Not CUI Compliant
4 NIST 800-171 gaps detected. Not FedRAMP authorized. Using this tool for CUI creates compliance violations under NIST 800-171 and DFARS 252.204-7012.
Google Drive (Commercial)
by Google
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
Cloud Storage
Overview
Google Drive commercial is the standard consumer and business cloud storage from Google. Unlike Google Workspace Government, the commercial version is not FedRAMP authorized for CUI.
CUI Risk Assessment
Not FedRAMP authorized. Using this tool for CUI creates compliance violations under NIST 800-171 and DFARS 252.204-7012.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
Google Drive (Commercial) 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 update the System Security Plan (SSP) to document Google Drive (Commercial) as an unauthorized external system connection violating NIST 800-171 requirements.
- 2Contracts officer shall review all active DoD contracts to identify DFARS 252.204-7012 clause applicability and potential cure notice requirements due to non-compliant CUI handling.
- 3System administrator must inventory all CUI data currently stored in Google Drive (Commercial), documenting file types, sensitivity levels, and sharing permissions for migration planning.
- 4ISSO shall create POA&M entries for NIST 800-171 controls 3.1.1, 3.1.2, 3.13.1, and 3.13.8 violations caused by Google Drive (Commercial) usage.
- 5Legal team must assess contractual liability exposure under DFARS 252.204-7012 for unauthorized CUI disclosure through non-FedRAMP systems.
- 6System administrator shall implement immediate access restrictions to Google Drive (Commercial) for all users with CUI access pending complete migration.
- 7ISSO must update authorization boundary diagrams to reflect Google Drive (Commercial) removal and document compensating controls during transition period.
- 8Contracts officer shall notify contracting officers of compliance remediation timeline and request contract modification if cure notice has been issued.
- 9System administrator must configure approved FedRAMP-authorized alternative (Microsoft 365 GCC High, Box Government Cloud, or equivalent) for CUI storage replacement.
- 10ISSO shall conduct post-migration assessment to validate all CUI has been removed from Google Drive (Commercial) and update SSP to reflect compliant configuration.
NIST 800-171 Violations
Using Google Drive (Commercial) for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
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FedRAMP Compliant Alternatives
Related Compliance Assessments
Frequently Asked Questions
Is Google Drive (commercial) FedRAMP authorized?
No. The commercial version of Google Drive is not FedRAMP authorized. Only Google Workspace Government holds authorization.
Can I use Google Drive with CUI?
No. The commercial Google Drive does not meet FedRAMP requirements. Use Google Workspace Government or another authorized platform for CUI.
What is a compliant alternative to Google Drive?
Google Cloud Government (FedRAMP Moderate) and Azure Government (FedRAMP High) are authorized alternatives for cloud storage.
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