Understanding Who is Responsible for Applying CUI Markings

Managing Controlled Unclassified Information (CUI) is an important part of protecting sensitive data in any organization, especially in manufacturing companies that often handle proprietary processes, designs, or customer information. One common question we hear from small and mid-sized manufacturing businesses is: Who is responsible for applying CUI markings?

Let’s clarify this step by step.

What is CUI?

Controlled Unclassified Information (CUI) is a designation used by the U.S. government to identify information that requires safeguarding and dissemination controls but is not classified under national security classification systems. Examples include technical data, manufacturing processes, or customer data that, if disclosed improperly, could cause harm or give unfair advantage.

Roles and Responsibilities for Applying CUI Markings

Broadly, the responsibility for applying CUI markings falls into several roles within an organization, depending on the size and structure of the company. Here’s a breakdown of who typically handles this task:

1. Responsibility of the Organization’s Leadership

At the top level, company leadership is responsible for establishing policies and ensuring that their employees understand their roles concerning CUI. This includes:

• Implementing and communicating procedures for marking CUI

• Providing training and resources

• Designating personnel responsible for document marking

> **Tip:** Clear policies prevent confusion and help ensure that everyone knows their part in safeguarding CUI.

2. Designated Employees or Responsible Personnel

While leadership sets the policies, the *actual application of CUI markings* is usually done by specific individuals trained for this task. These could be:

• Document controllers or administrative staff

• Engineering or technical staff handling sensitive data

• Contract managers or compliance officers

> **Important:** This person or team needs to be trained on what markings to use and how to apply them correctly.

3. Document Creators and Handlers

Often, the individuals who generate or handle CUI data (like engineers, project managers, or technical staff) are responsible for initially applying markings when creating or sharing documents. This is essential to prevent accidental mishandling.

What Does Correct Application of CUI Markings Entail?

Proper markings must be visibly placed on all CUI documents and data. According to the National Archives and Records Administration (NARA), markings should include:

• The CUI designation (e.g., “CUI”) in a clear, visible location

• The specific handling instructions if applicable

• Any other required control markings as defined by agency-specific or organizational policies

**Examples of markings include:**

- On the header or footer of a document: CUI - On email subject lines: [CUI]

- On physical containers or envelopes: “Controlled Unclassified Information”

> **Pro Tip:** Consistent and correct markings help prevent unintentional disclosure and streamline compliance.

Who Should Ensure Markings Are Correct?

While the individual creating or handling the document applies the markings, ultimately, organizations should have processes in place for verification. This might be a supervisor, quality control person, or records manager who reviews sensitive materials before they’re distributed or stored.

Summary: Clear Responsibilities Lead to Better CUI Protection

- **Leadership** sets policies and provides training.

- **Designated personnel** are trained and responsible for applying markings.

- **Document creators/handlers** mark documents at the source.

- **Reviewers** verify markings are correct before dissemination.

By clearly defining these roles, manufacturing companies can ensure that CUI is properly marked and protected, reducing risk and maintaining compliance with federal standards.

In Closing

The responsibility for applying CUI markings is shared but clearly assigned within an organization. Your company’s leadership must establish a clear process, and designated employees must be trained to apply markings accurately and consistently. Proper marking not only helps in compliance but also protects your sensitive information from accidental exposure.

For more detailed guidance, consult the National Archives and Records Administration resources on CUI.

If you’re unsure about how to train your team or implement a marking process, consider reaching out to experts in information security and compliance. Taking these steps now can save a lot of headaches down the line.