Nsacss P 6-22 20191121 Handling of Nsa-Css Information Storage Media

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UNCLASSIFIED

NSA/CSS POLICY 6-22


HANDLING OF NSA/CSS
INFORMATION STORAGE MEDIA

PUBLICATION INFORMATION
DATE: 21 November 2019 (See Document History)

OFFICE OF PRIMARY Security Engineering Services, 968-7777s.


INTEREST:
RELEASABILITY: This policy is approved for public release. The official document is
available on the Office of Policy (P12) website (“go policy”).

AUTHORITY: Gregory L. Smithberger, NSA/CSS Chief Information Officer


ISSUED: 9 June 2017

PURPOSE AND SCOPE


1. This document establishes policy and assigns responsibilities for the secure handling of
all NSA/CSS information storage media (ISM), including the proper labeling of classified and
unclassified ISM, the administrative declassification of previously classified ISM, and obtaining
approval to release these media from controlled facilities. ISM includes, but is not limited to,
magnetic storage, optical storage, and solid state storage, whether the ISM is connected to an
information system (IS) internally or externally.

2. This policy applies to users of all classified and unclassified IS resources for which the
Director, NSA/Chief, CSS has operational information system security responsibility. This policy
implements relevant portions of References a, b, and c.

POLICY
3. All ISM must be protected at the more restrictive of the following levels of
classification:

a. The classification of the data stored on the ISM, including handling caveats and
dissemination controls; or

b. The classification of the most restrictive data that can be accessed on the IS
security domain in which the ISM has been used.

4. All ISM shall bear external security labels or markings indicating the most restrictive
security classification at which it must be protected, in accordance with NSA/CSS Policy Manual
1-52, “NSA/CSS Classification Guide” (Reference d).

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5. If an ISM used in a less restrictive security domain is subsequently used in a more


restrictive security domain, it permanently assumes the sensitivity of the more restrictive domain
and must be relabeled to reflect the more restrictive classification or security requirements. See
paragraph 9 for guidance specific to optical ISM.

6. ISM labeled for use in a more restrictive IS security domain shall not be used in a less
restrictive IS security domain. Data that is classified at a less restrictive level than an IS security
domain may be written to a brand-new ISM without taking on the more restrictive requirements
of the IS security domain only after completion of the steps described in paragraph 32.

7. ISM users shall scan removable media each time it is used in an NSA/CSS IS using
current NSA/CSS Enterprise Solutions Baseline-approved anti-malware software, in accordance
with NSA/CSS Policy 6-7, “Malware Incident Prevention and Handling” (Reference e).

8. The use of ISM that are considered to be removable media (e.g., optical discs, thumb
drives, SD cards) shall be in accordance with NSA/CSS Policy Instruction 6-0004, “Using
Removable Media for Data Transfer on NSA/CSS Information Systems” (Reference f). Given
the restrictions of this policy and the destructive nature of the ISM sanitization techniques
outlined in NSA/CSS Policy Manual 9-12, “NSA/CSS Storage Device Sanitization Manual”
(Reference g), a magnetic or solid-state ISM may only be used for a single data transfer between
security domains of differing classification levels. Any requests for exception to this restriction
must follow the requirements in paragraph 33. See paragraph 9 for guidance specific to optical
ISM.

9. Optical storage media (e.g., CD, DVD) labeled for a less restrictive IS security domain
may be used in an IS of a more restrictive IS security domain without a change to the optical
ISM classification status provided the user can confirm that the optical storage drive in the more
restrictive IS is read-only. If the user cannot confirm that the optical storage drive in the more
restrictive IS is read-only, then the optical ISM must assume the classification/sensitivity of the
most restricted information processed on that system and the ISM must be relabeled accordingly.

10. Under no circumstances shall personally-owned or -produced media (e.g., music


CDs) be used in any classified or unclassified NSA/CSS IS or network.

11. Classified ISM from a controlled facility can be released to an uncontrolled facility
for recycling or disposal only after it has been sanitized and then administratively declassified in
accordance with ICS 500-18, “Removable Media Management” (Reference a), and Reference g.
The release of an ISM is an administrative risk decision that can only be made after all
sanitization procedures have been successfully completed.

12. Classified ISM may be used to transport information between NSA/CSS-controlled


areas according to the guidance in NSA/CSS Policy 5-25, “Hand-Carrying Classified Material”
(Reference h).

