On June 9, NARA released an implementation guidance document to help agencies prepare to meet Executive Order 13556. The guidance document provides agencies with some key information needed for them to prepare their CUI implementation plans. These plans are due to NARA in early November of this year.
Here are some of the highlights:
- They give guidance on how to handle legacy documents. This has been area of great interest to the government folks that we have been speaking with – they will appreciate the clarity.
- Safeguarding of CUI per existing OMB and NIST direction (a good thing – don’t think anyone wanted new standards).
- De-control dates for each category (welcome for various open government advocates).
- View into marking format: CUI//Authorized Category-Subcategory. Everyone’s been waiting for this one!
- They encourage portion marking. Portion marking refers to applying paragraph level markings that may be different than other markings within the same document or email. Portion marking is widely used across the intelligence and DoD community. It will be interesting to see this leveraged on the civilian side of things – end user training and education will be paramount to successful adoption.
Overall, this helps set the stage for what is to come. Expect to see more guidance issued as we get closer to the registry live date (November 2011, if they keep on track). The registry will hold all the approved CUI markings and be available to the public.
The guidance can be found at: http://www.fas.org/sgp/cui/guidance.pdf