03.01.22: Publicly Accessible Content

To meet the 03.01.22: publicly accessible content requirement, you must prevent Controlled Unclassified Information (CUI) and other sensitive system information from being posted to publicly accessible locations (websites, public repos, shared links, forums) without explicit authorization and safeguards. Operationalize it by inventorying public exposure paths, implementing technical blocking and review gates, and keeping recurring evidence that the controls run and catch issues. ¹

Key takeaways:

• Treat “publicly accessible content” as an exposure channel you must control, not a communications problem.
• Put review/approval gates in front of publishing systems and scanning/monitoring behind them.
• Evidence matters: retain inventories, approvals, scan results, and incident tickets tied to remediation.

Compliance teams usually struggle with this requirement because “public” content lives outside the core CUI enclave: marketing sites, support portals, collaboration tools, code repositories, and third-party file sharing. Those channels change fast and are often owned by non-security teams. The 03.01.22: publicly accessible content requirement forces you to put a control boundary around what can be published publicly, and to prove you have ongoing governance over that boundary. ¹

For a CCO, Compliance Officer, or GRC lead, the fastest path is to operationalize 03.01.22 as a repeatable process with clear ownership: (1) define what content is prohibited from public release, (2) identify where public release can happen, (3) implement preventive controls and approvals, (4) monitor for accidental exposure, and (5) retain evidence that the process works. ¹

This page gives requirement-level implementation guidance you can turn into tickets, procedures, and audit-ready artifacts. It assumes you handle CUI in nonfederal systems and need assessment-ready proof that public posting risk is controlled. ¹

Regulatory text

Requirement: “NIST SP 800-171 Rev. 3 requirement 03.01.22 (Publicly Accessible Content).” ¹

Operator interpretation (what you must do)

You must control what information from CUI-processing environments and related business processes can be made publicly accessible. In practice, that means you:

• prevent CUI (and CUI-derived content) from being published to public destinations;
• prevent system information that would help an attacker (credentials, internal IPs, configuration details, debug logs, architectural diagrams, security procedures) from being posted publicly; and
• can show governance, approvals, and monitoring over public publishing paths. ¹

This is not limited to your corporate website. “Publicly accessible” includes any location reachable by the general public without authentication, or accessible through anonymous/guest links that are effectively public (for example, “anyone with the link” sharing). Treat those as “public” for control purposes unless you can enforce access restrictions. ¹

Plain-English interpretation of the requirement

If your organization processes CUI, you cannot allow CUI (or sensitive system details) to end up on the open internet. You need a defined publishing process, technical controls that reduce human error, and monitoring that detects exposures quickly. Then you need to keep evidence that those safeguards operate over time. ¹

A practical way to frame it for operations:

• Policy question: “What content is prohibited from public release?”
• Systems question: “Where could someone accidentally publish it?”
• Control question: “What stops it, and what detects it if it slips through?” ¹

Who it applies to

Entity scope

• Federal contractors and subcontractors handling CUI in nonfederal systems.
• Any nonfederal organization operating systems that store, process, or transmit CUI under contractual or program requirements aligned to NIST SP 800-171. ¹

Operational scope (where this shows up)

This requirement touches multiple teams and platforms:

• Marketing/web team (corporate sites, landing pages, CMS)
• Engineering (public Git repositories, package registries, CI logs)
• IT/Collaboration (SharePoint/OneDrive/Google Drive links, wikis, ticketing portals)
• Customer support/success (knowledge bases, community forums, screen shares)
• HR/Recruiting (job postings, candidate portals with attachments)
• Third parties that host content for you (web agencies, managed service providers, content platforms) ¹

What you actually need to do (step-by-step)

Step 1 — Define “publicly accessible” and “prohibited content”

Create a short, enforceable standard that answers:

• Which destinations count as public (websites, public repos, public buckets, anonymous links, paste sites, forums, public issue trackers).
• Which data is prohibited from public release:
  • CUI and any document labeled/marked as CUI
  • Export-controlled or contract-restricted technical data, if applicable to your program
  • Secrets (API keys, tokens, passwords), private keys, certificates
  • Internal-only system details (network diagrams, security configs, vuln scan outputs, incident details)
• What is allowed (press releases, approved brochures) and who can approve exceptions. ¹

Deliverable: “Public Content & Posting Standard” owned by Security/GRC with Marketing/Engineering sign-off.

