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.
Notion
by Notion
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
Collaboration
Overview
Notion is a commercial workspace platform for notes, wikis, and project management. It does not hold FedRAMP authorization and is not suitable for defense contractor CUI collaboration.
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)
Notion 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 add Notion usage to the POA&M as a high-risk finding requiring remediation within 30 days per DFARS 252.204-7012.
- 2Contracts officer should notify the Contracting Officer Representative of the compliance gap and provide remediation timeline.
- 3System administrator must inventory all Notion workspaces and document CUI content for proper classification during migration.
- 4ISSO must update the authorization boundary diagram to show Notion as an unauthorized connection requiring removal.
- 5Legal counsel should review all Notion content for potential CUI spillage and coordinate with security team on incident reporting requirements.
- 6System administrator must export all business-critical content using Notion's native export functionality while maintaining CUI handling procedures.
- 7ISSO must select and procure FedRAMP authorized collaboration platform meeting AC-2, AC-3, and SC-8 requirements.
- 8System administrator should implement the approved replacement platform within the established authorization boundary.
- 9ISSO must update the SSP Section 10 (System Environment) to reflect the new collaboration tool and associated security controls.
- 10System administrator must verify complete data migration and deactivate all Notion accounts to eliminate unauthorized CUI storage.
NIST 800-171 Violations
Using Notion for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
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FedRAMP Compliant Alternatives
Frequently Asked Questions
Is Notion FedRAMP authorized?
No. Notion does not hold FedRAMP authorization and has not announced plans to pursue one.
Can I use Notion with CUI?
No. Notion is not authorized for CUI. Defense contractors should use FedRAMP authorized platforms like Teams GCC High for collaboration involving controlled information.
What is a compliant alternative to Notion?
Microsoft Teams GCC High with SharePoint provides FedRAMP High authorized wiki and collaboration capabilities suitable for CUI.
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