Art,
I hope all is well. Great question !! The best place to start is with a definitive answer, which is a resounding "No", but...
Let me explain. There are no specific requirements that must be implemented in support of NIST SP 800-171 (R1), rather the document is a statement of Security Requirements that are then cross referenced against two distinct documents that offer relevant security controls, NIST SP 800-53 R4 and ISO/IEC 27001. As a result, the options available to implement the security controls are actually bounded by the two documents, which offer guidance and a selection of options, but no specific "must-do's".
For instance, in NIST SP 800-53R4 SC-28:
"PROTECTION OF INFORMATION AT REST
Control:
The information system protects the [Selection (one or more): confidentiality; integrity] of [Assignment: organization-defined information at rest].
Supplemental Guidance: This control addresses the confidentiality and integrity of information at rest and covers user information and system information. Information at rest refers to the state of information when it is located on storage devices as specific components of information systems. System-related information requiring protection includes, for example, configurations or rule sets for firewalls, gateways, intrusion detection/prevention systems, filtering routers, and authenticator content. Organizations may employ different mechanisms to achieve confidentiality and integrity protections, including the use of cryptographic mechanisms and file share scanning. Integrity protection can be achieved, for example, by implementing Write-Once-Read-Many (WORM) technologies. Organizations may also employ other security controls including, for example, secure off-line storage in lieu of online storage when adequate protection of information at rest cannot otherwise be achieved and/or continuous monitoring to identify malicious code at rest. Related controls: AC-3, AC-6, CA-7, CM-3, CM-5, CM-6, PE-3, SC-8, SC-13, SI-3, SI-7.
Control Enhancements:
(1) PROTECTION OF INFORMATION AT REST | CRYPTOGRAPHIC PROTECTION The information system implements cryptographic mechanisms to prevent unauthorized disclosure and modification of [Assignment: organization-defined information] on [Assignment: organization-defined information system components]
Supplemental Guidance: Selection of cryptographic mechanisms is based on the need to protect the confidentiality and integrity of organizational information. The strength of mechanism is commensurate with the security category and/or classification of the information. This control enhancement applies to significant concentrations of digital media in organizational areas designated for media storage and also to limited quantities of media generally associated with information system components in operational environments (e.g., portable storage devices, mobile devices). Organizations have the flexibility to either encrypt all information on storage devices (i.e., full disk encryption) or encrypt specific data structures (e.g., files, records, or fields). Organizations employing cryptographic mechanisms to protect information at rest also consider cryptographic key management solutions. Related controls: AC-19, SC-12.
(2) PROTECTION OF INFORMATION AT REST | OFF-LINE STORAGE The organization removes from online storage and stores off-line in a secure location [Assignment: organization-defined information].
Supplemental Guidance: Removing organizational information from online information system storage to off-line storage eliminates the possibility of individuals gaining unauthorized access to the information through a network. Therefore, organizations may choose to move information to off-line storage in lieu of protecting such information in online storage."
Based on the above, you see two things:
A cross referencing of additional controls that offer guidance, and in some cases options on what approaches may be implemented
Options presented in the supplemental guidance section(s) that offer possibilities, but not specific declarative "must-do" statements.
The goal of NIST SP 800-171 R1 is to "provide a set of recommended security requirements for protecting the confidentiality of CUI when such information is resident in nonfederal systems and organizations; when the nonfederal organization is not collecting or maintaining information on behalf of a federal agency or using or operating a system on behalf of an agency; and where there are no specific safeguarding requirements for protecting the confidentiality of CUI prescribed by the authorizing law, regulation, or government wide policy for the CUI category or subcategory listed in the CUI Registry. The security requirements apply to all components of nonfederal systems and organizations that process, store, or transmit CUI, or that provide security protection for such components. The requirements are intended for use by federal agencies in contractual vehicles or other agreements established between those agencies and nonfederal organizations."
The key words: "provide a set of recommended security requirements" It's all about the options in other words, and they will vary, and be contextual, and may or may not be implemented the same way across organizations.
Hope that helps.
Cheers,
Adam
