Not CUI Compliant
4 NIST 800-171 gaps detected. Not FedRAMP authorized. Popular HRIS for SMBs. Handles employee PII including SSNs, background checks. No government compliance certifications.
BambooHR
by BambooHR
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
HR & Payroll
Overview
BambooHR is a popular human resources information system for small-mid businesses. It handles sensitive employee PII including SSNs, background check data, and compensation information. It holds no FedRAMP authorization or government compliance certifications.
CUI Risk Assessment
Not FedRAMP authorized. Popular HRIS for SMBs. Handles employee PII including SSNs, background checks. No government compliance certifications.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
BambooHR 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 immediately assess all CUI data types currently stored in BambooHR and document findings in a formal risk assessment report referencing DFARS 252.204-7012 requirements.
- 2Contracts officer should review all active DoD contracts to identify CUI handling requirements and notification obligations to contracting officers regarding current non-compliance status.
- 3ISSO must create POA&M entries documenting BambooHR compliance gaps with planned remediation timelines not exceeding 180 days per NIST 800-171 requirements.
- 4System administrator should implement immediate data export procedures using FIPS 140-2 validated encryption for all employee records containing CUI categories.
- 5Legal counsel must review vendor contracts and data processing agreements to identify data residency, breach notification, and termination clause implications.
- 6ISSO should update the System Security Plan (SSP) to reflect BambooHR as a non-compliant system requiring replacement within the authorization boundary.
- 7Procurement officer must initiate vendor selection process for FedRAMP authorized or on-premises HRIS solutions meeting CMMC Level 2 requirements.
- 8System administrator should configure secure data migration pipelines ensuring CUI protection during transfer to compliant replacement system.
- 9ISSO must coordinate with authorizing official to document residual risks and obtain formal risk acceptance for continued BambooHR use during migration period.
- 10Training coordinator should develop CUI awareness programs for HR staff covering new system procedures and NIST 800-171 compliance requirements.
NIST 800-171 Violations
Using BambooHR for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
Need a CUI-Compliant Alternative?
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Related Compliance Assessments
Frequently Asked Questions
Is BambooHR suitable for defense contractors?
BambooHR handles employee PII but has no FedRAMP authorization. Assess whether your HR data includes CUI-category information (e.g., cleared personnel records) and consider alternatives with stronger compliance posture.
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Schedule architecture reviewRelated: how much CMMC certification costs — DoD’s own priced figures