CM-12(1): Automated Tools to Support Information Location

CM-12(1) requires you to use automated tools to identify defined information types (your “what”) on defined system components (your “where”) so you can confirm the right protective controls are in place for organizational information and individual privacy ¹. Operationalize it by scoping targets, selecting discovery tools, running recurring scans, and retaining results as assessment evidence.

Key takeaways:

• Define exactly what information the tools must identify and where they must search, then document those parameters.
• Run automated discovery on a repeatable schedule and tie findings to access controls, encryption, retention, and privacy handling.
• Keep evidence that scans occurred, findings were triaged, and remediation or risk acceptance was approved.

CM-12(1): automated tools to support information location requirement is a “make it findable” control enhancement. It pushes you past manual data mapping and into automated discovery so you can prove you know where sensitive information lives across endpoints, servers, databases, SaaS, and storage. The practical goal is simple: if you cannot reliably locate certain information, you cannot reliably protect it, restrict access to it, apply retention rules to it, or respond to incidents involving it.

For a Compliance Officer, CCO, or GRC lead, the fastest path to implementation is to treat CM-12(1) as a bounded engineering-and-governance outcome: define the categories of information to identify, define the system components to scan, run automated tooling with logging and auditability, and connect scan results to concrete control actions (ticketing, permissions changes, encryption, deletion, or documented exceptions). Assessors usually care less about the brand of tool and more about whether the tool coverage matches your scoping decisions and whether you can show repeatable operation over time.

If you already run DLP, data classification, CSPM/SSPM, or eDiscovery, you may be closer than you think. The remaining work is often scope precision, evidence packaging, and remediation workflow discipline.

Regulatory text

Text (excerpt): “Use automated tools to identify {{ insert: param, cm-12.01_odp.01 }} on {{ insert: param, cm-12.01_odp.02 }} to ensure controls are in place to protect organizational information and individual privacy.” ¹

What the operator must do:

1. Fill in the blanks in a way that is testable:

• cm-12.01_odp.01 (the “what”): the specific information you must be able to identify (examples: CUI, PII, secrets/keys, regulated financial data, health data, export-controlled data, internal-only data classes).
• cm-12.01_odp.02 (the “where”): the specific system components you will scan (examples: endpoints, file shares, email, SaaS repositories, cloud object storage, databases, code repos, collaboration tools).

2. Use automation (not spreadsheets and interviews) to locate that information on those components.

3. Use the results to validate protection: confirm controls exist and are working for the discovered information (privacy and security), and remediate gaps.

Citations for this section are limited to the provided excerpt source ¹.

Plain-English interpretation (what CM-12(1) means in practice)

You need a repeatable, automated way to answer: “Where is our sensitive data right now?” across your defined environment. Then you must show that discovered data is protected according to your policies (access restrictions, encryption, retention, monitoring, and privacy handling). Manual data inventories may support planning, but they do not satisfy the “automated tools” expectation by themselves ¹.

Who it applies to (entity and operational context)

This requirement is commonly implemented by:

• Federal information systems implementing NIST SP 800-53 controls ².
• Contractor systems handling federal data, including environments that store or process government-provided or government-related sensitive information ².

Operationally, it applies wherever your organization processes information that demands tighter handling (security and privacy), especially in:

• Hybrid environments (on-prem + cloud)
• High-collaboration tool stacks (document sharing, messaging, ticketing attachments)
• Developer ecosystems (code repos, CI logs, artifact stores)
• Third-party hosted data stores where you still own data protection outcomes

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

Step 1: Define the “what” (information types) with precision

Produce a short list of information categories the tool must detect. Keep it auditable:

• Map each category to a policy basis (data classification standard, privacy policy, contract requirements).
• Define match logic at a high level: labels, metadata tags, regex patterns, fingerprinting, ML classifiers, exact data match, or keyword dictionaries.

Deliverable: “CM-12(1) Information Identification Scope” (one page).

