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.
Hightail
by OpenText
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
File Sharing
Overview
Hightail (formerly YouSendIt) is a commercial file sharing and creative collaboration tool owned by OpenText. It is not FedRAMP authorized and should not be used for CUI file transfers.
CUI Risk Assessment
Not FedRAMP authorized. Using this tool for CUI creates compliance violations under NIST 800-171 and DFARS 252.204-7012.
Using Hightail in a Defense Contractor Environment
Hightail presents significant compliance challenges for defense contractors handling CUI, particularly those working with technical drawings, engineering specifications, financial proposals, and contractor performance data. As a commercial cloud service without FedRAMP authorization, Hightail cannot be placed within a CMMC Level 2 authorization boundary for CUI processing. Defense contractors commonly use Hightail for large file transfers of CAD drawings, video content, and design reviews, but these activities often involve technical data subject to ITAR or export control restrictions. No compensating controls can adequately address the fundamental lack of FedRAMP authorization when processing CUI. DCMA and DIBCAC assessors consistently flag unauthorized cloud services during CMMC assessments, with Hightail being specifically identified in recent compliance reviews as a high-risk tool due to its data residency in commercial cloud infrastructure. The tool's automatic file sharing capabilities and external collaboration features create additional risks for inadvertent CUI disclosure. Recent DCMA guidance has specifically called out file-sharing services like Hightail as requiring immediate remediation when found in contractor environments processing CUI, with findings typically escalating to Corrective Action Requests (CARs) rather than Plans of Action and Milestones (POA&Ms).
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
Hightail 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 cease using Hightail for any CUI-related activities and implement a complete migration within 30-60 days to avoid DFARS compliance violations. Phase 1 (Week 1-2): Conduct comprehensive data inventory to identify all CUI stored in Hightail accounts, coordinate with legal team to ensure proper data classification, and notify affected project teams of the migration timeline. Phase 2 (Week 3-4): Export all data using Hightail's bulk download features while maintaining chain of custody documentation for CUI materials. Phase 3 (Week 5-6): Migrate to FedRAMP authorized alternatives such as Microsoft SharePoint (FedRAMP High), Box for Government, or DoD Safe for large file transfers. User training requires 4-8 hours per employee covering new file sharing protocols and CUI handling procedures. Compliance documentation updates must include removing Hightail from the authorization boundary diagram, updating the System Security Plan (SSP) to reflect new file sharing solutions, and creating POA&M entries for any residual risks during transition. Migration costs typically range from $15,000-$50,000 for mid-size contractors, including licensing for replacement solutions, data migration services, and compliance consulting to update authorization packages.
Migration Checklist
- 1ISSO must immediately audit all Hightail accounts to identify CUI data and document findings in incident response tracking system per NIST 800-171 requirement 3.6.1.
- 2Contracts officer shall review all active contracts to determine CUI processing requirements and notify customers of file sharing tool changes per DFARS 252.204-7012 compliance.
- 3System administrator must disable all Hightail integrations and API connections to prevent automated CUI uploads while maintaining audit logs per NIST 800-171 control AU-2.
- 4ISSO shall update the authorization boundary diagram to remove Hightail and document the change in SSP Section 8 (System Boundary).
- 5Legal team must coordinate with OpenText/Hightail to execute data destruction certificates for any CUI previously stored in their systems.
- 6System administrator shall implement FedRAMP authorized replacement solution (Box for Government, SharePoint, or DoD Safe) within the existing authorization boundary.
- 7ISSO must create POA&M entry documenting migration timeline and interim risk mitigation measures per NIST 800-171 control CA-5.
- 8Training officer shall conduct mandatory briefings for all users on new file sharing procedures and CUI handling requirements per DFARS 252.204-7012.
- 9ISSO shall update incident response procedures to include file sharing tool compliance verification and unauthorized cloud service detection.
- 10Compliance officer must schedule follow-up assessment within 90 days to verify complete Hightail elimination and proper implementation of authorized alternatives.
Compliance Cross-References
Hightail's non-FedRAMP status directly violates NIST 800-171 control families AC (Access Control) through lack of federal identity management integration, SC (System and Communications Protection) via insufficient encryption and boundary protection, and AU (Audit and Accountability) due to inadequate logging for government oversight. The tool triggers DFARS 252.204-7012 violations for unauthorized external information systems and 252.204-7021 requirements for cybersecurity incident reporting when CUI exposure occurs. Under CMMC Level 2 assessment domains, Hightail creates findings in Access Control (AC), System and Information Integrity (SI), and Configuration Management (CM) practices. The violation chain operates as follows: using Hightail for CUI creates an unauthorized connection outside the organization's security boundary (SC-7), allows CUI to reside on non-FedRAMP systems (AC-4), and prevents proper audit trail maintenance (AU-2, AU-3), ultimately resulting in a fundamental failure to protect CUI as required by DFARS 252.204-7012 and potential contract compliance violations.
NIST 800-171 Violations
Using Hightail for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
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FedRAMP Compliant Alternatives
Frequently Asked Questions
Is Hightail FedRAMP authorized?
No. Hightail does not hold FedRAMP authorization at any impact level.
Can I use Hightail with CUI?
No. Hightail lacks the FedRAMP authorization and security controls required for CUI file sharing.
What is a compliant alternative to Hightail?
SharePoint GCC High and Citrix ShareFile are FedRAMP authorized file sharing platforms for government contractors.
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