CMMC compliance: Securing how users access CUI

Defense organizations often approach Cybersecurity Maturity Model Certification (CMMC) with a seemingly straightforward assumption: “If the data is encrypted, doesn’t that reduce our compliance scope?” 

It’s a reasonable question, and one that can surface after organizations have already invested significantly in encrypted storage, segmented networks, and policy documentation. The architecture may look sound on paper. Then auditors start asking how users actually access and interact with Controlled Unclassified Information (CUI). This is where encryption alone can leave important questions unanswered. 

Encryption is a foundational control, but encrypting CUI doesn’t necessarily remove the systems, users, endpoints, and workflows that interact with it from consideration. Protecting the data also requires controlling what happens when people access and use it. 

That makes the digital workspace an important part of the CMMC conversation. 

Encryption is essential, but it’s not a boundary 

Encryption is a foundational part of protecting CUI, but it doesn’t define the full security boundary. 

Even when CUI is encrypted: 

• It is still subject to CMMC and National Institute of Standards and Technology (NIST) Special Publication 800-171 requirements. 
• Access still needs to be limited to authorized users and environments. 
• The endpoints and workflows that interact with CUI can still affect your compliance scope. 

On paper, the data may sit securely in an approved repository. But once a user opens it on a personal device, copies content into another application, or shares it during a remote session, CUI is interacting with systems beyond that repository. Your security controls need to account for those interactions. 

The real risk is access, not storage 

Storage is only one part of the CUI security equation. What happens when users interact with that data introduces another set of risks. 

Many of those risks can emerge during routine work: an engineer trying to collaborate quickly, a contract joining a call, or a team member using an unmanaged device to meet a deadline. Each interaction can introduce another environment where CUI needs to be protected. 

The moment a user: 

• Opens a CUI file 
• Copies content locally 
• Share sensitive data on screen 
• Downloads files to an unmanaged device 

…the systems and environments interacting with that data may need to be considered as part of your CMMC scope. 

This can leave organizations with encrypted repositories but gaps elsewhere, including: 

• Uncontrolled endpoints 
• Inconsistent controls across user workflows 
• Limited visibility into how CUI is being used 

Encryption can protect CUI while it’s stored or transmitted. Organizations also need controls for how that data is accessed, handled, and shared during day-to-day work. 

Why traditional approaches struggle to scale 

Historically, compliance strategies have been built around infrastructure boundaries, including networks, enclaves, and segmented storage. These approaches often assume that users access sensitive data from defined locations and systems. 

Today, CUI workflows can extend across distributed engineering teams, third-party suppliers, short-term specialists, and hybrid environments. As those workflows become more distributed, infrastructure-based approaches can become harder to manage consistently. 

Over time, this often creates: 

• More friction for users trying to access the resources they need 
• Operational silos across teams and environments 
• Challenges scaling secure access to contractors and remote teams 

These approaches can also make it harder to manage data-in-use risk as CUI moves through more users, devices, applications, and workflows. 

Secure the workspace 

As CUI workflows extend beyond traditional infrastructure boundaries, the digital workspace can provide a more consistent point of control. Security policies and access controls can follow the user across devices and locations, helping organizations manage how CUI is accessed and used. 

A workspace-based approach can help organizations: 

• Deliver secure virtual desktops and applications for CUI access 
• Keep sensitive data from persisting on unmanaged endpoints 
• Apply session-level, policy-based controls 
• Enforce security policies consistently across locations and devices 

These capabilities can support the distributed teams and environments common across the Defense Industrial Base, including engineering teams, third-party contractors, and hybrid or remote workers. 

By controlling the workspace where users interact with CUI, organizations can create a more consistent security boundary across these different ways of working. 

Rethinking scope: From infrastructure to experience 

If encrypting CUI doesn’t automatically reduce compliance scope, the more useful question is: How can you limit the number of environments where CUI is accessed and used? 

A more centralized workspace can help by giving users a controlled environment for accessing CUI. With fewer endpoints and workflows directly interacting with sensitive data, organizations have fewer places where security controls need to be applied, monitored, and audited. 

This can make CMMC compliance more manageable while still giving users the access they need to get their work done. 

Compliance and usability don’t have to compete 

CMMC requirements can create friction when security controls make it harder for users to access the applications and data they need. A controlled digital workspace can help reduce that friction by building security into how users access CUI. 

With the right workspace architecture, you can: 

• Prevent data exfiltration 
• Reduce the risk of CUI being stored on local or unmanaged devices 
• Maintain strict access controls 
• Give authorized users secure access across locations and devices 

This approach gives users a consistent way to work with CUI while giving IT greater control over where sensitive data can go and what users can do with it. 

Make the workspace your security boundary 

CMMC compliance requires organizations to understand how CUI is accessed, used, and governed throughout the workday. As CUI moves across distributed teams and environments, protecting it requires visibility and control wherever those interactions happen. 

A secure digital workspace gives organizations a way to centralize those interactions, apply consistent controls, and limit how CUI moves across endpoints and environments. That can make compliance easier to manage while supporting the flexibility users need to carry out mission-critical work. 

For Defense Industrial Base organizations, the opportunity is to make the digital workspace a more consistent security boundary for CUI. Learn how Omnissa can help you secure access to CUI and simplify compliance across your digital workspace. 

Explore federal compliance with confidence.