CUI Data Flow in CRM Systems: A Technical Analysis

A user with access to any node in this chain may traverse to CUI in connected records. Access controls must consider these relationship paths.

Search and Indexing

CRM search indexes make CUI discoverable:

• Full-text search exposes CUI in email bodies and notes
• Global search results may surface CUI from multiple record types
• Search indexes themselves become CUI storage requiring protection

AI Processing Paths

Modern CRMs route data through AI systems:

• Email summarization (CUI in emails → AI → summary stored back to CRM)
• Deal scoring (CUI in opportunity fields → AI → predictions)
• Contact enrichment (CUI in contact records → external APIs → enriched data)
• RAG retrieval (CUI in documents → vector embeddings → retrieval results)

Each AI processing step creates new compliance exposure. See our compliant AI proposal guide for AI-specific controls.

CUI Persistence Locations

CUI persists in multiple storage tiers within a typical CRM deployment:

1. Primary database: Structured record data (contacts, opportunities, accounts)
2. Blob storage: File attachments, email archives, document uploads
3. Search indexes: Elasticsearch/Solr indexes containing full-text CUI
4. Vector databases: Embeddings derived from CUI content for AI features
5. Cache layers: Redis/Memcached holding frequently accessed CUI
6. Backup systems: Database snapshots, file backups, disaster recovery copies
7. Audit logs: Access logs may contain CUI in query parameters or response data

Control Points for CMMC Compliance

Based on this data flow analysis, compliance controls must be implemented at these points:

• Ingress classification: Classify content at entry (email sync, manual entry, integrations)
• Access control enforcement: RBAC at record, field, and relationship levels
• Search filtering: CUI-aware search that respects access controls
• AI isolation: Private inference and RAG for CUI-touching features
• Export controls: Audit and restrict data exports, downloads, and API access
• Storage encryption: Encrypt all persistence layers at rest

Next Steps

Map your organization's specific CUI data flows using this framework:

1. Inventory all CUI ingress vectors active in your CRM
2. Document record relationships that could propagate CUI
3. Identify all AI features that process CRM data
4. Catalog all persistence locations where CUI resides
5. Verify controls exist at each identified control point

For implementation guidance, review our CUI-Safe CRM guide and CMMC CRM compliance checklist.