Controlled Unclassified Information (CUI) 2

[CAD_Man]

Looking for feedback from people who are EXPERIENCED in defining Controlled Unclassified Information (CUI).
Applicable standards include:
[ul]
[li]32 CFR §2002[/li]
[li]DFAR 252.204-7012[/li]
[li]FAR 52.204-21[/li]
[li]NIST SP800-171 Rev 1[/li]
[li]FIPS Publication 199[/li]
[li]FIPS Publication 200[/li]
[/ul]

My questions are:
1. If our ERP only contains textural data (no files), would things like the BOM be considered a Technical Data Item? If so how could it be "Marked" as CUI?
2. There has been much debate related to, at what point an item "looses it's identity". In other words, if we are contracted to design an assembly for the DOD, the top level assembly is definitely considered CUI, but would a shim used on that assembly also be considered CUI?

Thanks

Chris Wilson
Engineering Services Manager

Certified SolidWorks Professional
Certified Enterprise PDM Administrator

 

[IRstuff]

A BOM is essentially a report of sorts, so yes, it can be technical data item

CUI is a bit nebulous at best, because it's often tied to "compilation" classification, i.e., when a compilation of unclassified information might reveal some classified information. For example, say your top level assembly is actually classified, but that the individual components within are not. Thus, the BOM might be CUI, as someone might potentially reverse-engineer what your top level assembly does, based on the components within the BOM. Your DD254 or security classification guide should give you general guidelines on classification.

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[berkshire]

Anecdotal story,
Some years ago I was working in a DECAS certified shop , we had a bunch of nondescript parts with deliberately vague titles , the acceptance inspector from the major aerospace company came in to check the parts , and assembled the thing right there on the inspection bench. We could instantly see what it was and what it was for.
There was a lot of scrambling and butt covering over that one, and I still cannot tell you what it was.
B.E.


You are judged not by what you know, but by what you can do.