MP-5(1): Protection Outside of Controlled Areas

MP-5(1): Protection Outside of Controlled Areas requires you to protect system media whenever it leaves controlled spaces (offices, data centers, secure rooms) through documented handling, secure transport, and verifiable safeguards against loss, theft, or unauthorized access. Operationalize it by defining “controlled area,” setting approved transport/storage methods, training handlers, and retaining chain-of-custody evidence.

Key takeaways:

• Define what “outside controlled areas” means for your environment, then apply mandatory protections to any media movement across that boundary.
• Control execution is mostly operational: approved containers, courier rules, encryption where applicable, and chain-of-custody logs.
• Auditors fail teams on MP-5(1) more often for missing evidence than for imperfect tooling; build a repeatable evidence trail.

The mp-5(1): protection outside of controlled areas requirement sits in the NIST SP 800-53 Media Protection (MP) family and focuses on a simple risk: media is easiest to lose, steal, mishandle, or expose when it travels. “Media” includes physical and digital storage used to hold system information, such as backup tapes, external drives, removable USB media, laptops used as storage, printed output, and shipment packaging that may reveal sensitive details.

For a Compliance Officer, CCO, or GRC lead, the fastest path to readiness is to treat MP-5(1) as a boundary-and-handling control. First, you define which spaces count as “controlled areas.” Then, you define what protections must apply once media crosses the boundary: authorized handlers only, secure packaging, tracked transport, and documented receipt. Finally, you make the control assessable by producing consistent artifacts: procedures, training acknowledgements, inventories, movement logs, and exception records.

This page gives requirement-level implementation guidance you can assign to an owner and operationalize without turning it into a multi-quarter program.

Regulatory text

Excerpt (framework requirement): “NIST SP 800-53 control MP-5.1.” ¹

What the operator must do: Treat any movement, storage, or handling of system media outside your defined controlled areas as a high-risk activity. You must implement safeguards (procedural and technical) so media is protected from unauthorized access, loss, theft, and tampering while in transit or in uncontrolled locations. This is assessed as an operational control: an assessor will expect to see documented rules plus proof they are followed ².

Plain-English interpretation

If media leaves spaces you physically control, you need a secure way to:

1. approve the movement,
2. package it so it cannot be casually accessed or swapped,
3. transport it through trusted means,
4. confirm arrival and condition, and
5. document the whole sequence.

The control is less about having a fancy courier contract and more about preventing “unobserved exposure.” The moment a drive, tape, printed report, or shipment is unattended, the organization owns the risk unless safeguards and documentation show otherwise.

Who it applies to (entity and operational context)

Entity scope

• Federal information systems and programs implementing NIST SP 800-53 ².
• Contractor systems handling federal data where NIST SP 800-53 is flowed down contractually ².

Operational scenarios where MP-5(1) shows up

• Backup media sent to offsite storage.
• Replacement drives shipped to/from a data center.
• Removable media used for diagnostics, patch staging, or data transfer in restricted networks.
• Printed materials transported for meetings, hearings, or disaster recovery operations.
• Decommissioned media temporarily stored before destruction.

Teams involved

• IT operations (backup/restore, data center)
• Security operations / ISSO
• Facilities / physical security
• Procurement / third-party management (couriers, offsite storage providers)
• Legal/compliance (policy, exceptions)
• Business owners who request media movement (data owners)

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

Step 1: Define “controlled areas” and document the boundary

Create a short, enforceable definition that maps to your physical reality. Include examples:

• Controlled: data center floor with badge access, monitored secure rooms, locked records room with access list.
• Not controlled: employee homes, hotels, vehicles, shared conference venues, shipping docks, common carrier networks.

Artifact: “Controlled Areas Definition” section in your Media Handling Standard, approved by Security and Facilities.

Step 2: Build a media classification + handling matrix

Make a matrix that ties media type and data sensitivity to required protections outside controlled areas. Example categories:

• Media type: backup tape, external drive, USB, laptop-as-media, printed output.
• Sensitivity: public, internal, sensitive, regulated, classified (use your org’s scheme).

Define required protections (pick what fits, then standardize):

• Encryption requirements (for electronic media where feasible).
• Tamper-evident packaging.
• Locked containers for transport.
• Approved carrier list (internal courier vs. bonded courier vs. specialized service).
• “No unattended storage” rules (e.g., never in a vehicle overnight; if unavoidable, require locked trunk + documented exception).
• Two-person integrity for the highest-risk media (if your risk model supports it).

Artifact: Media Handling Matrix (one page) referenced by procedure.

Step 3: Establish an authorization and chain-of-custody process

Operationalize a minimal workflow that is easy to follow:

1. Request: who, what media, where to/from, purpose, classification.
2. Approval: control owner or delegate approves method and carrier.
3. Prepare: label, encrypt (if required), package, seal.
4. Dispatch: log date/time, handler identity, seal number, carrier tracking ID.
5. Receipt: receiving party verifies seal integrity, logs date/time, stores in controlled area immediately.
6. Exception handling: lost/damaged/late delivery triggers incident process and data owner notification.

A chain-of-custody log can be a ticket workflow, a secure spreadsheet with access controls, or a GRC workflow. What matters is consistent capture and retention.

Artifacts: Chain-of-custody log, approval records, incident/escalation records.

Step 4: Control third parties that touch your media

If an offsite storage provider or courier handles media, treat them as a third party with contract requirements:

• Transport security requirements (sealed containers, background checks where appropriate, tracking).
• Breach notification obligations if media is lost or tampered with.
• Subcontractor restrictions.
• Right to audit or provide SOC reports where relevant.

Artifacts: Contract clauses, third-party due diligence package, service procedures provided by the third party.

