Alternative Work Sites
Enforce safeguarding measures for CUI at alternate work sites.
What an assessor scores, the objectives
PE.L2-3.10.6 is met only when every one of these 2 objectives, from NIST SP 800-171A, is satisfied. A single missed objective makes the whole requirement not met.
- a.safeguarding measures for CUI are defined for alternate work sites
- b.safeguarding measures for CUI are enforced for alternate work sites
How a C3PAO checks it
NIST SP 800-171A defines three assessment methods. For PE.L2-3.10.6, an assessor uses these:
Physical and environmental protection policy; procedures addressing alternate work sites for personnel; system security plan; list of safeguards required for alternate work sites; assessments of safeguards at alternate work sites; other relevant documents or records
Personnel approving use of alternate work sites; personnel using alternate work sites; personnel assessing controls at alternate work sites; personnel with information security responsibilities
Organizational processes for security at alternate work sites; mechanisms supporting alternate wo rk sites; safeguards employed at alternate work sites; means of communications between personnel at alternate work sites and security personnel
What it means, in context
Alternate work sites may include government facilities or the private residences of employees. Organizations may define different security requirements for specific alternate work sites or types of sites depending on the work-related activities conducted at those sites. NIST SP 800 -46 and NIST SP 800 -114 provide guidance on enterprise and user security when teleworking.
Many people work from home or travel as part of their job. Define and implement safeguards to account for protection of information beyond the enterprise perimeter . Safeguards may include physical protections, such as locked file drawers, as well as electronic protections such as encryption, audit logging, and proper access controls. Example Many of your company ’s project managers work remotely as they often travel to sponsor locations or even work from home. Because the projects on which they work require access to CUI, you must ensure the same level of protection is afforded as when they work in the office. You ensure that each laptop is deployed with patch management and anti- virus software protection [b]. Because data may be stored on the local hard drive, you have enabled full-disk encryption on their laptops [b]. When a remote staff member needs access to the internal network you require VPN connectivity that also disconnects the lapto p from the remote network (i.e. , prevents split tunneling) [b]. The VPN requires multifactor authentication to verify remote users are who they claim to be [b]. Potential Assessment Considerations • Do all alternate sites where CUI data is stored or processed meet the same physical security requirements as the main site [b]? • Does the alternate processing site provide information security measures equivalent to those of the primary site [b]?
What passing evidence looks like
The alternate work site rule (home offices, client sites) and the safeguards there: locked space, encrypted managed device, no household access to CUI, in a short signed acknowledgment per remote worker.
Common ways contractors fail PE.L2-3.10.6
- !If anyone opens CUI from home, the home office is an alternate work site and needs the documented safeguards. The one page acknowledgment (screen lock, encrypted laptop, family does not use the machine, paper locked away) closes it.
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PE.L2-3.10.6 questions, answered
How many points is CMMC requirement PE.L2-3.10.6 worth?+
PE.L2-3.10.6 is worth 1 point in the CMMC Level 2 score under 32 CFR 170.24. If it is not met, you lose 1 from your total of 110.
Can PE.L2-3.10.6 be placed on a POA&M?+
Yes. A gap on PE.L2-3.10.6 can be deferred to a Plan of Action and Milestones, provided your overall score is 88 or better and the item closes within 180 days.
What family does PE.L2-3.10.6 belong to?+
PE.L2-3.10.6 is in the Physical Protection (PE) family, one of the 14 families of NIST SP 800-171 that make up CMMC Level 2.
- NIST SP 800-171 Rev. 2 3.10.6