Mapped to NIST 800-171 Requirement: 3.1.19
CMMC Assessment Objective: AC.L2-3.1.19[b]
What This Objective Means
This objective is about policy enforcement and procedural clarity. It ensures that:
• Portable storage devices are not used casually or by default
• Only authorized users and devices can be used to store or move CUI
• The authorization process is documented and consistent
The goal is to control the use of high-risk media that could be easily lost, stolen, or misused.
Why It Matters
Without explicit authorization:
• Users may store CUI on personal or unapproved USB drives
• CUI could be copied and transported without oversight
• There would be no audit trail to support investigation or incident response
Policies and procedures set the foundation for accountable and secure use of portable storage.
How to Implement It
• Update your access control policy to:
◦ Prohibit the use of portable storage for CUI without prior approval
◦ Define an approval process (e.g., form, ticket, or documented request)
◦ List roles responsible for authorizing and reviewing storage use
• Create standard operating procedures (SOPs) that:
◦ Outline encryption and labeling requirements
◦ Describe how to handle lost or damaged devices
◦ Include documentation and review requirements
Evidence the Assessor Will Look For
• Access control policy sections stating that portable storage must be authorized before use
• Procedure documents showing how requests are made, approved, and logged
• Forms or workflows used to track authorization decisions
• Records of previous device authorizations
Common Gaps
• Policy allows use of USBs without requiring approval
• No process to distinguish between authorized and unauthorized portable devices
• Personally owned devices used without policy coverage
How Cuick Trac Helps
Cuick Trac supports this control by:
• Reducing the need for portable storage with a centralized secure environment
• Helping organizations draft and enforce policies that govern storage device use
• Supporting tracking and documentation of authorized devices when use is necessary
• Providing secure alternatives to portable storage like file-based enclave sharing
With Cuick Trac, portable storage use is rare—and when it’s necessary, it’s fully controlled and documented.
Final CTA
Don’t let portable storage become a blind spot.
Schedule a Cuick Trac demo and make authorization a requirement, not an afterthought.