CM-8(8): Automated Location Tracking

CM-8(8): Automated Location Tracking requires you to support tracking system components by their geographic location using an automated mechanism you define and operate. To operationalize it quickly, decide which asset classes need location tracking, implement automated location data collection in your inventory workflow, and retain auditable evidence that locations are current and actionable. ¹

Key takeaways:

• Define the automated mechanism (tooling + data source) and the component scope you will track. ¹
• Make location an inventory attribute with automated updates, not a spreadsheet field people forget. ²
• Keep evidence that location data is produced, reviewed, and used for response and lifecycle decisions. ²

For most teams, CM-8(8) becomes urgent when you cannot answer basic questions during an incident, audit, or facility event: “Where is that server?”, “Which laptops are in a restricted country?”, “What components are in that closed office?”, “Which devices are offsite and unmanaged?” This enhancement to CM-8 (System Component Inventory) expects you to support geographic location tracking for system components using automation, not manual check-ins. ¹

“Geographic location” is broader than a street address. In practice, it can mean a data center and cage, a campus/building/floor, a branch office, a home office, or a country/region that drives export, privacy, and contractual obligations. The control is medium severity because location gaps turn into operational failures quickly: incomplete asset recovery, incomplete breach scoping, and misalignment with where data processing actually occurs.

This page translates the cm-8(8): automated location tracking requirement into an implementable procedure: scope, data model, tooling integration, operating cadence, and what evidence auditors actually ask for.

Regulatory text

Requirement excerpt: “Support the tracking of system components by geographic location using {{ insert: param, cm-08.08_odp }}.” ¹

Operator interpretation:

• You must be able to track system components by geographic location. “Support” is a design-and-operate expectation: the organization needs a working capability, not a policy statement. ²
• You must use an automated mechanism (the organization-defined parameter in the control text). That means location is derived or updated via tools and integrations (for example, endpoint management, network, cloud APIs, physical access/badge systems, or asset management tooling), not solely through manual updates. ¹

Plain-English requirement meaning

You need an inventory where each in-scope component has a reliable “where it is” attribute that updates automatically often enough to be useful, and you can produce that information during operations (incidents, audits, continuity events, investigations, asset recovery). ²

Who it applies to

Entity types: Federal information systems and contractor systems handling federal data commonly map to NIST SP 800-53 controls as part of their security program expectations. ²

Operational contexts where this matters most:

• Hybrid enterprises with on-prem, colocation, and cloud footprints where “location” spans facilities and regions.
• Distributed endpoint fleets (laptops, mobile devices, field equipment) where loss/theft and country-based restrictions are realistic scenarios.
• Regulated data processing where geographic boundaries affect legal commitments (data residency, government contracts, export controls, sanctioned regions).
• Third-party hosted environments where you still need component-level location awareness for systems you operate or are accountable for, including colocated hardware and managed services.

Typical in-scope components (decide explicitly):

• Endpoints (laptops, desktops, mobile devices)
• Servers (on-prem, colocated; cloud instances if your inventory treats them as components)
• Network gear (routers, switches, firewalls, SD-WAN appliances)
• Removable media and specialized devices if they are part of the system boundary
• Cloud-managed components, where “location” may be a region/availability zone rather than a street address

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

1) Set scope and define “geographic location”

Create a short scoping statement that answers:

• Which component classes require automated location tracking.
• What “location” means for each class (country only, city, site code, building/floor, data center room/rack; cloud region/zone).
• Allowed location sources (GPS, IP-to-geo, Wi-Fi SSIDs, EDR/MDM telemetry, cloud provider region metadata, asset tag scans, facilities systems).
  Keep this as a control procedure attachment, not buried in a policy. ²

2) Choose your automated mechanism and document it

CM-8(8) expects you to specify the automated mechanism (the organization-defined parameter). Document:

• Tool(s) of record (CMDB/asset inventory, endpoint management, cloud inventory, network management).
• How location gets populated (API, agent telemetry, scheduled jobs, event-driven updates).
• When automation is not possible, what exception path exists and who approves it. ¹

Practical pattern:

• Endpoints: MDM/EDR reports last-seen network and geo attributes into asset inventory.
• On-prem data center assets: Inventory integrates with CMDB plus facilities location fields (site/building/room/rack) tied to asset tags.
• Cloud: Use cloud provider APIs to record region/account/project and map to internal “geo” taxonomy.

3) Make location a required inventory attribute with validation rules

Update your inventory schema so that in-scope components cannot be “complete” without:

• Unique asset identifier
• Owner/custodian
• System/application association
• Location attribute per your definition
• Source-of-truth field (where the location came from)
• Timestamp of last location update

Add validation rules:

• “Unknown” location allowed only under a documented exception.
• Location format must match your taxonomy (site codes, approved country list, cloud region list). ²

4) Integrate location tracking into lifecycle workflows

Tie location capture to events you already control:

• Procurement/receiving: assign site code and expected location.
• Deployment: require enrollment in MDM/EDR before issuance.
• Moves/adds/changes: update facilities attributes for rack moves; update branch assignments for endpoints.
• Offboarding/disposal: verify last known location, then record disposition. ²

5) Define operational use cases and run them

Auditors respond well when location tracking is demonstrably used. Pick a few repeatable queries:

• “Show all assets in a specific site/country.”
• “Show assets with stale location telemetry.”
• “Show assets whose current location conflicts with assigned location.”
  Run them on a set cadence and route exceptions to an owner queue.

