Partial CUI Compliance
1 NIST 800-171 gaps detected. Not FedRAMP authorized. SOC 2 certified. Handles PII that may overlap with CUI. Document risk acceptance.
ADP Workforce Now
by ADP
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
HR & Payroll
Overview
ADP Workforce Now handles employee PII including SSNs, background check data, and financial information. While SOC 2 certified, it is not FedRAMP authorized. Contractors should assess whether HR data includes CUI and document risk acceptance accordingly.
CUI Risk Assessment
Not FedRAMP authorized. SOC 2 certified. Handles PII that may overlap with CUI. Document risk acceptance.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
ADP Workforce Now has no FedRAMP authorization on record. DFARS 252.204-7012(b)(2)(ii)(D) requires an external cloud service provider to meet security requirements equivalent to the FedRAMP Moderate baseline — an authorization is the straightforward way to show that, but it is not the only one. Without one, the burden is on you to establish, document, and defend equivalency, and to meet the clause's incident-reporting and media-preservation obligations. Most contractors find an authorized alternative cheaper than carrying that burden.
Migration Checklist
- 1ISSO must document formal risk acceptance for non-FedRAMP HR system in SSP Section 10 (Risk Assessment) with executive approval within 30 days.
- 2System administrator shall implement enhanced logging for all ADP Workforce Now CUI access events to meet NIST 800-171 3.3.1 audit requirements.
- 3Contracts officer must verify DFARS 252.204-7012 flow-down clauses exclude HR data processing or document specific CUI categories processed.
- 4ISSO shall update authorization boundary diagram to clearly delineate ADP Workforce Now as external service with CUI data flows documented.
- 5Security team must implement network segmentation to isolate ADP Workforce Now access from CUI systems per NIST 800-171 3.13.1.
- 6ISSO shall create POA&M entry documenting ADP Workforce Now non-compliance with target migration date within 12 months.
- 7HR administrator must classify all employee data to identify specific CUI categories (EMPINF, PRVCY, FININFO) processed in ADP Workforce Now.
- 8System administrator shall configure ADP Workforce Now data export capabilities for future migration to FedRAMP-authorized platform.
- 9Legal counsel must review ADP contract terms for CUI processing restrictions and data residency requirements per DFARS 252.204-7012.
- 10ISSO shall implement quarterly third-party risk assessments for ADP including SOC 2 report reviews and security posture monitoring.
NIST 800-171 Violations
Using ADP Workforce Now for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
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Frequently Asked Questions
Is ADP Workforce Now compliant for defense contractors?
ADP is SOC 2 certified but not FedRAMP authorized. If HR data does not include CUI, ADP is generally acceptable with documented risk acceptance. If HR records contain CUI (e.g., cleared personnel data), evaluate FedRAMP authorized alternatives.
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