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Controls / Media Protection / 3.8.5
3.8.5
MP.L2-3.8.5 · Level 2

Control access to media containing CUI and maintain accountability for media during transport…

NIST SP 800-171 Rev 2 · §3.8.5

Control access to media containing CUI and maintain accountability for media during transport outside of controlled areas.

Assessment objectives

From NIST SP 800-171A · 2 objectives must be met to satisfy this control
3.8.5[a] access to media containing CUI is controlled.
Examine
SELECT FROM: System media protection policy; procedures addressing media storage; physical and environmental protection policy and procedures; access control policy and procedures; security plan; system media; designated controlled areas; other relevant documents or records].
Interview
[SELECT FROM: Personnel with system media protection and storage responsibilities; personnel with information security responsibilities; system or network administrators].
Test
[SELECT FROM: Organizational processes for storing media; mechanisms supporting or implementing media storage and media protection].
3.8.5[b] accountability for media containing CUI is maintained during transport outside of controlled areas.
Examine
SELECT FROM: System media protection policy; procedures addressing media storage; physical and environmental protection policy and procedures; access control policy and procedures; security plan; system media; designated controlled areas; other relevant documents or records].
Interview
[SELECT FROM: Personnel with system media protection and storage responsibilities; personnel with information security responsibilities; system or network administrators].
Test
[SELECT FROM: Organizational processes for storing media; mechanisms supporting or implementing media storage and media protection].

What we look for in practice

The following are placeholder notes that should be refined based on practice experience.

What assessors look for in practice. Documented evidence that this control is implemented across all CUI-handling systems within scope. Specific artifacts vary, but expect requests for written procedures, system configurations, and operational records demonstrating the control is active.

Common failure patterns. Typical issues include incomplete documentation, inconsistent implementation across systems, and missing periodic review records. Refine this section as your practice accumulates direct assessment experience.

Strong evidence looks like. Formal policy referencing this control, technical configurations demonstrating enforcement, periodic review logs with sign-off, and procedures for handling exceptions.

Scoring and POA&M context. 1-point control under the DoD Assessment Methodology. Lower scoring impact, but still required for full compliance. POA&M-eligible — deferral up to 180 days is allowed under conditional certification per 32 CFR 170.21.