13. Continual administrative declassification and release of ISM that is a requirement of


an organization’s daily mission shall be documented and maintained as part of the System
Security Plan (SSP) for the system(s) in question.

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14. ISM that is categorized as a restricted item per the requirements of NSA/CSS Policy
Manual 5-23, “Physical Security Requirements for Controlled Areas Manual” (Reference i),
must be approved by an appropriate Information System Security Manager (ISSM) (“go issm”)
and Security and Counterintelligence prior to being introduced into an NSA/CSS sensitive
compartmented information facility (SCIF).

PROCEDURES
Labeling ISM

15. ISM must be labeled with a color-coded security label or otherwise marked to clearly
identify the approved classification level of the ISM. Color-coded security labels (Standard
Forms 706 through 712) may be ordered through the supply system or by contacting an
appropriate Information System Security Officer (ISSO) (“go isso”).

16. Security labels shall be affixed to all ISM in a manner that does not adversely affect
proper operation of media devices or drives.

17. Optical storage media shall have the approved classification level written in
permanent marker on the media itself. Color-coded security labels may be affixed to the external
cases.

18. ISM that is too small to reasonably attach a security label to may be otherwise
marked in a manner that clearly indicates the classification of the ISM. For example:

a. A microSD card could be marked with a serial number that corresponded to a


number on its case, and the classification of the media could be marked on the case.

b. A USB flash drive could have a lanyard affixed to it, and the classification of
the drive could be marked on the lanyard.

19. Unlabeled ISM still in the vendor’s original packaging (i.e., shrink-wrap) shall be
treated as unclassified.

20. Unlabeled ISM that is not in the manufacturer’s original package shall be stored and
protected at the classification level of the facility to minimize the possibility of compromise to
classified or sensitive information. Users should contact their local facility mission security
officer (MSO) (“go msos”) with questions about storage of classified information.

Sanitizing and administratively declassifying ISM

Unclassified ISM

21. Unclassified ISM never used in a classified IS, and not containing for official use
only (FOUO) information, Privacy Act information, or personally identifiable information (PII),
does not require sanitizing.

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22. Unclassified ISM never used in a classified IS, and containing FOUO, Privacy Act, or
PII data shall be sanitized before release for disposal or recycling to properly protect the
information in accordance with Reference d and NSA/CSS Policy 1-22, “Protecting Privacy on
NSA/CSS Electronic Information Systems” (Reference j).

23. Personally-produced unclassified music CDs must remain in the workplace and must
be disposed of through the special burn process when no longer needed, in accordance with
Reference i.

Sanitizing ISM

24. Requests for sanitization of ISM must be authorized by the requestor’s


supervisor/government lead, the appropriate ISSO (“go isso”), and the appropriate system owner.

25. Media that has ever contained classified information, other than communications
security (COMSEC) material, shall be sanitized using the destruction procedures specified in
Reference g. Media that has ever contained COMSEC material shall be destroyed using the
procedures specified in CNSSI 4004.1, “Destruction and Emergency Procedures for COMSEC
and Classified Material” (Reference k). If the COMSEC status of the information is unknown,
the media shall be sanitized using the more destructive sanitization procedure of those listed for
that media type in Reference g or Reference k.

26. Methods for the sanitizing of classified ISM will be different for magnetic, solid state,
and optical storage devices. Instructions for each type are provided in Reference g.

27. At the completion of the sanitization process, all labels or markings that indicate
previous use or data classification shall be removed.

Administrative Declassification

28. Administrative declassification of ISM may only be authorized by an appropriate


ISSO (“go isso”), the requestor’s supervisor/government lead, and the system owner upon
successful completion of sanitization procedures.

29. Administrative declassification of ISM shall be recorded by the ISSO and shall
include the following:

a. A description of the media (type, manufacturer, model number, serial number);

b. The classification of the data on the media;

c. A description of the sanitization procedures;

d. The name(s) of the individual(s) executing the procedures (e.g., data transfer
agent (DTA)/ISSO/system administrator) as well as the names of at least two individuals
who have verified the results. Individual(s) executing the procedures may also be
included as the individuals verifying the results;

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e. The detailed reason for the release;

f. The intended recipient of the ISM; and

g. The date of administrative declassification approval.

30. If an ISM cannot be sanitized, it must not be administratively declassified or released


from an NSA/CSS-controlled facility, and must be maintained or destroyed in accordance with
Reference g.