Step 2 — Inventory your public publishing paths (internal + third party)

Build and maintain a list of:

• domains and subdomains you control;
• hosting providers, CDNs, CMS platforms;
• public code orgs, repos, and project boards;
• file-sharing platforms where “public link” is possible;
• cloud storage with potential anonymous access;
• third parties who publish content on your behalf. ¹

Practical tip: make the inventory assessment-friendly. Include an owner, business purpose, and the “control gate” used (review workflow, DLP, scanning).

Step 3 — Put approval gates in front of publication

Implement “no direct publish” rules where you can:

• CMS publishing requires an approval workflow (editor + approver).
• Repo governance: restrict who can create public repos; require pull request review for changes to docs/content areas.
• Cloud storage: block anonymous public access by policy, and restrict “anyone with the link” settings.
• Support knowledge base: require review for attachments and screenshots; disable public posting of file types that commonly contain embedded metadata. ¹

Make approvals concrete:

• The approver checks classification/markings, customer identifiers, screenshots, logs, and attachments.
• The approver confirms the content source is sanctioned (no copy/paste from internal tickets containing CUI). ¹

Step 4 — Add technical prevention controls (reduce reliance on humans)

Depending on your stack, implement:

• DLP rules for common CUI markers, customer/program identifiers, and sensitive keywords.
• Secret scanning for keys/tokens in repos and web content.
• Cloud posture controls that block public buckets/containers and alert on policy drift.
• Outbound content controls for collaboration platforms to restrict public link creation. ¹

You do not need perfect detection to comply, but you do need a defensible design and proof it runs.

Step 5 — Continuous discovery and monitoring for exposures

Run recurring checks across your public surface:

• scan websites and public repos for sensitive patterns;
• monitor DNS/subdomain changes (shadow sites and forgotten hosts);
• alert on public-access configuration changes in cloud storage;
• review “new public repo created” events and access settings changes. ¹

Operationalize the response:

• create an incident ticket template for “public exposure,”
• define severity criteria and escalation,
• document containment steps (take down content, rotate credentials, invalidate caches),
• document root cause and corrective actions (training, workflow change, control tuning). ¹

Step 6 — Train the groups who publish

Targeted training beats broad annual training:

• marketing/web publishers: screenshots, PDFs, embedded metadata, customer logos/program names
• engineers: secrets, debug logs, public repo hygiene
• support: ticket sanitization, attachments, screen recordings ¹

Keep training short and role-specific; track attendance.

Step 7 — Map the requirement to policy, controls, and recurring evidence

Assessors will ask how you know the control keeps working. Build a simple control map:

• requirement → policy clause → technical controls → monitoring → evidence cadence → owner. ¹

Daydream (as a workflow) fits naturally here: keep the requirement-to-control mapping, assign owners, and schedule recurring evidence collection so you are not rebuilding proof during an assessment.

Required evidence and artifacts to retain

Keep artifacts that show both design and operation:

Governance and scope

• Public Content & Posting Standard (approved, versioned)
• Inventory of public publishing paths (with owners and platforms)
• Roles and responsibilities (RACI) for publishing, approval, monitoring, and incident response ¹

Preventive control evidence

• CMS/workflow screenshots or exports showing approval gates
• Repo settings exports (who can create public repos; branch protection rules)
• Cloud policy evidence showing public access blocked and exceptions governed ¹

Detective control evidence

• Scan configurations (what is scanned, patterns, scope)
• Monitoring alerts and weekly/monthly reports
• Sample findings with remediation tickets and closure proof ¹

Exceptions and incidents

• Exception requests and approvals (with business justification and compensating controls)
• Incident tickets for any public exposure, including containment and lessons learned ¹

Common exam/audit questions and hangups

Expect questions like:

