CM-12: Information Location

CM-12 is a Configuration Management control, but in practice it functions like a “data map with teeth.” You are being asked to produce a precise, bounded answer to two questions: Where is the information? and What system components touch it? The control is intentionally specific: it is not satisfied by a generic data flow diagram, a cloud architecture slide, or an asset inventory that lists servers without tying them to information types.

For a CCO, compliance officer, or GRC lead, the fastest path is to operationalize CM-12 as an evidence-ready mapping between: (1) the information types you decide are in scope (the control’s organization-defined parameter), (2) the environments/locations where that information is processed and stored, and (3) the named system components that do the processing and storage. Your end state should support traceability during assessment: pick a data type (for example, “CUI” or “customer PII”), then prove exactly which databases, object stores, queues, endpoints, and compute services handle it, and where those services are hosted.

This page gives requirement-level implementation guidance you can execute quickly, plus the artifacts to retain so CM-12 holds up under audit.

CM-12: Information Location (what the requirement means)

CM-12 requires you to identify and document the location of organization-defined information and the specific system components on which the information is processed and stored. ¹

Plain-English interpretation

You need a maintainable record that answers, for each in-scope information type:

1. Location: Where the information resides (for example, data center/site, cloud region/account/tenant, SaaS instance, enclave, segment).
2. Component: Which concrete components handle it (for example, named application, database, storage bucket, VM/host group, Kubernetes namespace, managed service, message bus, endpoint cache).

Assessors look for specificity. “Stored in AWS” is not specific. “Stored in S3 bucket X in account Y, region Z; processed by Lambda function A and EKS cluster B; replicated to backup vault C” is specific.

Who it applies to (entity and operational context)

CM-12 is relevant anywhere NIST SP 800-53 is in scope, including:

• Federal information systems and system owners documenting system boundaries and data handling.
• Contractor systems handling federal data (common in regulated government contracting environments) that must prove where sensitive government-related information is stored and processed. ¹

Operationally, CM-12 becomes urgent when you have:

• Hybrid environments (on‑prem + cloud).
• Multiple cloud accounts/subscriptions and regions.
• Third-party/SaaS processing in the system boundary (ticketing, CRM, logging, monitoring, CI/CD).
• Distributed data stores (object storage, queues, caches, analytics warehouses).
• M&A or rapid product growth where “where data lives” is no longer common knowledge.

Regulatory text

“Identify and document the location of [organization-defined information] and the specific system components on which the information is processed and stored.” ¹

What the operator must do:

• Decide and record what the “organization-defined information” is for your system boundary (for example, “CUI,” “PHI,” “payment card data,” “customer PII,” “incident logs,” “auth secrets”).
• Produce documentation that maps each in-scope information type to:
  • Where it is processed and stored; and
  • The specific components that do that processing/storage.
• Keep that documentation current as systems change.

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

Step 1: Lock the scope (the CM-12 ODP)

CM-12 hinges on what you define as “the information.” Write it down in a short scoping statement:

• Information type(s) in scope (by policy/data classification).
• System boundary/enclave(s) covered.
• Inclusions/exclusions (especially SaaS and third parties).

Deliverable: CM-12 scope statement owned by the system owner and approved by GRC.

Step 2: Build the “information → components → locations” mapping

Create a structured register (spreadsheet, CMDB table, GRC record, or architecture repository) with a minimum viable schema:

Field	Example
Information type	“CUI”; “Customer PII”; “Secrets”
System / application	“Case Management App”
Processing components	API service, worker service, ETL job
Storage components	RDS instance, S3 bucket, data warehouse dataset
Location attributes	DC site, cloud account/subscription, region, SaaS tenant
Data state	At rest / in transit / in use (optional but helpful)
Owner	App owner + infra owner
System boundary note	In-boundary / out-of-boundary with rationale
Last verified	Date + verifier

Focus on components that actually touch data: compute, storage, backups, replicas, logs, analytics pipelines, and support tooling where in-scope data lands (for example, export jobs to a BI warehouse).

Deliverable: CM-12 Information Location Register.

Step 3: Validate completeness with “data landing zone” discovery

Run targeted discovery aligned to your environment:

• Cloud: enumerate storage services (object stores, databases, file shares), analytics stores, backup services, logging sinks.
• On‑prem: file shares, databases, backup appliances, endpoint storage patterns.
• SaaS/third parties: confirm tenant, region/data residency settings, and which connectors ingest/export data.

You are not required to deploy a new tool for CM-12, but you must be able to defend that your mapping is complete for the defined scope.

Deliverable: Discovery notes and export snapshots that support the register entries.

Step 4: Tie the register to change management

CM-12 breaks when teams ship changes that create new data stores, new regions, or new integrations. Add CM-12 checks to:

• Architecture review / security design review: “Does this introduce a new data location or component that processes/stores in-scope information?”
• Change tickets: required field linking to an updated register entry.
• Cloud guardrails: region/account provisioning workflows that trigger mapping updates.

Deliverable: Updated change management SOP with CM-12 update trigger.

Step 5: Define cadence and ownership

Assign a control owner (usually security/GRC) and operational owners (platform + app owners). Define:

• How updates happen (PR to repo, service catalog update, GRC workflow).
• How you verify accuracy (spot checks, quarterly attestation, pre-audit review).
• How exceptions work (unknown location becomes a tracked issue with due date).

Deliverable: RACI + operating procedure.

