03.04.11: Information Location

To meet the 03.04.11: information location requirement, you must maintain an accurate, current view of where CUI resides and flows across your environment (systems, services, regions, and third parties), and be able to prove it during an assessment. Operationally, that means building and maintaining a CUI data map tied to approved storage/processing locations and enforcing it through configuration and governance. ¹

Key takeaways:

• You need a defensible inventory and map of CUI locations (including cloud regions and third parties), not a one-time diagram. ¹
• Auditors look for traceability: CUI categories → repositories → systems → owners → controls/evidence. ¹
• The common failure mode is unknown or uncontrolled copies (SaaS sprawl, endpoint sync folders, email, collaboration tools). ¹

03.04.11 is a requirement you operationalize by answering a deceptively simple question: “Where is our CUI, right now?” In a real contractor environment, CUI rarely stays in one place. It lands in intake mailboxes, moves into ticketing systems, gets attached to chat threads, syncs to endpoints, and ends up inside third-party tooling used by Engineering, Program Management, or Procurement. If you cannot identify those locations, you cannot credibly claim you are protecting CUI, because you cannot scope controls, monitoring, incident response, retention, or access boundaries to the actual places the data exists. ¹

For a CCO or GRC lead, the fastest path is to treat “information location” as a repeatable operational process: define authorized locations, map and validate actual locations, close gaps, and keep evidence current. This page gives requirement-level implementation guidance you can hand to system owners, IT, and security engineering, then use to pass an assessment with clean, reviewable artifacts. ¹

Regulatory text

Requirement: “NIST SP 800-171 Rev. 3 requirement 03.04.11 (Information Location).” ¹

Operator interpretation: You must be able to identify, document, and keep current the locations where CUI is stored, processed, or transmitted in your nonfederal environment, including locations managed by third parties. You also need to control those locations by defining what is authorized and detecting or correcting what is not. ¹

Plain-English interpretation (what this means in practice)

03.04.11 means you can’t protect CUI by policy statements alone. You need a working, maintained answer to:

• Which CUI categories do we handle?
• Which systems and services touch them?
• Where does that data physically/logically live (data stores, tenants, cloud regions, backups, replicas, endpoint caches)?
• Who owns each location and what control set applies?

A strong implementation makes CUI location discoverable, reviewable, and enforceable. A weak one is a stale spreadsheet created during an audit scramble. ¹

Who it applies to

Entities:

• Federal contractors and subcontractors handling CUI in nonfederal systems. ¹
• Any nonfederal organization operating systems that store, process, or transmit CUI. ¹

Operational contexts where this control becomes “real”:

• Cloud migrations: IaaS/PaaS services, SaaS collaboration suites, CI/CD platforms.
• Distributed work: endpoints, sync clients, local caches, mobile access.
• Third-party workflows: managed service providers, external support desks, eDiscovery tools, payroll/HR tools that may receive attachments, and any subcontractor receiving CUI.

If CUI touches it, it is in scope for location mapping and location control. ¹

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

Use this as an execution checklist you can assign and track.

Step 1: Define what “authorized locations” means for your organization

1. Set CUI handling boundaries (e.g., “CUI only allowed in these approved tenants, repositories, and endpoint configurations”).
2. Define location attributes you will track:
   • System/service name and type (SaaS, IaaS, endpoint, on-prem file server)
   • Environment/tenant/subscription/account
   • Region/geo (as applicable)
   • Data store(s): buckets, databases, file shares, document libraries, ticket attachments
   • Backup/replication locations
   • Owner (business + technical)
   • Third party involvement (processor, subprocessor, MSP)
3. Document approvals: who can approve a new CUI location, and what gates must be satisfied (security review, contract review, configuration baseline).

Output: “Authorized CUI Locations Standard” (one-pager plus a register) mapped to system owners. ¹

Step 2: Build a CUI data inventory and flow map that is assessment-ready

1. Start from CUI entry points: contracting inboxes, portals, SFTP drops, customer shared drives, ticketing intake, engineering exchanges.
2. Map flows: entry point → processing systems → collaboration → storage → archival → destruction.
3. Tie each flow step to a concrete location (not “SharePoint,” but “Tenant X, Site Y, Library Z,” and who administers it).
4. Include shadow locations you see in practice:
   • Email attachments and mailboxes
   • Chat/file shares inside collaboration tools
   • Endpoint sync folders
   • Screenshots and exported PDFs
   • Logs that may contain CUI fragments (tickets, application logs, analytics exports)

Output: CUI Data Map + CUI Location Register (your system of record). ¹

Step 3: Validate actual locations against authorized locations

1. Reconcile against system inventories (CMDB, asset inventory, SaaS inventory).
2. Run targeted discovery:
   • Repository searches for CUI markings/keywords where feasible
   • DLP signal review (if you have it)
   • Export lists of storage resources (buckets, sites, projects) and review ownership
3. Interview process owners for “where do you put it when…” scenarios (proposal writing, subcontractor collaboration, support escalations).

Output: Location Validation Report: “Authorized vs Actual,” with gaps logged as findings. ¹

Step 4: Close gaps with technical and procedural controls

Typical remediation patterns:

• Block/limit new locations: restrict creation of new repositories, projects, or external sharing without approval.
• Fix configuration: disable anonymous links, enforce tenant restrictions, restrict external domains, require managed devices for sync.
• Move data: migrate CUI out of personal drives, unapproved SaaS, or unmanaged endpoints into approved repositories.
• Update contracts and third-party controls: ensure third parties that store/process CUI are known, approved, and governed.