Step 2: Define the “where” (system components) as an inventory-backed scope

Build a scoped list of repositories and components to scan:

• Endpoints (managed devices)
• File shares and NAS
• Email and collaboration suites
• Cloud storage (object/block/file)
• Databases and data warehouses
• Source code repos and CI/CD artifacts
• Backups (include or explicitly exclude with rationale)

Tie scope to your asset inventory/CMDB so additions trigger review.

Deliverable: “CM-12(1) System Components in Scope” list, with owners.

Step 3: Select automated discovery tooling that matches the scope

Pick tools based on coverage, not popularity. Common patterns:

• DLP/data discovery for content scanning and classification across endpoints and SaaS
• CASB/SSPM for SaaS discovery and policy enforcement signals
• CSPM for cloud storage misconfiguration plus sensitive-data signals where supported
• eDiscovery for enterprise content repositories
• Secrets scanning for code repos and build logs

Minimum operator checks:

• Can it scan the in-scope components?
• Can it detect the in-scope information types?
• Can you export logs/results and preserve them?
• Can it integrate with ticketing/IRM for remediation?

Tip: If no single tool covers everything, use a toolchain and document the boundary. CM-12(1) is satisfied by outcomes, as long as automation identifies the defined data on the defined components ¹.

Step 4: Implement scanning, credentials, and safety guardrails

Work with IT/SecOps to:

• Configure least-privilege scan accounts/service principals.
• Define scan frequency and triggers (new repository, new SaaS app, new cloud account).
• Protect scan outputs (results can themselves be sensitive).
• Validate performance impact for large repositories.

Operator control point: if scan credentials are “shared admin,” expect audit pushback.

Step 5: Define triage and remediation workflow (the part auditors test)

Create a standard workflow for findings:

1. Triage (false positive vs true positive; severity; business owner)
2. Assign remediation to a named team (ticket)
3. Fix (permission changes, encryption, move data to approved store, delete, apply labels/retention, rotate secrets)
4. Verify via re-scan or evidence of control change
5. Exception path with time-bound approval when you cannot remediate

This is where you prove you “ensure controls are in place” for privacy and security ¹.

Step 6: Operationalize as a recurring control with metrics you can defend

Track a small set of operational measures (avoid vanity metrics):

• Repositories/components scanned vs in-scope inventory
• High-risk findings open past SLA
• Exceptions approved and their expiry dates
• Coverage gaps (components not technically scannable)

Step 7: Package the control for assessment readiness

A working CM-12(1) program fails audits when evidence is scattered. Centralize:

• Control narrative (how tools identify what/where)
• Scope parameters (the “blanks”)
• Run logs and reports
• Tickets and remediation proof
• Exceptions and approvals

Where Daydream fits naturally: Daydream can act as the control system of record that maps CM-12(1) to an owner, a procedure, and recurring evidence artifacts, so you can show consistent operation without rebuilding an audit binder each cycle.

Required evidence and artifacts to retain

Use this as your evidence checklist:

• Control statement and procedure for CM-12(1), including defined “what” and “where” parameters ¹.
• Tool configuration exports (redact secrets): connectors enabled, scan policies, included/excluded repositories, scan account roles.
• Scan execution evidence: dated reports, job run logs, screenshots with timestamps, or immutable log exports.
• Findings register: sampled findings with classification, location, owner, and status.
• Remediation tickets: evidence of closure and verification (re-scan result or control change record).
• Exception approvals: rationale, compensating controls, expiry, approver identity.
• Change management records showing scan scope updates when new systems are added.

Common exam/audit questions and hangups

Assessors and internal audit tend to ask:

• “What information types are you identifying, and how did you decide?”
• “Show me the list of system components scanned. How do you know it’s complete?”
• “Demonstrate a scan run and trace one finding from detection to closure.”
• “What happens when a new SaaS app is adopted?”
• “How do you prevent discovery tooling from becoming a privacy risk itself?”
• “What are your exclusions, and who approved them?”

Hangups that slow audits:

• No documented parameters for the two placeholders in the requirement text.
• Tools exist, but evidence of recurring operation is missing.
• Findings have no owner, or remediation is informal (chat messages, no tickets).

