What Should Contractors Know About Handling Sensitive Contracting Information at GSA?
GSA requires CUI handling under its policy, mandatory training for people with GSA CUI access, and FAR basic safeguards for contractor systems.
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What controls and training does GSA require for sensitive contracting information?
According to GSA’s CUI policy, the rules apply to all persons or entities that handle GSA CUI under agreements that include CUI provisions, including contracts. GSA’s CUI guide says the program covers handling, marking, protecting, sharing, destroying, and decontrolling CUI, and it requires anyone working for or with GSA to be aware of required CUI protections and complete mandatory training in GSA Online University. The guide also says the CUI Registry is the authoritative source for categories and markings, and only categories listed there may be marked and handled as CUI. For contractor systems that process, store, or transmit Federal contract information, FAR 52.204-21 requires basic safeguards such as limiting access to authorized users, verifying identities, controlling external connections, protecting communications, sanitizing media before disposal or reuse, and maintaining physical access controls and audit logs. The clause also requires the same substance to be flowed down to applicable subcontracts.
What is the key distinction between GSA CUI and Federal contract information?
Important Note
GSA’s guide says legacy markings such as SBU, FOUO, OUO, and similar terms may still appear during the transition to CUI. In those cases, use the protections required by the law, regulation, or government-wide policy that covers the information.
- GSA CUI rules apply to persons or entities handling GSA CUI under agreements that include CUI provisions.
- GSA says required CUI protections and mandatory training apply to anyone working for or with GSA.
- Only CUI Registry categories may be marked as CUI; the registry is the authoritative source for categories and markings.
- For Federal contract information on covered contractor systems, FAR 52.204-21 requires basic safeguards and subcontract flowdown.
Use the CUI Registry and contract clause language to classify the information before storing, sharing, or marking it.
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