Release of ISM

31. Classified magnetic and solid state ISM may be released from an NSA/CSS-
controlled facility to an environment not controlled by NSA/CSS only if the ISM meets the
following conditions:

a. The ISM is capable of being sanitized;

b. The sanitization process has been successfully completed in accordance with


this policy and Reference g;

c. The administrative declassification process has been documented and approved


by the appropriate supervisor/government lead, ISSO, and system owner; and

d. The ISM is relabeled, if applicable, in accordance with requirements in this


policy and Reference g.

32. Data of a less restrictive classification produced on a classified IS may be written to a


new, never-used ISM in accordance with the NSA/CSS Data Transfer Agent process (“go dta”).
This ISM may then be labeled UNCLASSIFIED, CONFIDENTIAL, or SECRET, as appropriate.
The requestor must obtain documented authorization from their supervisor/government lead and
an appropriate ISSO (“go isso”). The requestor should consult a Classification Advisory Officer
(CAO) about proper classification and marking of the data being transferred. However, it is
ultimately the responsibility of the requestor to ensure that the classification of the information is
consistent with the classification constraints of the system to which the data is being transferred.
If UNCLASSIFIED data is intended for public release, the requestor must request a
prepublication review in accordance with NSA/CSS Policy 1-30, “Review of NSA/CSS
Information Intended for Public Release” (Reference l).

Exceptions

33. Organizations requesting an exception to this policy will submit a formal written
request to the appropriate ISSO (“go isso”) for review. The ISSO will then forward the request to
the NSA/CSS Deputy Authorizing Official (AO) for a decision. Exception decisions will be made
on a case-by-case basis. The Deputy AO will notify the Security and Counterintelligence Group
of all exceptions granted. The appropriate ISSO shall review exceptions annually. If the
exception is still required, an updated request must be submitted to the Deputy AO.

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RESPONSIBILITIES
Directors, Cryptologic Center Commanders/Chiefs, and Service Cryptologic Component
Commanders

34. The Directors, Cryptologic Center Commanders/Chiefs, and Service Cryptologic


Component Commanders shall establish procedures to provide oversight for, and ensure proper
control of, all ISM under their purview.

Security and Counterintelligence Group

35. The Security and Counterintelligence Group shall:

a. Render documented decisions, in coordination with appropriate ISSMs, on


requests for the introduction/removal of restricted ISM to/from an NSA/CSS SCIF.

b. Conduct counterintelligence IS security incident reviews for incidents


involving ISM and coordinate, as appropriate, with the Office of the Inspector General
(OIG), the appropriate ISSO, the NSA/CSS Information Systems Incident Response
Team (NISIRT), and the Office of the General Counsel.

NSA/CSS Deputy Authorizing Official (AO)

36. The NSA/CSS Deputy Authorizing Official (AO) shall:

a. Render documented decisions on requests for exceptions to this policy; and

b. Inform the Security and Counterintelligence Group of any approved exception


requests.

Supervisors and Government Leads

37. Supervisors (for government personnel) and government leads (for contractor
employees) shall:

a. Render documented decisions, in coordination with the appropriate ISSO and


system owner, on requests to sanitize ISM;

b. Determine the requirement for ISM under their purview to be administratively


declassified and/or released based on mission and operational need;

c. Render documented decisions, in coordination with the appropriate ISSO and


system owner, on requests by subordinates to administratively declassify and/or release
ISM under their purview; and

d. Coordinate with the appropriate ISSO to review requests by subordinates for


data transfers using removable media.

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Information System Security Managers (ISSMs)

38. Information System Security Managers (ISSMs) shall:

a. Render documented decisions, in coordination with Security and


Counterintelligence, on requests for the introduction/removal of restricted ISM to/from
an NSA/CSS SCIF; and

b. Review all computer security incident reports (CSIRs) related to sanitized,


declassified, and/or released ISM to determine possible impact on the integrity of data on
systems under their purview and inform the Security Health Officers (SHO) of any such
impact.

