NIST SP 800-171 Rev. 3 3.4.11 — Information Location

What this control requires

This control requires identifying and documenting the locations of Controlled Unclassified Information (CUI) and the system components where it is processed and stored. It also mandates documenting changes to the location of system components where CUI is processed and stored, ensuring proper protection mechanisms are applied to maintain security and access controls. This control supports the Information Location Management capability within the Configuration Management (3.4) family.

In plain English

This control requires identifying and documenting the locations of Controlled Unclassified Information (CUI) and the system components where it is processed and stored. In practice, this means you can prove you access management-level controls on a defined cadence.

Why it matters

DoD contractors and their subcontractors must implement all 100 SP 800-171 requirements to keep CUI handling contracts. Gaps are scored against the SPRS scoring methodology; below a 110-point starting score, each unmet requirement deducts points and a below-threshold score can disqualify a bid.

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 C3PAO conducting a CMMC Level 2 assessment uses NIST SP 800-171A objectives. They expect a System Security Plan (SSP), Plan of Action & Milestones (POA&M) for any gaps, and objective evidence (configurations, ticket records, training records) for every requirement.

Within Configuration Management, the assessor will trace your implementation back to the catalogue reference (Requirement 3.4.11) and look for objective evidence on the latest two assessment cycles.

How to implement

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Operational checklist

• Access. Document the trigger, the owner and the cadence.
• Information. Document the trigger, the owner and the cadence.
• Protection. Document the trigger, the owner and the cadence.
• Configuration. Document the trigger, the owner and the cadence.
• System. Document the trigger, the owner and the cadence.
• Scope: management, cui, configuration, location, security, protection, system components.

Evidence to collect

• Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policy or standard documents the safeguard. Focus: Information Location.

Common pitfalls

• Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

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.

• NIST SP 800-53 Rev. 5 CM-12 — Information Location
• BSI C5:2020 OIS-01 — Information Security Management System (ISMS)
• ISO/IEC 27001:2022 A.5.1 — Policies for information security
• HIPAA (45 CFR Part 164) 164.308(a)(5)(i) — Security Awareness and Training
• SOC 2 (2017 TSC) CC2.3 — External Communication on Internal Control Matters

Related controls in NIST SP 800-171 Rev. 3

• Requirement 3.4.1 — Baseline Configuration
• Requirement 3.4.12 — System and Component Configuration for High-Risk Areas
• Requirement 3.15.1 — Policy and Procedures
• Requirement 3.8.4 — Media Marking
• Requirement 3.10.6 — Alternate Work Site
• Requirement 3.4.8 — Authorized Software - Allow by Exception

References

• NIST Computer Security Resource Center — NIST SP 800-171 Rev. 3
• Catalogue identifier: Requirement 3.4.11

Topics: governance riskpolicy management