Partial CUI Compliance
1 NIST 800-171 gaps detected. Not FedRAMP authorized for cloud components. Strong endpoint DLP with deep visibility. Popular with defense contractors but requires documented risk acceptance.
Digital Guardian
by Fortra
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
Data Loss Prevention
Overview
Digital Guardian (now Fortra) provides endpoint-focused data loss prevention with deep visibility into data movement. Popular with defense contractors for its strong endpoint DLP capabilities. Cloud components are not FedRAMP authorized — the on-premises deployment option may be preferable for CUI environments.
CUI Risk Assessment
Not FedRAMP authorized for cloud components. Strong endpoint DLP with deep visibility. Popular with defense contractors but requires documented risk acceptance.
Using Digital Guardian in a Defense Contractor Environment
Digital Guardian's endpoint DLP capabilities make it attractive for defense contractors handling CUI categories including technical drawings (CTI), export-controlled technical data (ITAR/EAR), financial information, and personnel records. In CMMC Level 2 environments, Digital Guardian typically sits at network perimeters and endpoints within the authorization boundary, monitoring data exfiltration from CAD workstations, email systems, and file shares containing CUI. However, the cloud-based management console and analytics components operate outside FedRAMP boundaries, creating a significant compliance gap. Compensating controls must include documented risk acceptance for cloud components, enhanced logging of all DLP policy violations, and alternative monitoring for cloud-transmitted metadata. DCMA assessors specifically scrutinize Digital Guardian deployments during CMMC assessments, focusing on data flow diagrams showing CUI movement through non-FedRAMP components. Recent DIBCAC reviews have flagged organizations using Digital Guardian's cloud features without documented risk acceptance or alternative boundary protections. The tool's strength in detecting insider threats and data exfiltration attempts must be weighed against the compliance risks introduced by its non-authorized cloud infrastructure, particularly for contractors handling ITAR-controlled technical data or classified derivative information.
Deployment & Architecture
Deployment Model: Hybrid (cloud + on-prem)
Digital Guardian lacks FedRAMP authorization. Using this tool for CUI processing violates DFARS 252.204-7012 requirements. Defense contractors must evaluate FedRAMP-authorized alternatives or implement and document compensating controls in their POA&M.
Migration Guidance
Defense contractors must immediately isolate Digital Guardian's on-premises components from cloud services to maintain CUI compliance. Migration timeline spans 12-16 weeks across four phases: assessment (2 weeks), alternative selection (4 weeks), implementation (6-8 weeks), and validation (2 weeks). During assessment, catalog all DLP policies, incident histories, and CUI data flows monitored by Digital Guardian. Export policy configurations, violation logs, and user behavior analytics data while ensuring CUI remains within authorized boundaries during transfer. Alternative solutions include Microsoft Purview DLP (FedRAMP authorized), Symantec DLP (on-premises deployment), or Forcepoint DLP (government cloud options). User training requires 40 hours across security teams to learn new interfaces and policy management. Update SSP Section 10 (Data Loss Prevention), authorization boundary diagrams removing cloud components, and create POA&M entries for migration milestones. Compliance documentation must reflect new data flow patterns and control implementations. Migration costs range $150,000-$400,000 including new licensing, professional services, staff training, and compliance documentation updates. Consider maintaining Digital Guardian in air-gapped test environments for forensic capabilities while implementing compliant alternatives for production CUI processing.
Migration Checklist
- 1ISSO must document immediate risk acceptance for Digital Guardian cloud components in POA&M with mitigation timeline per NIST 800-171 requirement 3.13.8.
- 2System administrator shall disable all cloud-based Digital Guardian features including analytics dashboards and remote management capabilities.
- 3ISSO must update authorization boundary diagrams removing Digital Guardian cloud services and documenting on-premises components only.
- 4Security team must configure enhanced logging for all Digital Guardian policy violations to compensate for reduced cloud analytics per NIST 800-171 AU family.
- 5System administrator shall implement network segmentation isolating Digital Guardian management servers from internet connectivity.
- 6ISSO must conduct data flow analysis documenting all CUI categories monitored by Digital Guardian endpoints within authorization boundary.
- 7Contracts officer must verify Digital Guardian usage complies with DFARS 252.204-7012 adequate security requirements for CUI processing.
- 8ISSO shall create incident response procedures for Digital Guardian alerts without relying on cloud-based threat intelligence feeds.
- 9System administrator must establish alternative monitoring solutions for network-level DLP to compensate for disabled cloud features.
- 10ISSO must schedule quarterly compliance reviews of Digital Guardian configuration against CMMC Level 2 requirements for SC.3.177 and SC.3.190.
Compliance Cross-References
Digital Guardian's non-FedRAMP status directly impacts NIST 800-171 System and Communications Protection (SC) controls, specifically SC.3.177 (session authenticity) and SC.3.190 (cryptographic mechanisms) when cloud components transmit CUI metadata. The violation of 3.13.8 (cryptographic mechanisms for CUI confidentiality) stems from uncontrolled cloud data transmission outside authorized boundaries. DFARS 252.204-7012 adequate security clause requires all CUI processing systems maintain FedRAMP equivalent protections, making Digital Guardian's cloud features non-compliant. CMMC Level 2 assessment domains affected include Asset Management (AM), System Security (SS), and Data Protection (DP), where assessors evaluate boundary controls and data flow documentation. The non-compliance cascades to Access Control (AC) family requirements when cloud authentication mechanisms cannot be validated against government standards. Organizations must address these gaps through POA&M entries targeting SC and AC control families while implementing compensating detective controls through enhanced audit capabilities.
NIST 800-171 Violations
Using Digital Guardian for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
Need a CUI-Compliant Alternative?
Digital Guardian has 1 NIST 800-171 gaps. Get real-time alerts when compliant alternatives launch, plus AI-matched contract opportunities.
FedRAMP Compliant Alternatives
Frequently Asked Questions
Is Digital Guardian FedRAMP authorized?
The cloud-hosted version is not FedRAMP authorized. The on-premises deployment can be hosted in your own FedRAMP authorized environment. Document your deployment model in your SSP.
Run a Full Tech Stack Audit
Check all your enterprise tools at once with our free CUI Compliance Auditor.
Launch CUI AuditorTrack Digital Guardian compliance monitoring with AI-powered intelligence
Signals matches SAM.gov opportunities to your profile, monitors regulatory changes, and alerts you before competitors. Free for 90 days.
Start Free — 90 Days