Mapped to NIST 800-171 Requirement: 3.1.19
CMMC Assessment Objective: AC.L2-3.1.19[a]
What This Objective Means
This objective ensures your organization maintains a full inventory of portable storage media that could be used to handle CUI. These devices are especially risky due to their:
• Physical portability
• Ease of loss or theft
• Limited or no native access controls
The assessor wants to see that you’ve identified all such devices and that they’re tracked and managed intentionally.
Why It Matters
Portable storage devices are one of the most common sources of:
• Data exfiltration
• Accidental leaks
• Policy violations
• Insider threats
Without tracking these devices, you can’t effectively protect CUI.
How to Implement It
• Identify and inventory all portable media capable of storing or moving CUI:
◦ USB flash drives
◦ External SSDs or HDDs
◦ SD cards and compact flash cards
◦ CDs/DVDs, if applicable
• For each device, document:
◦ Owner or assigned user
◦ Device type, serial number, and location
◦ Purpose and authorized use
◦ Encryption or protection status
• Review inventory regularly to ensure accuracy
Evidence the Assessor Will Look For
• A centralized inventory of portable storage devices that may handle CUI
• Labels or unique identifiers for each device
• Assignment records showing who can use each device
• Policies or procedures that define how these devices are approved and tracked
Common Gaps
• Portable media is used without any inventory or tracking
• Personally owned storage devices allowed without approval
• Devices reused across departments or projects without controls
How Cuick Trac Helps
Cuick Trac supports this control by:
• Minimizing the need for portable storage through a centralized secure enclave
• Helping organizations define, track, and manage portable media with advisory templates
• Supporting encryption enforcement and documentation for any approved portable storage
• Eliminating USB or offline transfers of CUI through secure virtual access
With Cuick Trac, your CUI stays off portable drives unless explicitly needed—and always under control.
Final CTA
Portable doesn’t have to mean uncontrolled.
Schedule a Cuick Trac demo and bring your CUI-related storage devices under secure management.