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.
HubSpot
by HubSpot
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
CRM
Overview
HubSpot is a popular commercial CRM platform for marketing, sales, and customer service. It does not hold FedRAMP authorization and is not approved for handling CUI or other sensitive government data.
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)
HubSpot 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
- 1Conduct immediate CUI data inventory within HubSpot (ISSO, Week 1)
- 2Initiate procurement process for FedRAMP-authorized CRM alternative (Contracts, Week 2)
- 3Export all customer data and documents from HubSpot using native tools (Sysadmin, Week 4)
- 4Deploy and configure replacement CRM within authorization boundary (Sysadmin, Week 8-10)
- 5Migrate sanitized non-CUI data to new platform with proper access controls (ISSO, Week 12)
- 6Train users on new CRM platform and CUI handling procedures (Training Lead, Week 14-16)
- 7Update SSP and boundary documentation to reflect HubSpot removal (ISSO, Week 18)
- 8Deactivate HubSpot accounts and request data deletion certification (ISSO, Week 20)
NIST 800-171 Violations
Using HubSpot 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 HubSpot FedRAMP authorized?
No. HubSpot does not hold a FedRAMP authorization at any impact level and has not announced plans to pursue one.
Can I use HubSpot with CUI?
No. Using HubSpot to process or store CUI violates NIST 800-171 requirements for access control (3.1.1, 3.1.2) and system/communications protection (3.13.1, 3.13.8) and creates DFARS non-compliance.
What is a compliant alternative to HubSpot?
Salesforce Government Cloud and Microsoft Dynamics 365 GCC High are both FedRAMP High authorized CRM platforms that support CUI handling for defense contractors.
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