3.8.9·critical·Component: Media ProtectionWhat this control requires
This control requires implementing cryptographic mechanisms to protect the confidentiality of backup information and prevent the unauthorized disclosure of Controlled Unclassified Information (CUI) at backup storage locations. It suggests using hardware security modules (HSM) for managing cryptographic keys and performing cryptographic operations such as encryption and decryption. This control supports the Cryptographic Protection capability within the Media Protection (3.8) family.
In plain English
This control requires implementing cryptographic mechanisms to protect the confidentiality of backup information and prevent the unauthorized disclosure of Controlled Unclassified Information (CUI) at backup storage locations. In practice, this means you can prove you information 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 critical in the source catalogue. Treat gaps here as production incidents in the risk register, not housekeeping.
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 Media Protection, the assessor will trace your implementation back to the catalogue reference (Requirement 3.8.9) 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
- 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.
- Media. Document the trigger, the owner and the cadence.
- Scope: management, cui, configuration, hardware, recovery, security, storage, - cryptographic protection.
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: System Backup - Cryptographic Protection.
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.
- NIST SP 800-53 Rev. 5 CP-6(2) — Recovery Time And Recovery Point Objectives
- BSI C5:2020 OPS-09 — Data Backup and Recovery - Storage
- CIS Controls v8 11.3 — Protect Recovery Data
Related controls in NIST SP 800-171 Rev. 3
- Requirement 3.13.8 — Transmission and Storage Confidentiality
- Requirement 3.14.8 — Information Management and Retention
- Requirement 3.13.6 — Network Communications - Deny by Default - Allow by Exception
- Requirement 3.4.12 — System and Component Configuration for High-Risk Areas
- Requirement 3.4.6 — Least Functionality
- Requirement 3.1.18 — Access Control for Mobile Devices
References
- NIST Computer Security Resource Center — NIST SP 800-171 Rev. 3
- Catalogue identifier:
Requirement 3.8.9
Topics: data protectioncloud postureconfiguration managementnetwork securitybackup recovery