3.9·high·Component: ProtectWhat this control requires
Encrypt data on removable media.
In plain English
Encrypt data on removable media. In practice, this means you can prove you encrypt network-level controls on a defined cadence.
Why it matters
The CIS Controls are an industry-vetted, prioritised defence: skipping a safeguard widens the attack surface that the safeguards above and below it assume is closed. Audit frameworks (FedRAMP, PCI DSS, HIPAA) all cite CIS as evidence of due care.
This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.
What an auditor looks for
A CIS-aligned reviewer wants to see (a) which Implementation Group you are targeting, (b) a documented owner for the safeguard, and (c) a tooling or process artefact (config, scan output, ticket) that proves the safeguard runs on the cadence the control demands.
Within Protect, the assessor will trace your implementation back to the catalogue reference (Control 3.9) and look for objective evidence on the latest two assessment cycles.
How to implement
Cloud Posture
CSPM. Run Wiz / Prisma / Defender for Cloud / Security Command Center over every account; auto-ticket findings above your accepted-risk threshold.
Configuration Management
Policy-as-code. Codify the control as Service Control Policies (AWS), Azure Policy initiatives, or Organisation Policy (GCP) so the platform enforces what the document promises.
IaC. Gate Terraform / Pulumi / CloudFormation changes with Checkov / tfsec / OPA so misconfigurations never reach production.
Drift. Run a CSPM (Wiz / Prisma / Defender for Cloud / Security Command Center) over every account and route findings to a single risk register.
Network Security
AWS. VPC Flow Logs to S3, default-deny security groups, AWS Network Firewall for north-south, and Transit Gateway for hub-and-spoke segmentation.
Azure. NSGs with deny-by-default, Azure Firewall Premium with TLS inspection, Private Endpoints for PaaS, and Microsoft Defender for Cloud's secure score for drift.
GCP. VPC Service Controls perimeters around sensitive APIs, Cloud NGFW Enterprise for L7 inspection, Private Service Connect for managed services.
Operational checklist
- Encrypt. Document the trigger, the owner and the cadence.
- Protect. Document the trigger, the owner and the cadence.
- Scope: network, data, encryption.
Evidence to collect
- Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.
Infrastructure posture tooling (AWS Config, Azure Policy, Nessus) verifies platform hardening. Focus: Encrypt Data on Removable Media.
Common pitfalls
- Treating CSPM findings as a backlog instead of a hot queue: findings older than the policy SLA accumulate until the auditor asks why.
- Manual cloud-console changes that never make it back to Terraform — drift accumulates until the next outage forces a reconciliation.
- Default-allow egress rules; East-West traffic with no segmentation; jump hosts on the public internet with password auth.
How it maps to other frameworks
Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.
- GDPR Article 25 — Data protection by design and by default
- BSI C5:2020 COM-03 — Internal audits of the information security management system
- NIST SP 800-171 Rev. 3 3.4.6 — Least Functionality
Related controls in CIS Controls v8
- Control 10.3 — Disable Autorun and Autoplay for Removable Media
- Control 16.8 — Separate Production and Non-Production Systems
- Control 14.2 — Train Workforce Members to Recognize Social Engineering Attacks
- Control 3.12 — Segment Data Processing and Storage Based on Sensitivity
- Control 11.3 — Protect Recovery Data
- Control 7.3 — Perform Automated Operating System Patch Management
References
- Center for Internet Security — CIS Controls v8
- Catalogue identifier:
Control 3.9
Topics: governance riskcloud postureconfiguration managementnetwork securityencryption at rest