The document provides an overview of Controlled Unclassified Information (CUI) and the application of NIST Special Publication 800-171, focusing on the implications for research institutions and organizations that handle federally sourced sensitive data. CUI is defined as information requiring safeguarding or dissemination controls per applicable laws and policies but is not classified under executive-level directives. Established by Executive Order 13556 and governed by a federal registry, CUI encompasses a broad range of categories such as financial, legal, privacy, export control, and proprietary business information, underscoring its relevance beyond research contexts into areas like business services, law enforcement, and immigration.
NIST 800-171, first released in 2015 and revised subsequently, sets standardized security requirements for nonfederal entities that process, store, or transmit CUI on their systems, but excludes cases where organizations operate systems on behalf of the government. The standard outlines 14 control families—including access control, incident response, and configuration management—encompassing 110 specific controls, many of which demand substantial effort and resources. Full implementation was mandated by the end of 2017, with relevant regulatory and contractual clauses introduced progressively in federal acquisition rules. NIST 800-171 applies when information falls within defined CUI categories and a “federal nexus” exists, such as through a federal contract or data-sharing agreement. Effective compliance requires engagement across diverse institutional stakeholders, including IT, contracting, business services, and student or immigration services, highlighting the collaborative and cross-functional nature of safeguarding CUI in academic and other organizational settings.