Step 5: Train the people who actually move media

MP-5(1) fails in practice when the “last mile” handler does what’s convenient. Training must cover:

• What counts as media.
• Where controlled boundaries are.
• How to package/seal and what “tamper evidence” looks like.
• How to complete the log and what to do when something goes wrong.

Artifacts: Training content, attendance/acknowledgements, role-based assignment list.

Step 6: Monitor and test the process

Add lightweight controls:

• Periodic spot checks of chain-of-custody completeness.
• Reconciliation between backup inventory and offsite storage receipts.
• Review of exceptions and corrective actions.

If you want this to stay audit-ready, set it up as a recurring evidence task with named owners. Many teams use Daydream to map MP-5(1) to the control owner, the written procedure, and a recurring evidence checklist so audits don’t become a scavenger hunt.

Artifacts: Spot-check records, reconciliation results, corrective action tickets.

Required evidence and artifacts to retain

Use this as your audit-ready checklist:

Governance

• Media Protection / Media Handling Policy and Standard referencing MP-5(1) ².
• Controlled areas definition and ownership (Security + Facilities signoff).

Procedures

• Media transport procedure (packaging, sealing, carrier selection, receipt verification).
• Exception procedure (temporary storage, emergency shipment, lost media escalation).
• Third-party handling requirements (contract language or security addendum).

Operational records

• Media inventory (at least for sensitive/regulated media).
• Chain-of-custody logs with approvals, tracking IDs, seal numbers, send/receive attestations.
• Incident tickets for lost/damaged media and post-incident actions.

People

• Training materials and completion evidence for handlers.
• Access lists for storage rooms and authorized shippers/receivers.

Common exam/audit questions and hangups

Expect assessors to ask:

• “Define ‘controlled area’ for your organization. Show where it is documented.”
• “Show evidence of a media shipment and the full chain-of-custody from request to receipt.”
• “How do you prevent someone from reading or swapping media during transit?”
• “What happens if the seal is broken or the package is delayed?”
• “Which third parties handle media, and what are their security obligations?”

Where teams get stuck:

• They have a policy but no movement logs.
• Logs exist but don’t show approvals or receipt verification.
• “Controlled area” is implied but never defined.
• Third-party courier/offsite storage is out of scope in third-party risk management, so contract controls are missing.

Frequent implementation mistakes and how to avoid them

1. Mistake: Treating MP-5(1) as “only about backup tapes.”
   Fix: Expand scope to all removable and transported media, including printed output and devices used as storage.

2. Mistake: No clear boundary for controlled areas.
   Fix: Publish a controlled-area list (by site/room), tie it to Facilities access control records.

3. Mistake: Chain-of-custody exists, but it’s optional.
   Fix: Make shipment approval contingent on a logged request. Enforce via ticketing workflow.

4. Mistake: Relying on “trusted employees” without packaging rules.
   Fix: Standardize tamper-evident seals and require seal verification at receipt.

5. Mistake: Third-party handling is not contractually enforceable.
   Fix: Add handling, notification, and tracking requirements to MSAs/SOWs for couriers and storage providers.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat MP-5(1) primarily as an assessment and breach-risk control rather than a control with a predictable enforcement pattern. The practical risk is straightforward: loss or compromise of media during transit can trigger incident response obligations, contractual noncompliance, and findings in audits against NIST SP 800-53 expectations ².

Practical 30/60/90-day execution plan

First 30 days (get to a defensible minimum)

• Assign a control owner (Security or IT Ops) and a backup owner.
• Define controlled areas and publish the boundary definition.
• Draft the media handling matrix and the transport procedure.
• Stand up a chain-of-custody log (ticket workflow preferred).

Days 31–60 (make it real in operations)

• Train handlers and receiving personnel.
• Implement standardized packaging and seal process; stock the materials.
• Identify third parties that handle media; add contract addenda for new work and build a remediation plan for existing contracts.
• Run a tabletop test for “lost media during transit” and confirm escalation paths.

Days 61–90 (make it assessable and sustainable)

• Perform spot checks and reconcile inventory to movement logs.
• Review exceptions and fix root causes (missing receipt steps, incomplete logs, unclear approvals).
• Package evidence for assessment: 2–3 sample shipments with end-to-end documentation.
• In Daydream, map MP-5(1) to the control owner, the procedure, and recurring evidence artifacts so collection stays continuous.

Frequently Asked Questions

What counts as “media” for MP-5(1)?

Treat any physical or portable item that can store or display system information as media: removable drives, backup tapes, laptops used to stage data, and printed output. If it can leave the building with data on it, assume it’s in scope.

Do we have to encrypt all media that leaves controlled areas?

NIST SP 800-53 expects protection appropriate to risk ². Many teams require encryption for electronic media as the default, then document exceptions for cases where encryption is not feasible.

How detailed does a chain-of-custody log need to be?

It must show who released the media, who approved the movement, how it was protected (e.g., seal ID), and who received it with date/time. If you cannot prove receipt and integrity, auditors usually treat that as a control failure.

Are cloud backups covered by MP-5(1)?

MP-5(1) is about media protection outside controlled areas; cloud backups shift the handling to a third party. If a third party manages the underlying media, focus on contract requirements, third-party due diligence, and assurance evidence that they protect media in their operations.

We occasionally hand-carry drives between sites. Is that acceptable?

It can be, but only with documented approvals, required packaging/sealing, and receipt verification. Hand-carry without logs is a common gap because it bypasses normal controls.

What evidence should we show an assessor for MP-5(1)?

Provide the written procedure, controlled-area definition, and a few completed chain-of-custody records that show approval, dispatch details, and receipt verification. Add training completion for handlers and any incident records if a shipment had issues.

Footnotes

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

2. NIST SP 800-53 Rev. 5