhostNet monitored network traffic and audio and video devices to monitor information. 

 

How Does CMMC Gover Information Flow?

CMMC incorporates security requirements from NIST Special Publication 800-171, which outlines specific controls related to data flow.?

  • Access Control (AC) 3.1.3: Implement mechanisms to ensure that CUI is only transmitted or received by authorized users and systems, preventing unauthorized data exposure.
  • Audit and Accountability (AU) 3.3.2: Ensure that the actions of individual system users can be uniquely traced to those users.?  Maintain detailed logs of user activities to monitor data access and transfer, preventing unauthorized data flows.
  • System and Communications Protection (SC) 3.13.2: Employ architectural designs, software development techniques, and engineering principles that promote effective information security within organizational systems.?
  • SC 3.13.5: Implement subnetworks for publicly accessible system components physically or logically separated from internal networks. Using network segmentation to control data flow between public-facing systems and internal networks reduces the risk of unauthorized access to sensitive information.
  • SC 3.13.8: Implement cryptographic methods to protect CUI during transmission unless otherwise protected by alternative physical measures. Encrypt CUI when transmitted over networks to prevent interception and unauthorized access during data flow.

 

Zero Trust and Information Flow Protection

CMMC information flows

Zero Trust Architecture (ZTA) plays a crucial role in protecting information flow by enforcing strict access controls, continuous monitoring, and verifying every entity attempting to move or access data within an organization. The core principle of Zero Trust is to “never trust, always verify,” which means that no entity—whether inside or outside the network—is automatically trusted.

The benefits of ZTA for protecting information flows (whether applied to CMMC or not) are clear:

  • Prevents Unauthorized Data Movement: Zero Trust significantly reduces the risk of data leakage and unauthorized transfers by enforcing authentication and authorization at every access point.
  • Mitigates Insider Threats: Even if an insider has credentials, Zero Trust policies can limit their ability to move data across the network.
  • Reduces Attack Surface: Zero Trust minimizes the potential paths an attacker can exploit by segmenting the network and controlling data flow within micro-perimeters.
  • Enhances Compliance and Auditing: Continuous monitoring and logging support compliance with frameworks like CMMC, NIST, and SOC 2 by providing traceability and accountability of data flows.
  • Thwarts Advanced Persistent Threats: APTs often rely on lateral movement within a compromised network. Zero Trust blocks unauthorized data flows, stopping attackers from moving across systems.

Accordingly, there are several specific tactics for ZTA to be effective:

  1. Least Privilege Access ensures that users and systems have only the minimum necessary permissions to perform their tasks. Strictly controlling access points also reduces the risk of unauthorized data flows.
  2. Micro-segmentation divides the network into smaller segments to contain data flow within isolated zones. This limits the lateral movement of data and threats, reducing the impact of a potential breach.
  3. Identity and Access Management (IAM) implements strong user authentication (MFA) to verify identities before allowing data flow. Role-based and attribute-based access controls (RBAC and ABAC) manage data movement based on user roles and attributes.
  4. Continuous Monitoring and Logging tracks data flows in real-time to detect anomalies and unauthorized access attempts, automating responses to suspicious data flow patterns.
  5. Encryption and Data Protection encrypt data at rest and in transit to ensure confidentiality and integrity. Cryptographic controls to secure data flows, preventing eavesdropping or tampering.
  6. Contextual Access Policies apply dynamic policies that consider user behavior, device posture, location, and data sensitivity. Limiting data flows based on context reduces the risk of insider threats and compromised accounts.

Monitor Information Flow Controls with Continuum GRC

A well-executed incident response plan is a requirement for CMMC compliance and an essential defense mechanism against cyber threats. Organizations implementing continuous monitoring, structured response processes, and proactive security measures will meet CMMC standards and enhance their overall security resilience.

Continuum GRC is a cloud platform that stays ahead of the curve, including support for all certifications (along with our sister company and assessors, Lazarus Alliance). 

We are the only FedRAMP and StateRAMP-authorized compliance and risk management solution worldwide.

Continuum GRC is a proactive cyber security® and the only FedRAMP and StateRAMP-authorized cybersecurity audit platform worldwide. Call 1-888-896-6207 to discuss your organization’s cybersecurity needs and learn how we can help protect its systems and ensure compliance.

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