Control statement
- a.Establish policy and procedures to ensure that requirements for the protection of controlled unclassified information that is processed, stored or transmitted on external systems, are implemented in accordance with applicable laws, executive orders, directives, policies, regulations, and standards; and
- b.Review and update the policy and procedures [Organization-defined: organization-defined frequency].
Discussion
Controlled unclassified information is defined by the National Archives and Records Administration along with the safeguarding and dissemination requirements for such information and is codified in [32 CFR 2002](#91f992fb-f668-4c91-a50f-0f05b95ccee3) and, specifically for systems external to the federal organization, [32 CFR 2002.14h](https://www.govinfo.gov/content/pkg/CFR-2017-title32-vol6/xml/CFR-2017-title32-vol6-part2002.xml) . The policy prescribes the specific use and conditions to be implemented in accordance with organizational procedures, including via its contracting processes.
Organization-defined parameters
These values must be resolved through the organization’s tailoring and governance process. Bracketed parameter references in the control text identify where a decision is required.
From control text to operational evidence
Use Protecting Controlled Unclassified Information on External Systems as a testable risk decision. Translate the official statement into accountable people, repeatable processes, configured technology, and evidence that demonstrates the outcome over time. In this family, pay particular attention to enterprise program governance, accountability, resources, metrics, and organization-wide risk decisions.
Implementation workflow
- Define the control boundary, responsible owner, inherited portions, and systems or processes in scope.
- Resolve each organization-defined parameter before declaring the control implemented.
- Document how the implementation satisfies every clause of the official control statement.
- Collect evidence as a normal byproduct of operation rather than only before an assessment.
- Review exceptions, changes, and monitoring results on a risk-based cadence.
Evidence examples
- program charters and policies
- governance meeting records
- risk and performance metrics
- resource and responsibility assignments
Common failure patterns
- program metrics count activity instead of outcomes
- system-level risks never reach enterprise governance
- responsibilities assigned without authority or resources
- privacy and security managed in separate silos
Questions practitioners should ask
- What risk decision is this control intended to support in this system?
- Which parts are implemented locally, inherited, shared, or not applicable—and what evidence supports that decision?
- Do the documented narrative, deployed configuration, operating process, and collected evidence agree?
- What event or threshold requires the implementation to be reviewed or changed?
Assessment objectives and methods
Show the assessment objective
- PM-17a.
- PM-17a.[01]policy is established to ensure that requirements for the protection of controlled unclassified information that is processed, stored, or transmitted on external systems are implemented in accordance with applicable laws, executive orders, directives, policies, regulations, and standards;
- PM-17a.[02]procedures are established to ensure that requirements for the protection of controlled unclassified information that is processed, stored, or transmitted on external systems are implemented in accordance with applicable laws, executive orders, directives, policies, regulations, and standards;
- PM-17b.
- PM-17b.[01]policy is reviewed and updated [Organization-defined: frequency];
- PM-17b.[02]procedures are reviewed and updated [Organization-defined: frequency]
Examine
- Controlled unclassified information policy
- controlled unclassified information procedures
- other relevant documents or records.
Interview
- Organizational personnel with controlled unclassified information responsibilities
- organizational personnel with information security responsibilities.
Related controls
These relationships come from the official OSCAL catalog. They indicate useful dependencies or context, not automatic inheritance or equivalence.
Authoritative sources
Bare Metal Cyber is an independent educational publisher and is not affiliated with or endorsed by NIST. Official control requirements and interpretations remain with NIST and the responsible authorizing organization.