Partial CUI Compliance
1 NIST 800-171 gaps detected. Not FedRAMP authorized. SOC 1/SOC 2 certified. Growing HCM provider used by some mid-size GovCon companies.
Paylocity
by Paylocity
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
HR & Payroll
Overview
Paylocity is a growing payroll and human capital management platform. SOC 1 and SOC 2 certified but not FedRAMP authorized. Used by some mid-size defense contractors for payroll, benefits, and talent management.
CUI Risk Assessment
Not FedRAMP authorized. SOC 1/SOC 2 certified. Growing HCM provider used by some mid-size GovCon companies.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
Paylocity 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 remove Paylocity from the authorization boundary diagram within the System Security Plan and document the exclusion rationale per NIST 800-171 control SC-7.
- 2Contracts officer should review all active DoD contracts to identify DFARS 252.204-7012 clauses and assess CUI handling requirements that prohibit Paylocity usage.
- 3ISSO must create POA&M entries documenting the plan to migrate away from Paylocity within 180 days to address NIST 800-171 control violations.
- 4Sysadmin should implement data loss prevention controls to prevent CUI spillage into Paylocity during the transition period per AC-4 requirements.
- 5Legal counsel must review Paylocity's data processing addendum to ensure proper data destruction procedures align with NIST 800-171 MP-6 media sanitization requirements.
- 6ISSO should establish separate processing workflows for cleared personnel data that bypass Paylocity entirely per SC-7 boundary protection controls.
- 7HR administrator must implement manual CUI marking procedures for any employee data that temporarily interfaces with Paylocity during migration per MP-3 requirements.
- 8ISSO must update the authorization boundary network diagram to show Paylocity as an external, non-CUI system with appropriate boundary protections documented.
- 9Sysadmin should configure enhanced logging for any remaining Paylocity interfaces to support NIST 800-171 AU-2 auditable events during transition period.
- 10Contracts officer should notify DCMA of the planned migration timeline and request guidance on interim compensating controls per DFARS 252.204-7021 requirements.
NIST 800-171 Violations
Using Paylocity for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
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Frequently Asked Questions
Is Paylocity FedRAMP authorized?
No. Paylocity is SOC 1/SOC 2 certified but not FedRAMP authorized. If payroll data does not include CUI, document a risk acceptance.
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