EvidenceSheet
NIST SP 800-53 Rev 5 · CM - Configuration Management

CM-12 Information Location

a. Identify and document the location of organization-defined information and the specific system components on which the information is processed and stored; b. Identify and document the users who have access to the system and system components where the information is processed and stored; and c. Document changes to the location (i.e., system or system components) where the information is processed and stored.

Source: NIST SP 800-53 Rev 5, CM-12. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open NIST SP 800-53 Rev 5 in the compliance library.

Base controls and their enhancements. Which apply follows the baseline you are assessed against (for example FedRAMP Moderate or High, or the low, moderate and high baselines of SP 800-53B). Text in square brackets is a parameter your organisation sets.

10
artefacts
1
held by a system
2
at each review
hard
to go live
Policy repository / GRC workspace
where the evidence lives
teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

  • List of users with system and system component access · Cloud console / configuration management

periodic reviewEvidence produced at each review

  • Audit records · Cloud console / configuration management
  • Test of Organizational processes governing information location; mechanisms enforcing policies and methods for governing information location · Cloud console / configuration management

governing documentDocuments that govern the control

  • Configuration management policy · Policy repository / GRC workspace
  • Procedures addressing identification and documentation of information location · Policy repository / GRC workspace
  • Configuration management plan · Policy repository / GRC workspace
  • System design documentation · Policy repository / GRC workspace
  • System architecture documentation · Policy repository / GRC workspace
  • PII inventory documentation · Policy repository / GRC workspace
  • Data mapping documentation · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Cloud console / configuration management on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.

Common gaps auditors find

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

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CM-11(3) User-installed Software | Automated Enforcement and Monitoring · CM-12(1) Information Location | Automated Tools to Support Information Location