The Crucial Role of Authorized Holders in CUI Marking and Dissemination

Controlled Unclassified Information (CUI) is a crucial element in the realm of information security, primarily in government and related industries. CUI encompasses unclassified information that is sensitive in nature and requires protection against unauthorized access, disclosure, or dissemination. To ensure the security of CUI, it is essential that proper markings and dissemination instructions are applied. But who is responsible for these critical tasks? In this article, we will explore the roles and responsibilities related to CUI markings and dissemination instructions as per official documents from the Defense Counterintelligence and Security Agency (DCSA) and the Federal Trade Commission (FTC).

Photo: freepik on

Responsibility According to DCSA

The Defense Counterintelligence and Security Agency (DCSA) provides detailed guidance on Controlled Unclassified Information in its ‘CUI Program: Standard Practice and Procedure (SPP) Template’ document, dated January 27, 2022. Let’s delve into the responsibilities outlined by DCSA concerning the application of CUI markings and dissemination instructions.

1. Authorized Holder of CUI

The DCSA document emphasizes that the authorized holder of Controlled Unclassified Information plays a pivotal role in the application of CUI markings and dissemination instructions. An “authorized holder” is defined as an individual or organization that has been granted access to CUI and has the responsibility to protect it appropriately.

2. Marking of CUI

The primary responsibility for marking CUI lies with the authorized holder. When an individual or entity creates or receives CUI, they must ensure that it is properly marked. The markings serve to clearly indicate the sensitivity of the information and provide guidance on its handling and dissemination.

Markings typically include designations such as “Controlled Unclassified Information,” the category of the information (e.g., “CUI-FOUO” for For Official Use Only), and any specific handling or dissemination instructions. These markings are a crucial aspect of safeguarding CUI, as they communicate the necessary security measures to anyone who encounters the information.

3. Dissemination Instructions

The DCSA document also outlines that the authorized holder of CUI is responsible for including appropriate dissemination instructions with the marked information. Dissemination instructions specify who can access the information, under what conditions, and any specific restrictions or limitations on its use or sharing. These instructions are vital to controlling the flow of CUI and ensuring it reaches only those with authorized access.

4. Compliance with CUI Policies and Procedures

In addition to marking and disseminating CUI, the authorized holder must also comply with CUI policies and procedures established by the organization. This includes adhering to specific security measures, reporting any security incidents or breaches, and ensuring that all employees or individuals with access to CUI are aware of and follow the organization’s CUI guidelines.

5. Training and Education

The DCSA document underscores the importance of training and educating authorized holders of CUI. Those responsible for CUI should receive proper training on identifying, marking, and disseminating CUI in accordance with organizational policies. Adequate training is essential for maintaining the integrity and security of CUI throughout its lifecycle.

Responsibility According to FTC

The Federal Trade Commission (FTC) also defines its own set of responsibilities for handling Controlled Unclassified Information, as outlined in its ‘Controlled Unclassified Information Policy and Notices’ document. The FTC’s approach to CUI responsibilities aligns with the principles outlined by DCSA, emphasizing the importance of secure handling and dissemination of sensitive information.

1. Commission Staff Responsibility

The FTC’s policy document clearly states that Commission staff are responsible for handling CUI appropriately. This responsibility extends to all individuals working within the FTC who may come into contact with CUI during the course of their duties.

2. Implementation of Policies, Procedures, and Guidance

FTC staff is responsible for implementing and adhering to the FTC’s CUI policies, procedures, and guidance. These documents provide the framework for handling CUI within the organization, including the marking and dissemination of sensitive information.

3. CUI Identification and Marking

FTC staff must be diligent in identifying CUI when it is encountered and appropriately marking it to signify its controlled nature. Proper markings ensure that all staff members are aware of the sensitivity of the information and the need for heightened security measures.

4. Dissemination Controls

As with DCSA’s guidelines, the FTC emphasizes the importance of controlling the dissemination of CUI. Staff members are responsible for following the instructions provided with the marked information, ensuring that it is shared only with authorized personnel and in accordance with the established guidelines.

5. Reporting and Incident Handling

In the event of a security incident or breach involving CUI, FTC staff members are responsible for promptly reporting the incident to the appropriate authorities. This ensures that corrective actions can be taken to mitigate any potential harm and prevent future breaches.

6. Training and Awareness

Similar to DCSA’s recommendations, the FTC underscores the importance of training and awareness among its staff. Employees must receive the necessary training and education to understand the handling and protection of CUI in line with the organization’s policies and procedures.

The Common Thread

While the specific documents from the DCSA and the FTC provide guidance tailored to their respective organizations, there are several common threads in the responsibilities related to the application of CUI markings and dissemination instructions:

  • Authorized Holder Responsibility: In both cases, the authorized holder of CUI is central to the process. They are tasked with recognizing CUI, applying appropriate markings, and ensuring that dissemination instructions are followed.
  • Marking Standards: Both DCSA and FTC stress the importance of standardized markings. These markings not only indicate the sensitivity of the information but also provide guidance on its handling and dissemination.
  • Dissemination Control: Controlling the flow of CUI is crucial. Authorized holders are responsible for ensuring that CUI is shared only with those who have the necessary clearance and under the appropriate conditions.
  • Training and Education: Proper training and education are key to maintaining the security of CUI. Individuals with access to CUI must be aware of the organization’s policies and procedures to handle it effectively.


Controlled Unclassified Information (CUI) is a critical asset that requires safeguarding to protect against unauthorized access or disclosure. Responsibility for applying CUI markings and dissemination instructions falls on the authorized holder of the information. This individual or entity is tasked with recognizing CUI, marking it appropriately, and controlling its dissemination in line with established policies and procedures.

The guidelines provided by the Defense Counterintelligence and Security Agency (DCSA) and the Federal Trade Commission (FTC) serve as valuable references for organizations in their efforts to secure CUI. These documents stress the importance of standardized markings, dissemination controls, and employee training and awareness.

It is imperative for organizations to take these responsibilities seriously and ensure that their staff members are well-versed in the proper handling of CUI. By doing so, they can protect sensitive information and maintain the integrity of their operations in an increasingly interconnected and data-driven world.

Leave a Reply