Information System Security Officers (ISSOs)

39. Information System Security Officers (ISSOs) shall:

a. Render documented decisions, in coordination with the appropriate supervisor


and system owner, on requests to sanitize media for systems under their purview;

b. Render documented decisions, in coordination with the appropriate supervisor


and system owner, on requests to administratively declassify and/or release ISM under
their purview;

c. Ensure that the release of ISM under their purview is in accordance with this
policy;

d. Coordinate with the requestor’s supervisor/government lead to review requests


for data transfers using removable media and systems under their purview;

e. Ensure users of systems under their purview comply with this policy and the
procedures implementing it through education, awareness, and random physical
inspections of ISM to ensure that all ISM is labeled in accordance with this policy and
Reference a;

f. Review requests for exceptions to this policy and forward to the NSA/CSS
Deputy AO for decision. Any approved exceptions must be reviewed annually for
continued need. If the exception is still required, an updated request must be submitted to
the Deputy AO for decision;

g. Review any approved exceptions annually for continued need. If the exception
is still required, an updated request must be submitted to the Deputy AO for decision;

h. Ensure that Deputy AO-approved requests for exceptions are documented in


the appropriate SSP;

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i. Perform, or supervise the performance of, sanitizing of ISM under their purview
in accordance with Reference g, this policy, and its administrative declassification
procedures; and

j. Maintain a copy of the administrative declassification/release authorization


pertaining to ISM under their purview.

System Owners

40. System owners shall:

a. Render documented decisions, in coordination with the appropriate supervisor


and ISSO, on requests to sanitize media for systems under their purview; and

b. Render documented decisions, in coordination with the appropriate supervisor


and ISSO, on requests to administratively declassify and/or release ISM associated with
systems under their purview.

Center for Storage Device Sanitization Research

41. The Center for Storage Device Sanitization Research shall provide technical guidance
for the sanitization and/or destruction of ISM (Reference g).

REFERENCES
a. Intelligence Community Standard (ICS) 500-18, “Removable Media Management,” dated 16
February 2011

b. Committee on National Security Systems Policy (CNSSP) No. 26, “National Policy on
Reducing the Risk of Removable Media for National Security Systems,” dated May 2013

c. Department of Defense Instruction (DoDI) 8500.01, “Cybersecurity,” dated 14 March 2014

d. NSA/CSS Policy Manual 1-52, “NSA/CSS Classification Guide,” dated 2 June 2015

e. NSA/CSS Policy 6-7, “Malware Incident Prevention and Handling,” dated 4 January 2017

f. NSA/CSS Policy Instruction 6-0004, “Using Removable Media for Data Transfer on
NSA/CSS Information Systems,” dated 19 February 2016

g. NSA/CSS Policy Manual 9-12, “NSA/CSS Storage Device Sanitization Manual,” dated 15
December 2014

h. NSA/CSS Policy 5-25, “Hand-Carrying Classified Material,” dated 16 December 2014

i. NSA/CSS Policy Manual 5-23, “Physical Security Requirements for Controlled Areas
Manual,” dated 20 May 2013

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j. NSA/CSS Policy 1-22, “Protecting Privacy on NSA/CSS Electronic Information Systems,”


dated 9 January 2012

k. Committee on National Security Systems Instruction (CNSSI) 4004.1, “Destruction and


Emergency Procedures for COMSEC and Classified Material,” dated August 2006, with Annex
B as amended, dated 24 October 2008

l. NSA/CSS Policy 1-30, “Review of NSA/CSS Information Intended for Public Release,” dated
13 May 2015

GLOSSARY
administrative declassification—The process of recording information about the sanitization of
information storage media (ISM). This information must be recorded before sanitized media may
be released from an NSA/CSS-controlled facility (e.g., for destruction or recycling). These steps
are authorized and performed by an information systems security officer (ISSO) and include
recording the following information about ISM: a description of the media; classification of the
data on the media (prior to sanitization); sanitation procedures; who performed the procedures;
reason for release; intended recipient; and date of administrative declassification approval.

Authorizing Official (AO)—Senior (Federal) official with the authority to formally assume
responsibility for operating an information system at an acceptable level of risk to organizational
operations (including mission, functions, image, or reputation), organizational assets,
individuals, other organizations, and the Nation. (Source: NSA/CSS Policy Glossary)

Classification Advisory Officer (CAO)—Individuals responsible for assisting their


organizations to ensure that protected information is properly classified, marked, and
safeguarded and that the employees in their organizations understand and properly apply
classification rules and guidance. (Source: NSA/CSS Policy Glossary)

exception—Indicates that an implementation of one or more security requirements is


temporarily postponed and that satisfactory mitigations for the requirement(s) may be used for a
specified period of time. This is in contrast to a waiver that implies a security requirement has
been set aside and need not be implemented at all. (Source: NSA/CSS Policy Glossary)

information storage media (ISM)—Data storage objects capable of being read from, or written
to, by an IS to include, but not limited to, diskettes, optical disks, CDs, DVDs, thumb drives, and
other removable media. Other terms for ISM include magnetic storage media, data storage
media, or removable storage media.

