For data security experts, properly classifying sensitive information is crucial. But making sense of categories like CUI and ITAR can be confusing. Let’s break things down using a trusty whiskey analogy!
First, rye and bourbon whiskey. While both are made from grain mash and aged in barrels, they have distinct requirements. Bourbon laws mandate at least 51% corn in the recipe, among other rules. Rye, unsurprisingly, necessitates a mash bill with a minimum 51% rye grain.
So while these American whiskey styles share many attributes, there is zero overlap in their technical definitions. No spirit can simultaneously be called both rye and bourbon.
Similarly, ITAR and CUI data are specialized sub-types living under the wider umbrella of sensitive information. Both classify types of data requiring extra protections and access procedures compared to publicly shareable information.
However, unlike whiskey, CUI and ITAR specifications can actually overlap in certain situations. For example, defense-related technical data controlled under ITAR regulations may also meet the criteria for handling controls laid out for CUI information. In these cases, the data is dual-status - simultaneously categorized as both CUI and ITAR protected. Misunderstanding this subtlety can cause you do extra work when it may not be necessary. Alternatively, it could cause you to ignore work that is necessary, thereby increasing your risk for non-compliance.
In summary:
Rye ≠ Bourbon
ITAR ∩ CUI ≠ ∅
So while rye and bourbon whiskeys can never crossover, ITAR and CUI data classifications sometimes intersect. Understanding where they converge (and where they remain distinctly separate) is critical for information security teams seeking to properly protect sensitive data in compliance with established regulations.
The next time you find yourself sipping American whiskey or working to secure sensitive data, remember this: categories matter and things aren’t always black and white.
Here’s to celebrating nuance and fostering improved compliance with data security and privacy regulations!
Join Virtru and ATX Defense for a webinar on January 30th: CUI in Context: Clarifying CMMC and ITAR Confusion for Defense Contractors. During the conversation we will demystify some important topics, and also shed light on practical real-world choices for cloud collaboration platforms -- specifically, key differences between the expensive and complicated Microsoft Office365 GCC High, and it's practical and less expensive alternative, Google Workspace.