Output: Remediation tickets with closure evidence and updated location register. ¹

Step 5: Operationalize: make location tracking continuous, not episodic

1. Assign owners for each CUI location (named role + backup).
2. Set change triggers:
   • New contract/program handling CUI
   • New SaaS adoption or integration
   • New subcontractor added
   • New cloud account/subscription
   • Major org restructure (owner changes)
3. Run periodic attestations by system owners that the location register is accurate and that unauthorized locations were not introduced.
4. Collect recurring evidence on a cadence that matches your environment’s change rate.

How Daydream fits naturally: If your struggle is keeping the location register and evidence current across many systems and third parties, Daydream can track control mappings, owners, and recurring evidence requests so “information location” stays continuously reviewable instead of rebuilt during audit season. ¹

Required evidence and artifacts to retain

Auditors typically want artifacts that show completeness, currency, and control. Keep:

• CUI Location Register (system of record) with owners, repositories, and regions/tenants where applicable. ¹
• CUI Data Flow Map (diagram + narrative) tied to the register. ¹
• Authorized Locations Standard and approval workflow (policy/procedure + RACI). ¹
• Discovery/validation outputs (exported lists, review notes, DLP findings summaries where available). ¹
• Remediation records: tickets, change requests, migration logs, updated configurations. ¹
• Third-party inventory for CUI-related processing, including which third parties host or access CUI and where. ¹
• Attestations from system owners and program owners that locations remain accurate.

Common exam/audit questions and hangups

Expect questions like:

1. “Show me everywhere CUI is stored.” Be ready to produce the register and walk from CUI category to system to repository. ¹
2. “How do you prevent CUI from ending up in unauthorized SaaS?” They will look for governance plus technical guardrails. ¹
3. “What about backups, replicas, and exports?” If you ignore these, the assessor will treat the control as incomplete. ¹
4. “Which third parties store or process CUI, and where?” A hand-wave like “our MSP handles it” won’t pass. ¹
5. “How do you keep this current?” A register with no owner, no change triggers, and no periodic review is a predictable finding. ¹

Frequent implementation mistakes (and how to avoid them)

Mistake	What it looks like	How to avoid it
Treating “location” as only data centers	“CUI is in AWS” with no account/region/store detail	Track tenant/account, region, and specific storage services and repositories. 1
Missing “incidental” CUI stores	Tickets, chat uploads, email, endpoint sync caches omitted	Start mapping from workflows, not from IT assets. Validate with interviews plus exports. 1
Confusing policy with proof	A policy says “CUI must be stored in X” but no evidence	Keep system exports, access reviews, and change records tied to the register. 1
Third-party blind spots	Subcontractors or SaaS processors not recorded	Maintain a third-party list for CUI and link each to the specific CUI locations they touch. 1
One-time mapping	A diagram built for an assessment then ignored	Add change triggers and periodic owner attestations; track deltas as part of normal operations. 1

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this guidance stays grounded in the framework text. ¹

Practically, weak information-location control increases risk in predictable ways:

• Scoping failure: you cannot confidently claim which systems are in-scope for CUI controls. ¹
• Incident response delays: you lose time identifying affected repositories and third parties during a suspected spill or breach. ¹
• Uncontrolled sharing: unauthorized copies proliferate into tools with weaker access control, retention, or logging. ¹

Practical 30/60/90-day execution plan

First 30 days (establish the control surface)

• Name an executive owner and operational owner for the CUI Location Register.
• Publish “Authorized CUI Locations” and an approval workflow for new locations.
• Build the first version of the register from known systems, contracts, and program workflows. ¹

By 60 days (validate and remediate)

• Validate the register with exports from key systems (cloud accounts, collaboration suites, ticketing, file storage).
• Identify unauthorized locations and create remediation tickets (move, block, or reconfigure).
• Link third parties to the exact CUI locations and data flows they touch. ¹

By 90 days (operate and evidence)

• Implement a standing review process tied to change triggers (new program, new tool, new third party, new cloud account).
• Start periodic owner attestations and evidence capture (exports, review notes, closed tickets).
• Conduct an internal tabletop: “A CUI spill is reported, show where it could exist and how you would contain it.” ¹

Frequently Asked Questions

Does 03.04.11 require knowing the physical street address of every server?

You need a defensible understanding of where CUI resides in your environment, which often means logical and administrative location (tenant/account, region, repository) rather than street addresses. Track physical details when you manage on-prem infrastructure directly. ¹

We use SaaS tools. What counts as “information location” there?

The location is your tenant plus the specific repositories and sharing surfaces where CUI can live (sites, projects, tickets, attachments), and any region/geo choices the SaaS exposes. Your evidence should show you know and govern those locations. ¹

Do backups and archives have to be included in the location register?

Yes, if they contain CUI. Include backup vaults, replication targets, archives, and any long-term retention stores, because they are still CUI locations you must control and be able to identify. ¹

How do we handle CUI in email and collaboration chats?

Treat mailboxes, shared mailboxes, and chat file uploads as explicit CUI locations. Reduce exposure by driving users toward approved repositories and restricting external sharing and unmanaged sync paths. ¹

What’s the minimum evidence an assessor will accept?

A current CUI Location Register, a CUI data flow map tied to real systems, and proof you validate and correct unauthorized locations. Pair that with change records and owner attestations to show the process runs. ¹

How should we document third-party CUI locations without over-collecting?

Record which third party touches CUI, what service they provide, and the specific systems/tenants/regions (where applicable) where CUI is stored or processed under that relationship. Keep it scoped to CUI, not a full enterprise data catalog. ¹

Footnotes

1. NIST SP 800-171 Rev. 3