Protecting CUI is critical to national security. As adversaries increasingly target the Defense Industrial Base, the Department of Defense has strengthened its approach to cybersecurity compliance through the CMMC. While CMMC does not explicitly create or enforce data governance frameworks, it plays a pivotal role in operationalizing the technical and procedural controls necessary to secure CUI throughout its lifecycle.

This article explores how CMMC intersects with data governance and CUI lifecycle management.

The Role of CMMC in CUI Protection

CMMC is designed to verify that DoD contractors have implemented cybersecurity measures to protect CUI. At Level 2, CMMC requires compliance with the security requirements of NIST SP 800-171, while Level 3 adds selected controls from NIST SP 800-172, which target advanced persistent threat protections. These controls cover various security disciplines, including access control, incident response, system integrity, and media protection.

CMMC does not alter or supersede the federal definitions and categorizations of CUI established under 32 CFR Part 2002 or DoD Instruction 5200.48. Instead, CMMC assessments focus on correctly implementing security requirements that help ensure the confidentiality of CUI in contractor systems. The DoD or contracting agency determines what constitutes CUI and provides appropriate markings.

Mapping CUI Lifecycle to CMMC Controls

Professionals securing CUI must recognize how its lifecycle aligns with CMMC requirements. While CMMC doesn’t explicitly define a CUI lifecycle, its requirements effectively span each phase of a traditional data lifecycle from creation to disposal:

Creation and Classification Although CMMC does not assess classification decisions or data labeling accuracy, it does require contractors to implement access control mechanisms that restrict who can create or alter data within systems containing CUI. Controls like AC.L2-3.1.1 and AT.L2-3.2.1 ensure that personnel understand their responsibilities and access is provisioned based on the principle of least privilege.
Storage and Maintenance NIST SP 800-171 mandates robust safeguards for storing CUI. Requirements like SC.L2-3.13.16 and MP.L2-3.8.9 ensure encryption and physical safeguards are in place. Configuration Management practices, such as CM.L2-3.4.1 and CM.L2-3.4.2, help maintain system integrity throughout data retention periods.
Usage and Sharing: CMMC enforces network protections, user monitoring, and secure communication channels as CUI is used or transmitted. SC.L2-3.13.1 and AU.L2-3.3.2 ensure system activities involving CUI are logged, auditable, and restricted to authorized parties. Additional layers like SC.L2-3.13.13 and IA.L2-3.5.3 are essential for remote access scenarios.
Archival and Retention: CMMC doesn’t dictate retention schedules for CUI; this is the purview of DoD contracting officers and NARA policies. However, the system’s ability to preserve the integrity and confidentiality of stored data over time is addressed through the continued application of controls in the areas of access control, audit, and system maintenance.
Destruction and Disposal: The final phase of the data lifecycle involves secure media sanitization and disposal. CMMC incorporates these needs via MP.L2-3.8.3, which requires organizations to sanitize or destroy media containing CUI using methods approved by NIST SP 800-88. This ensures that no residual data can be retrieved post-disposal.

Data Governance Responsibilities: CMMC vs DoD/NARA

CMMC enforces the how of CUI protection, while DoD and NARA establish the what and why.

Data governance encompasses more than technical safeguards; it includes policy frameworks for classifying, labeling, sharing, and managing data based on business and legal requirements. In the context of CUI, these responsibilities remain squarely with the federal government and DoD, not with CMMC or its assessors.

DoD remains the data owner and governs CUI definitions, markings, and dissemination restrictions under 32 CFR Part 2002 and DoDI 5200.48. Contractors must follow these rules, but are not subject to assessment under CMMC for how well they classify or mark data. Instead, CMMC assesses how well the contractor’s systems protect CUI once it is present.

Assessment Implications and Boundaries for CUI

Understanding what CMMC assessors will and will not evaluate is crucial for compliance professionals. CMMC assessments focus on evidence that demonstrates implementation of required security controls. This includes:

System Security Plans (SSPs) document how controls are applied
Policies and procedures that align with requirements
Technical configurations and logs
Interview responses from personnel

Assessors do not evaluate the accuracy of CUI markings or whether data should be classified as CUI in the first place. Likewise, CMMC does not assess how well a contractor aligns with government data-sharing policies or makes risk decisions on behalf of the data owner. Those areas are out of scope.

However, a compliance failure would occur if a contractor fails to identify where CUI resides or fails to apply required controls in those environments. Accurate system scoping and identification of CUI assets are foundational to a successful CMMC assessment.

Practical Recommendations for Classifying CMMC

Clarify Responsibilities Internally: Ensure organizational clarity regarding data governance and cybersecurity implementation. Assign distinct roles for compliance with DoD marking guidance versus the technical implementation of CMMC controls.
Establish Strong Data Handling Policies: While CMMC doesn’t require governance policies per se, having robust internal guidance on CUI handling, access, retention, and destruction strengthens implementation and audit readiness.
Use SSPs as Governance Tools: Treat your System Security Plans not only as compliance artifacts but as operational guides that detail where CUI lives and how it is protected.
Coordinate with Contracting Officers: For questions around classification, retention, or dissemination of CUI, engage your DoD contracting authority. Do not rely on CMMC assessors to guide these topics.
Regularly Review Asset Categorization: Use the CMMC Scoping Guides to accurately identify and update which assets process, store, or transmit CUI. Misclassification or omission of CUI systems can lead to compliance failure.

Keep Your Data Categorized and Documented with Lazarus Alliance

CMMC does not establish or govern the broader policies that define and regulate CUI, but it is instrumental in enforcing the security controls safeguarding this information across its lifecycle. DIB professionals must align internal governance and technical practices with both the letter of the CMMC framework and the intent of federal CUI policies.

To learn more about how Lazarus Alliance can help, contact us.

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Navigating Data Governance and CUI Lifecycle Management in CMMC