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What is Controlled Unclassified Information?


This article is written through the lens of requirements to protect CUI in the context of the U. We only accommodate that contractually across Azure, Office , and Dynamics in the US Sovereign Cloud, built in a fully isolated environment that is both physically and logically separated.

Our mantra is clear. This trade off recognizes that your solution may exceed requirements for a specific type of data; but provides confidence you likely have addressed your aggregate requirements.

This is ideal when your internal classification and marking efforts may not be where you would like them yet. In what will be one of my most hotly contested articles to date, this is intended to spark a debate on how CUI data protection practices apply holistically. I intend to keep this initial argument high level, as there are a million nuances that may be deliberated indefinitely. We will not police you, nor will we demand you choose one cloud over another.

We will be very clear on where we provide contractual obligations. The CUI Program is an ever-evolving initiative to standardize the markings and data protection practices across Federal agencies to facilitate sharing of sensitive information, transcending individual agencies.

CUI includes markings that span many categories and groupings. The groupings consist of everything from Financial and Privacy data, all the way up to Export Controlled and Intelligence data.

Individual agencies have their own requirements for CUI, resulting in additional rules that govern the data protection practices of CUI. CUI is defined by a program that includes all categories under a single umbrella.

Not all CUI markings are protected precisely the same way. However, it can be untenable to discern the various restrictions for CUI given consolidated language used by standards and regulations. In addition, the complicated array of markings are often not applied effectively. As a result, the reduced risk data protection strategy is to opt for the highest watermark possible for protection of CUI, rather than risk it by adopting a lower control set. ITAR has a data sovereignty requirement.

To summarize, before the advent of CUI, there were a myriad of autonomous Federal agencies and departments that had each developed its own practices for protecting sensitive information. This non-conformity made it extremely difficult to share information with transparency throughout the Federal government and its stakeholders, such as the Defense Industrial Base DIB. The CUI program is an ever-evolving initiative to standardize the markings and data protection practices across Federal agencies to facilitate sharing of sensitive information, transcending individual agencies.

You can read about it here in the Federal Register:. You can find the list here:. It goes without saying that each of the Federal executive branch agencies have had their own requirements for CUI, resulting in additional rules that govern the data protection practices of CUI. Thus, there does remain a level of autonomy from NARA. It is intended to address inconsistent definition and marking requirements specific to the DoD expanding what is outlined in 32 CFR Part In addition, there are multiple regulations that govern specific categories of CUI.

Mishandling of other categories may earn you an orange jump suit, such as spilling ITAR regulated data to an unauthorized foreign state actor. That being said, we cannot adjust the definition of CUI to exclude export controlled or other protected information; the Executive Order's definition of CUI is clear and includes all unclassified information that laws, regulations, and Government-wide policies require to have safeguarding or dissemination controls.

While we may agree that not all CUI is the same, there is a consensus that all CUI is defined by a program that includes all categories under a single umbrella. So the question is, how do you differentiate between CUI that is sensitive such as Privacy categories, versus those with damaging national security concerns, such as export-controlled data?

Another way to ask the question is, how do you discern the various restrictions for CUI given the complicated array of markings that are not often applied effectively? Technically, you are right. I honestly do not hear anyone differentiating categories of CUI for purposes of maintaining compliance with individual markings. In addition, most recognize CUI markings are not applied consistently and marking efforts may not be where they would like them yet. In other words, they have not located all CUI stored in their enterprise information systems.

CMMC defines five Levels:. This article is not about how to become CMMC compliant. This article is specifically focused on CUI. Most CSPs will not allow ad-hoc third parties to perform assessments on their data centers.

Trust me, we would not have invested an extraordinary amount to build the US Sovereign Cloud if we could have simply pulled it off in Commercial with a few compensating controls. I am assuming the intent is to drive the selection of a cloud that has been authorized by the DoD, as opposed to a cloud that is only authorized with FedRAMP. It goes on to define the specific requirements for ITAR.

In this case, IL4 is specifically placing an emphasis on CUI to explicitly scope in export-controlled data and how to protect it.

However, is it that simple? The above conclusion is that CUI has export-controlled data as a common high watermark of data protection practices, to include ITAR regulated data. Since ITAR is a high bar for compliance, it comes along with a stringent set of requirements for data sovereignty. Allow me to pull on that string a bit. They have the contractual amendment from Microsoft to support ITAR with NOFORN and have established a clear accreditation boundary for protection of export-controlled data natively within their information systems.

The second company does not handle export-controlled data frequently. They have deployed their information systems in commercial clouds that are not natively compliant for ITAR regulations.

Do the two companies have equivalent risk profiles, as they both have certifications for CMMC Level 3? The short answer is definitively no. The second company has a tremendously higher risk of non-compliance and spillage relying on the human factor to protect export-controlled data.

In addition, most export-controlled data does not begin its life as such. Most begin simply as intellectual property, such as documents generated during a research and development project.

If you are saving that data in a commercial cloud unprotected not opaque to the Cloud Service Provider , you subsequently end up with a deemed export without the fault of the original document author. As such, it is imperative to protect all intellectual property by specially encrypting virtually everything that may potentially become CUI in the future. Here is final example. They rely on a system of checks and balances throughout the tiers to ensure each sub-contractor levels deep is compliant and is obligated to protect their crown jewels.

If CMMC is intended to establish a level of trust that any vendor certified at a Level 3 is compliant for data handling of CUI, they should not have to additionally qualify protection of export-controlled data.