• “Show me where you define what ‘publicly accessible’ means for your environment.” ¹
• “Which systems can publish content publicly, and who owns them?”
• “How do you prevent a user from making a file public by link?”
• “Do engineers have the ability to create public repos? Who approves that?”
• “Prove monitoring runs continuously. Show alerts, not just tool screenshots.”
• “Show an example of a caught issue and the remediation timeline.” ¹

Hangups that stall assessments:

• no complete inventory of publishing paths;
• reliance on “training” without technical controls;
• evidence that exists only as tribal knowledge in Slack/email, not retained. ¹

Frequent implementation mistakes (and how to avoid them)

1. Scoping only the corporate website.
   Fix: treat public repos, public cloud storage, knowledge bases, and “anyone with link” sharing as first-class scope items. ¹

2. No defined approver with authority.
   Fix: name roles and backups; require approvals in the system of record (CMS, ticketing) so evidence is automatic. ¹

3. Overbroad scanning that creates alert fatigue.
   Fix: start with high-signal patterns (secrets, CUI markers, specific program/customer identifiers), then tune. Document tuning decisions as part of control operation evidence. ¹

4. Exception sprawl.
   Fix: time-bound exceptions, require compensating controls, and review exceptions on a schedule tied to your governance cycle. ¹

Risk implications (why assessors care)

Public exposure is hard to contain. Once content is indexed, cached, forked, or copied, you may not be able to fully recover it. For CUI programs, that creates contractual risk, incident response burden, and potential loss of eligibility for future work depending on customer requirements. This is why evidence of prevention and detection is as important as the written policy. ¹

Practical 30/60/90-day execution plan

First 30 days (stabilize and define)

• Publish the Public Content & Posting Standard with clear prohibited content categories and an exception process. ¹
• Build the initial inventory of public publishing paths and assign owners.
• Implement quick wins: disable anonymous public links where possible; restrict public repo creation to admins; require approval in CMS where supported.
• Define evidence you will retain and where (GRC system, ticketing, document repository).

Days 31–60 (control build-out)

• Implement or tune DLP/secret scanning for top channels (web, repos, file sharing). ¹
• Establish monitoring and alert routing to a response queue with SLAs defined internally (your choice).
• Run a tabletop for “CUI posted publicly” and finalize the runbook steps and communications owners.
• Start role-based training for publishing teams; track completion.

Days 61–90 (operationalize and prove)

• Run recurring scans and produce a consistent report package (scope, findings, remediation status). ¹
• Test evidence readiness: pick a random week and assemble an assessor packet (inventory, approvals, scan logs, tickets).
• Tighten exception governance: review all open exceptions, close or renew with documented rationale.
• Put the control on a recurring compliance calendar in Daydream so evidence is collected continuously, not rebuilt during assessment.

Frequently Asked Questions

Does “publicly accessible” include “anyone with the link” file sharing?

Treat “anyone with the link” as publicly accessible unless you can enforce authentication and restrict link forwarding in practice. Write the rule in your standard and back it with tenant settings and monitoring evidence. ¹

Are public GitHub repos always prohibited?

Public repos are not automatically prohibited, but publishing CUI, secrets, or sensitive system information is. Control repo creation, require code review, run secret scanning, and keep audit logs that show the controls operate. ¹

What evidence is strongest for auditors on 03.01.22?

Evidence that shows operation over time: approval workflow records, scan results, alerts, and remediation tickets tied to closure. Pair that with an inventory of public publishing paths and an exception log. ¹

We outsource our website to a third party. Are we still responsible?

Yes. You still need governance over what the third party can publish and proof of controls (contract clauses, workflow approvals, and monitoring of the live site). Add the third party publishing channel to your inventory and evidence plan. ¹

How do we handle marketing content that references government programs or customers?

Route it through a defined approval process that checks contractual publicity restrictions and removes operational details that could reveal CUI context. Keep the approval record and final published artifact as evidence. ¹

What should we do if we find CUI on a public page today?

Treat it as an incident: remove or restrict access, preserve evidence (URLs, timestamps, copies), assess whether credentials or technical details were exposed, and document corrective actions. Keep the incident ticket and lessons learned as part of 03.01.22 evidence. ¹

Footnotes

1. NIST SP 800-171 Rev. 3