information system (IS)—Any telecommunications and/or computer-related equipment or


interconnected system or subsystems of equipment that is used in the acquisition/collection,
storage, manipulation, management, movement, control, display, switching, interchange,
transmission, or reception of voice and/or data, and includes software, firmware, and hardware.
IS examples are: stand-alone systems, Local Area Networks (LANs), supercomputers, process
control computers that perform special purpose computing functions (e.g., Supervisory Control
and Data Acquisition (SCADA), other Industrial Control Systems, embedded computer systems),

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and the communications networks that disseminate information. (Source: NSA/CSS Policy
Glossary)

information system security—The protection of information systems (ISs) against unauthorized


access to or modification of information, whether in storage, processing, or transit, and against
the denial of service to authorized users, including those measures necessary to detect, document,
and counter such threats. (Source: NSA/CSS Policy Glossary)

Information System Security Manager (ISSM)—Individual responsible for the information


assurance of a program, organization, system, or enclave. (Source: NSA/CSS Policy Glossary)

Information Systems Security Officer (ISSO)—Individual assigned responsibility for


maintaining the appropriate operational security posture for an information system or program.
(Source: NSA/CSS Policy Glossary)

magnetic storage—Tapes, hard disk drives, diskettes, and other magnetic media which store
data.

Mission Security Officer (MSO)—A professional Security Officer assigned to a Directorate,


Associate Directorate, or major office, to provide full-range security guidance and assistance to
senior management, supervisors, and all personnel within the assigned organization.

NSA/CSS Enterprise Solution Baseline—A common suite of enterprise approved standard


hardware and software products that support corporate goals to reduce IT complexity, improve
collaboration through interoperability, improve information system security, and manage IT
costs. (Source: NSA/CSS Policy Glossary)

optical storage—Compact Disks (CD), Digital Versatile Disks (DVD), and other optical
removable media (i.e., Blu-Ray, Holographic) which store data. (Source: NSA/CSS Policy
Glossary)

personally identifiable information (PII)—Information which can be used to distinguish or


trace an individual’s identity, such as his or her name; social security number; date and place of
birth; mother’s maiden name; and biometric records, including any other personal information
which is linked or linkable to a specified individual. (Source: NSA/CSS Policy Glossary)

release—Final authorization given by the ISSO to allow ISM to leave an NSA/CSS-controlled


facility. Classified media may only be released after approved sanitization and administrative
declassification procedures have been completed.

sanitization—The removal of information from the storage device such that data recovery using
any known technique or analysis is prevented. Sanitization includes the removal of data from the
storage device, as well as the removal of all labels, markings, and activity logs. The method of
sanitization varies depending upon the storage device in question, and may include degaussing,
incineration, shredding, grinding, embossing, etc. (Source: NSA/CSS Policy Glossary)

security domain—A domain that implements a security policy and is administered by a single
authority. (Source: CNSSI 4009)

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security label—Information that represents or designates the value of one or more security
relevant attributes (e.g., classification) of a system resource. (Source: CNSSI 4009)

solid state storage—Random access memory (RAM), read-only memory (ROM), field
programmable gate array (FPGA), and smart cards which store data (solid state storage includes
thumb drives and other portable flash memory). (Source: NSA/CSS Policy Glossary)

system security plan (SSP)—The formal document prepared by the information system owner
(or common security controls owner for inherited controls) that provides an overview of the
security requirements for the system and describes the security controls in place or planned for
meeting those requirements. The plan can also contain as supporting appendices or as references,
other key security-related documents such as a risk assessment, privacy impact assessment,
system interconnection agreements, contingency plan, security configurations, configuration
management plan, and incident response plan. (Source: NSA/CSS Policy Glossary)

DOCUMENT HISTORY
Date Approved by Description
9 June 2017 Gregory L. Smithberger, Policy issuance; supersedes NSA/CSS
NSA/CSS Chief Policy 6-22 dated 27 May 2015
Information Officer
21 November 2019 Chief, Policy An administrative update to incorporate
accessibility enhancements

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