These DIB may not accept the second company that is in any ole commercial cloud without native compliance. It will be your sole responsibility to prove and maintain compliance for it in other clouds. Please follow me here and on LinkedIn.

Gold Standard! Microsoft expands qualification of contractors for government cloud offerings. RichardWakeman - Great article as always! You do a great job of walking through some of the regulatory pieces that can be very complex at times. In addition, the updates to the ITAR earlier this year remove the explicit requirement for data to reside in the US if it meets certain criteria. The criteria being:. However, with that update, they also updated the definition of "release" to include providing "access information" to a foreign person.

Previously if you could prove that there was no access, it was not considered a "release" Microsoft's copious logging was great for this. Microsoft has always been forthcoming that there is no standing access to customer data by MS employees and access is only granted on a limited, time-bound basis when needed. If that is accurate, and a customer has Lockbox turned on in both O and Azure, then a "release" would not occur, even in a Commercial environment until a customer approves a lockbox request pending the controlled data being in a service covered by Lockbox.

Would you agree? One additional challenge that I have seen is around the "level" of export-controlled data that should be caught by the CUI tag. Technically, EAR99 data is "export-controlled" to embargoed countries or 9E data is "export-controlled" if going to a military end-user in China.

That same data could be going to the Airbus A line in Tianjin and not be considered "export-controlled. Due to this, I would agree with setting controls to the high watermark that you mention. However, this complicates the issue as to how to work efficiently across a multi-national organization in one of the sovereign environments. This is where some type of federation between Commercial and Gov would be very beneficial.

If environments could be managed through a single window, and a single identity could be synced, that would open up some new architecture possibilities. The key to protecting export controlled data is enabling End-to-End Encryption E2EE that prohibits unauthorized access where only intentional parties have access to decrypt and view the data in plain text.

You are correct there are valid scenarios where non-US persons may be authorized. This is especially true for multi-national companies that may even have foreign site-based export control licenses. It is common to give the non-US persons access to a tenant where CUI resides and ensure conditional access control policies enforce data protection appropriately.

There are even examples where customers are connecting from OCONUS locations and networks and still well within compliance. After all, it is a shared responsibility model, such as ensuring the end-points are protected. It is possible to leverage compensating controls such as Customer Lockbox in Commercial to prevent non-US persons from having access to your data. However, Customer Lockbox is not available in all services across Office , Azure, Dynamics , etc. Ultimately, it's not a full-proof scheme across all Commercial Services.

In addition, not all services support E2EE with a customer-managed key. Many do, but not all. Thus, it becomes your responsibility to ensure the services you use support your compliance policies. The risk of course, is that export controlled data may slip through the cracks.

And customers also leverage E2EE as well, especially for sharing scenarios where the data may leave the system boundary. This all said, many customers have decided to implement their own compensating controls and find an acceptable amount of risk using Commercial or GCC.

And this is all in context of U.


Singing the Reformation

This article is written through the lens of requirements to protect CUI in the context of the U. We only accommodate that contractually across Azure, Office , and Dynamics in the US Sovereign Cloud, built in a fully isolated environment that is both physically and logically separated. Our mantra is clear. This trade off recognizes that your solution may exceed requirements for a specific type of data; but provides confidence you likely have addressed your aggregate requirements.

Figure (a) Each topic is represented by its top probability words. embedding process and connecting the words that have the same CUI in the UMLS.

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The classification of information by the US government exists to secure sensitive information that is not intended for public release. The classification system contains three levels Top Secret, Secret, and Confidential. Each level is based on the degree to which a disclosure would damage national security. In recent years, US intelligence agencies have discovered that foreign adversaries are especially adept at gathering unclassified information and connecting it together like pieces in a puzzle to create a larger more revealing and potentially damaging picture. In other words, there are mountains of data that exist below the classified levels that—especially when combined with other information—could pose a threat to US national security. Additionally, there is sensitive financial, immigration, patent, law enforcement information, and more that must remain private and secure. Prior to the signing of this executive order, a uniform standard set of policies, procedures, and markings that applied to all agencies and departments did not exist. CUI is created or possessed by Government or it may be information that an entity creates or possesses for or on behalf of government, under contract.

Conversational UI - CUI is the next big digital disruption

cui connectors words

Associate Professor Tenured. We published a survey paper on out-of-distribution generalization here , accompanied with a website to maintain the paper list for OOD generalization. We have released the source code of StableNet , and its paper is here. We released a dataset, named NICO , for non-i. Kernelized Heterogeneous Risk Minimization.

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It’s All Relative: Italian Relative Pronouns That Will Awaken Your Italian Muse

Does anyone believe that now we can simply talk to our screens and get things done, without filling forms, dragging and dropping objects, and clicking buttons? Yes, a mere science fiction thirty years ago is going to become reality in the near future. Going forward, the entire field of visual interface design - literally everything we know about placing controls, handling the mouse and touch interaction - even picking colours - will be affected by the switch to conversational form, or will go away altogether. Source: Flickr. Though GUIs are here to stay for some time and cannot be done away with altogether, their monopoly is going to be challenged more than ever before by the rise of Conversational User Interfaces CUI bots, virtual assistants and invisible apps. As they become mainstream, Conversational User Interfaces CUI will forever change the way we design, develop and interact with our technology. In short, the Conversational UI is going to be the next big digital disruption.

ways: (i) connecting words that have the same tion of words that represent the same or similar between clinical words using the CUI attribute of.

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