NIST SP 800-53 Rev. 5 CM-12(1) — Automated Tools To Support Information Location

What this control requires

Use automated tools to identify defined information types across system components, supporting enforcement of controls to safeguard data and privacy. This control supports the Automation capability within the Configuration Management family.

In plain English

Use automated tools to identify defined information types across system components, supporting enforcement of controls to safeguard data and privacy. In practice, this means you can prove you policy management-level controls on a defined cadence.

Why it matters

SP 800-53 is the catalogue every U.S. federal authorisation (FedRAMP, FISMA, CMMC) and most regulated industries point at. A missing control surfaces as a Plan of Action & Milestones (POA&M) item that an Authorizing Official must approve before the Authority To Operate is granted or renewed.

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 3PAO (FedRAMP) or Independent Assessor (NIST RMF) tests against NIST SP 800-53A assessment procedures. For each control they expect a documented implementation that addresses every assessment objective (Examine, Interview, Test) and an implementation summary in the System Security Plan.

Within Configuration Management, the assessor will trace your implementation back to the catalogue reference (Control CM-12(1)) 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

• Policy. Document the trigger, the owner and the cadence.
• Information. Document the trigger, the owner and the cadence.
• Configuration. Document the trigger, the owner and the cadence.
• Data. Document the trigger, the owner and the cadence.
• Protection. Document the trigger, the owner and the cadence.
• Scope: management, enforcement, information, privacy, system, location, controls, protection.

Evidence to collect

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

Signed policy or standard documents the safeguard. Focus: Automated Tools To Support 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 800-171 Rev. 3 3.4.11 — Information Location
• SOC 2 (2017 TSC) P2.1 — Communication of Data Subject Choices and Consequences
• BSI C5:2020 AM-02 — Acceptable Use and Safe Handling of Assets Policy

Related controls in NIST SP 800-53 Rev. 5

• Control CM-12 — Information Location
• Control CM-13 — Data Action Mapping
• Control SI-18(1) — Automation Support
• Control CM-4(2) — Verification Of Controls
• Control SC-42(5) — Collection Minimization
• Control SI-19(7) — Validated Algorithms And Software

References

• NIST Computer Security Resource Center — NIST SP 800-53 Rev. 5
• Catalogue identifier: Control CM-12(1)

Topics: governance riskdata protectionpolicy managementprivacy management