Step 6: Make it assessment-ready (traceability test)

Perform a quick trace test:

• Pick one in-scope information type.
• Trace it to every component listed.
• For each component, show the supporting evidence (configuration screenshot/export, architecture diagram, IaC, CMDB record).
• Confirm the “location” fields are explicit enough for an assessor to validate.

Deliverable: CM-12 trace test worksheet (one per major information type).

Required evidence and artifacts to retain

Keep artifacts that show both design intent and current state:

1. CM-12 scope statement (ODP definition) and approval record.
2. Information Location Register (versioned; with owners and last verified).
3. Architecture diagrams / data flow diagrams that reference component names used in the register (component naming consistency matters).
4. System inventory/CMDB extracts showing component identifiers (instance IDs, cluster names, database IDs).
5. Cloud configuration exports demonstrating region/account and resource existence (for example, storage inventory exports).
6. SaaS/third-party documentation: data residency settings, tenant identifiers, integration lists, and contractual/service docs if available internally.
7. Change management artifacts: tickets/PRs showing register updates tied to releases.
8. Periodic review evidence: attestation emails, meeting notes, or signed review checklists.

Common exam/audit questions and hangups

Assessors commonly ask:

• “What information types are in scope for CM-12, and who approved that definition?” ¹
• “Show me where that information is stored, including backups and replicas.”
• “Which system components process the data, and how do you know?”
• “How do you keep this up to date as teams deploy changes?”
• “Does any in-scope information go to SaaS or other third parties, and where is it hosted?”

Hangups that stall audits:

• The register lists locations but not specific components (or vice versa).
• Component names in diagrams do not match real resource identifiers.
• Cloud regions are missing or inconsistent across accounts.
• Logs/telemetry pipelines quietly store sensitive data, but aren’t mapped.

Frequent implementation mistakes (and how to avoid them)

1. Treating CM-12 as “data residency only.”
   Fix: always pair location with the exact processing/storage components.

2. Over-scoping without a defensible ODP.
   Fix: define the information types explicitly, get sign-off, and expand later with a controlled change.

3. Ignoring derived data and secondary stores.
   Fix: include exports, analytics, search indexes, caches, and backups if they contain in-scope information.

4. One-time spreadsheet that goes stale.
   Fix: connect updates to change management and make owners attest to accuracy on a defined cadence.

5. No evidence behind the mapping.
   Fix: attach or link configuration exports/screenshots/IaC references per major component class.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for CM-12, so this guidance stays focused on assessment and operational risk.

Risk implications you can explain to leadership in plain terms:

• If you cannot prove where sensitive information is processed and stored, you cannot confidently apply access controls, encryption, retention, incident response scoping, or breach notifications.
• Unknown data locations expand incident impact and slow containment because responders cannot bound what systems are involved.
• Third-party and cloud sprawl create “silent” locations (logs, backups, analytics) that often become the real finding during assessment.

Practical 30/60/90-day execution plan

First 30 days (Immediate)

• Name the CM-12 control owner and system owner(s).
• Write the CM-12 scope statement (ODP) and get sign-off. ¹
• Stand up the Information Location Register with the minimum schema.
• Populate the register for the highest-risk apps and data stores first (start with systems handling your most sensitive in-scope information).

By 60 days (Near-term)

• Expand mapping coverage across remaining in-scope systems and shared services (identity, logging, SIEM, ticketing, CI/CD if in boundary).
• Collect and attach evidence exports for each major storage and processing category.
• Run at least one trace test per major information type and fix gaps found.
• Add a CM-12 update check to architecture review and change tickets.

By 90 days (Ongoing operationalization)

• Move the register into a controlled system (repo with pull requests, CMDB, or GRC tool) with version history and approvals.
• Implement periodic verification (owner attestations plus spot checks).
• Define and track exceptions (unknown locations, legacy apps, or third-party constraints) as time-bound remediation items.
• If you use Daydream for control operations, map CM-12 to a named owner, a written procedure, and recurring evidence tasks so the register stays current and audit-ready.

Frequently Asked Questions

What counts as “location” for CM-12 in a cloud environment?

Document the cloud account/subscription, region, and the service context (for example, specific database instance or storage bucket) where information is processed or stored. Generic statements like “in the cloud” are rarely assessable against CM-12. ¹

Do I need to include backups and replicas in the CM-12 mapping?

If backups/replicas store the in-scope information, include them because they are storage locations and often live in separate services or regions. If you exclude them, document the exclusion rationale and verify it is accurate.

How do we handle SaaS and other third parties for CM-12?

If the third party is within your system boundary or processes/stores the in-scope information for the system, record the SaaS tenant and any available hosting/region residency details. Also document the integration path so assessors can trace how data enters and leaves.

Our teams deploy daily. How do we keep CM-12 current without slowing delivery?

Put a lightweight trigger in your change process: any new datastore, new region/account, or new integration requires a register update as part of the change definition of done. Then verify with periodic spot checks rather than trying to review every release in detail.

What level of “specific system components” detail is enough?

Use identifiers that operations teams can point to in configuration: database instance names/IDs, bucket names, cluster/namespace names, service names, and key SaaS workspaces. The goal is that an assessor can pick a component and validate it exists and matches the documented location. ¹

Can CM-12 be satisfied by a data flow diagram alone?

Usually no. Diagrams help explain flows, but CM-12 expects you to identify and document the actual locations and specific components where processing and storage occur. Keep diagrams as supporting context and maintain a register for traceability. ¹

Footnotes

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