6) Monitor, alert, and investigate anomalies

Add basic detection logic:

• Location missing for an in-scope asset.
• Location changes to a disallowed geography for that asset class.
• Asset appears in a geography that triggers contractual or policy constraints.

Define who triages and what happens next (ticket, investigation, containment steps). ²

7) Map ownership and evidence to avoid “paper compliance”

Assign a control owner (often IT Asset Management, SecOps, or GRC) and name the operators for:

• Inventory platform administration
• Endpoint management/cloud inventory feeds
• Facilities coordination for physical assets
  If you use Daydream to manage your control library, keep CM-8(8) mapped to the owner, implementation procedure, and recurring evidence artifacts so evidence collection does not depend on individual memory. ¹

Required evidence and artifacts to retain

Keep evidence that shows both design (what you intended) and operating effectiveness (that it runs).

Design artifacts

• CM-8(8) control procedure with:
  • In-scope component classes
  • Definition of “geographic location”
  • Automated mechanism description and data flows
  • Exception handling and approvals ¹

Operating artifacts

• Inventory export showing location fields populated and last-updated timestamps for a sample of assets.
• Screenshots or reports from the automated mechanism (MDM/EDR, cloud inventory, CMDB integration status).
• Tickets/alerts for location exceptions and the resolution trail.
• Change records for taxonomy updates (new sites, renamed locations, cloud region additions).
• Periodic review attestation (manager sign-off that stale/unknown locations were addressed). ²

Common exam/audit questions and hangups

Expect assessors to test “automation” and “actionability”:

1. “What is your automated mechanism for location tracking?”
   They will look for actual tool output and integration evidence, not a policy statement. ¹

2. “Which components are in scope and why?”
   If scope is unclear, they may treat gaps as control failure. Show a defensible boundary statement tied to your system inventory approach. ²

3. “How current is your location data?”
   If you cannot show last update timestamps and a process for stale records, you will struggle to prove the capability is operational.

4. “How do you handle remote endpoints and travel?”
   Have a clear rule: what geo precision you collect, what you consider acceptable, and how you handle privacy considerations as part of governance.

5. “Show an example where location data drove action.”
   Bring an incident example (sanitized) or an operational ticket where a location exception was investigated.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Treating “location” as a free-text field	Free text breaks reporting and exceptions	Use controlled taxonomy (site codes, approved countries, cloud regions) and validation
Relying on manual updates	Manual processes drift and fail under stress	Make automation the default; manual only under approved exceptions 1
Tracking only “assigned location,” not “last known location”	You cannot respond to theft/travel/anomalies	Keep both assigned and observed location with timestamps
Ignoring cloud components	Cloud “geo” is still geographic	Record account/project + region/zone as the location model
No evidence trail	Control may exist but cannot be assessed	Predefine recurring evidence artifacts and collect them on a schedule 2

Enforcement context and risk implications

No public enforcement case sources were provided for CM-8(8) in the supplied catalog, so you should treat this as a program assurance requirement rather than an enforcement-driven headline risk. The operational risk is still real: inaccurate component location slows containment, complicates asset recovery, and increases uncertainty in incident scoping and continuity planning. ²

Practical 30/60/90-day execution plan

First 30 days (Immediate)

• Name a CM-8(8) owner and identify system inventories and data sources you already have (CMDB, MDM, EDR, cloud inventory). ²
• Define scope: component classes and what “geographic location” means for each.
• Pick the automated mechanism(s) you will stand up first (usually endpoints and cloud).
• Add location fields and timestamps to the inventory schema; define approved taxonomy.

Days 31–60 (Near-term)

• Implement integrations and validate data quality:
  • Confirm location field population for a representative asset sample.
  • Implement stale/unknown location exception reporting.
• Write the control procedure with screenshots/data flow and exception workflow.
• Run your first operational location review and open remediation tickets for gaps.

Days 61–90 (Operationalize)

• Expand to remaining asset classes (network gear, colocated servers, specialized devices).
• Add anomaly alerts (disallowed geography, unexpected moves).
• Package audit-ready evidence: latest exports, exception tickets, review records, and a short narrative of how location tracking supports incident response and lifecycle processes. ²

If you manage controls in Daydream, this is the point to formalize recurring evidence requests and owners so future audits do not turn into ad hoc data hunts. ¹

Frequently Asked Questions

What counts as “automated” for CM-8(8)?

Automated means the location attribute is populated or updated by a system mechanism (agents, APIs, integrations, scheduled jobs), not by periodic manual spreadsheet edits. Document the mechanism you chose and show its outputs. ¹

Do we need GPS-level precision for endpoints?

CM-8(8) does not prescribe precision in the provided excerpt; you define what “geographic location” means for your program. Pick a level of detail that supports your operational needs and can be collected consistently. ¹

How should we represent location for cloud components?

Use cloud region (and zone if relevant) as the geographic location and map it to your internal taxonomy. Keep evidence from cloud inventory APIs that show where resources run. ²

What if a device is offline and has no recent location?

Treat it as an exception condition: track “last known location” with timestamp, set an internal threshold for staleness, and route follow-up to the device owner or IT. Retain the exception ticket and resolution notes. ²

Does CM-8(8) apply to third-party hosted systems?

It applies to system components in your system boundary and accountability model. For third-party environments, you may satisfy it through provider reporting and your own inventory mappings, but you still need evidence that you can track component location at the level you defined. ²

What evidence is most convincing in an assessment?

A current inventory export with location fields and timestamps, plus proof of automated feeds and an exception workflow that shows location issues being identified and resolved. Pair this with a short, owned procedure document. ²

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5