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Treating CM-12(1) as a one-time data inventory.
   Avoid it: establish recurring scans and keep run evidence.

2. Mistake: Scanning only cloud storage while ignoring endpoints and collaboration tools.
   Avoid it: align scope to where data actually moves in your organization.

3. Mistake: No linkage from discovery to protective controls.
   Avoid it: require a remediation outcome category (restrict, encrypt, move, delete, exception) for every confirmed finding.

4. Mistake: Over-collecting scan results and exposing sensitive findings broadly.
   Avoid it: restrict access to results, log access, and redact where appropriate.

5. Mistake: Unclear ownership.
   Avoid it: name a control owner (GRC) and operational owners (SecOps/IT/Data owners) and document RACI in the procedure.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite enforcement actions.

Practically, CM-12(1) reduces risk that drives real incidents and audit findings:

• Sensitive data sprawl across unmanaged locations
• Inability to meet privacy commitments because you cannot locate personal data
• Overexposure from misconfigured storage or overshared collaboration links
• Secrets embedded in code or logs that later get exfiltrated

The control’s value is auditability: you can show that you systematically search for sensitive information across your defined environment and take action based on what you find ¹.

Practical execution plan (30/60/90-day)

Because time-boxed day counts are allowed here as planning guidance (not a factual claim), use this as an execution cadence.

First 30 days (stand up the control)

• Assign control owner and operational owners; document RACI.
• Define “what” (information types) and “where” (system components) parameters.
• Pick tools already in your stack that can meet scope; identify gaps.
• Pilot scans on a small set of repositories; validate permissions and performance.
• Define finding severity and a ticketing workflow.

By 60 days (expand coverage and prove repeatability)

• Expand scanning to the full prioritized scope (highest-risk stores first).
• Implement logging/export for scan runs and results retention.
• Start a findings register and run weekly triage with data owners.
• Close a set of findings end-to-end with verification evidence.
• Write and approve the CM-12(1) operating procedure.

By 90 days (assessment-ready operation)

• Integrate scope updates with asset inventory and change management.
• Formalize exclusions and exception management with expirations.
• Produce an evidence packet: scope, configs, sample scan runs, sample remediation tickets.
• Run a tabletop audit: pick one system component and trace detection to closure.
• Load CM-12(1) mapping, procedure, and evidence pointers into Daydream (or your GRC system) so the record stays current.

Frequently Asked Questions

What counts as an “automated tool” for CM-12(1)?

Any system that performs programmatic discovery of defined information types across defined system components and produces auditable results. DLP, data discovery, eDiscovery, CSPM/SSPM signals, and secrets scanners can qualify if they match your scope and produce evidence ¹.

Do we have to scan every system in the enterprise?

The requirement is scoped by your defined parameters for “what” and “where.” Auditors will expect your “where” list to be justified (asset inventory-backed) and your exclusions to be explicitly approved and tracked ¹.

How do we handle encrypted data stores where content scanning is limited?

Document the technical constraint, then use alternative automated signals where possible (metadata, labels, access patterns, classification at ingestion) and require an approved exception with compensating controls. Keep the exception time-bound and review it routinely.

How much evidence is enough for an assessment?

Keep proof of scope definition, tool configuration, multiple scan runs, and at least a few traced examples of findings through remediation or approved exception. Assessors want to see repeatability and governance, not a single report export.

Can we meet CM-12(1) with manual reviews plus occasional scripts?

Manual reviews support scoping, but CM-12(1) explicitly calls for automated tools to identify the defined information on defined components. If you rely on scripts, treat them like production tooling: version control, logs, run records, and documented procedures ¹.

Who should own CM-12(1): Security, Privacy, or GRC?

GRC typically owns the control definition and evidence, Security/IT owns tooling and operations, and Privacy validates that discovery and handling align to privacy obligations. Put the split in a RACI so triage and exceptions do not stall.

Footnotes

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

2. NIST SP 800-53 Rev. 5