How to Fix Common CMMC Gaps Blocking Your Data Workflow Security

A clear, auditable path to CMMC hinges on fixing a handful of recurring weaknesses in how organizations move, store, and share Controlled Unclassified Information (CUI).

In this guide we’ll show you how to achieve and maintain CMMC compliance for data workflows by scoping CUI accurately, mapping requirements to existing controls, and hardening operations with Zero Trust, continuous monitoring, and automation. We translate requirements into practical steps—complete with checklists, tables, and governance patterns—so you can reduce scope, eliminate “control drift,” and stay audit-ready while streamlining business operations.

Hard truth: documentation without operational discipline fails CMMC—this guide prioritizes enforceable, testable controls over policy prose.

Executive Summary

• Main idea: This guide shows how to achieve and sustain CMMC Level 2 compliance for data workflows by accurately scoping CUI, mapping requirements to existing controls, and hardening operations with Zero Trust, FIPS-validated cryptography, continuous monitoring, and automation. You must prove these controls with evidence tied to requirements; non‑FIPS crypto or untraceable logs will fail Level 2 crypto and audit controls.

• Why you should care: Fixing these common gaps reduces audit pain and cost, limits compliance scope, curbs tool sprawl, protects contracts (and bid eligibility), and materially lowers breach risk across email, file sharing, SFTP, and API exchanges.

Key Takeaways

1. Close recurring data-workflow gaps to stop control drift. Standardize and automate CUI discovery, access reviews, encryption, and evidence collection. Manual control execution typically drifts within a quarter; automation aligns daily operations with documented procedures, reduces assessment surprises, and strengthens resilience.

2. Right-size scope with accurate CUI discovery and DFDs. Build an authoritative asset inventory and contract-specific data flow diagrams. If you can’t draw it, you can’t defend it—find shadow channels, decommission or govern them, and validate scope with stakeholders to reduce audit surface and focus remediation.

3. Operationalize requirements with crosswalks and POA&Ms. Map NIST SP 800-171 practices to people, process, and technology. Assign one accountable owner per practice, set due dates and risks, and automate evidence, approvals, and reminders to drive closure and prevent drift.

4. Enforce Zero Trust with FIPS crypto, SSO/MFA, and least privilege. Adopt deny-by-default, identity-aware segmentation, and privileged access controls. Apply FIPS-validated encryption in transit and at rest across email, files, SFTP, and APIs; harden service accounts with vaulting and non-interactive use.

5. Centralize monitoring and evidence to stay audit-ready. Forward logs and telemetry to a SIEM, tag artifacts to controls, and maintain dashboards. If an alert can’t be traced to a ticket and resolution, assume it’s not handled; continuous monitoring, EDR/XDR, and vulnerability scanning create tamper-evident audit trails.

Understand Common CMMC Gaps in Data Workflows

Controlled Unclassified Information is sensitive government-related data that requires safeguarding and dissemination controls. It sits at the center of CMMC because its mishandling exposes the defense supply chain to nation-state and criminal threats; Level 2 maps to 110 practices from NIST SP 800-171 that govern how CUI is identified, accessed, protected, and monitored per the official Level 2 assessment guide from DoD CIO.

Common workflow gaps typically stem from inconsistent, manual practices and tooling sprawl—not a lack of policy. The result is control drift, where documented procedures diverge from day-to-day operations, undermining audits and resilience, as emphasized in the Kiteworks guide to sustaining CMMC for data workflows. Operational reality: if controls aren’t automated, reviewed, and evidenced on a cadence, drift is inevitable.

Top gaps that block certification and security often include, as detailed in Kiteworks’ CMMC Level 2 file security tools overview:

• Incomplete CUI discovery and labeling across emails, file shares, and cloud apps

• Weak or inconsistent access controls and permission reviews

• Incomplete encryption coverage for data at rest and in transit

• Gaps in monitoring, logging, and evidence collection

Quick diagnostic table:

• Gap: CUI not consistently labeled

  • Why it happens: Manual methods, siloed tools

  • Audit impact: Scope errors; missing artifacts

  • First fix: Automated, policy-driven discovery and classification with human review for edge cases

• Gap: Over-permissioned access

  • Why it happens: Privilege creep, unmanaged shares

  • Audit impact: AC-family findings

  • First fix: RBAC, MFA, periodic reviews with revoke workflows

• Gap: Encryption gaps

  • Why it happens: Mixed vendors, legacy protocols

  • Audit impact: SC-family findings

  • First fix: FIPS-validated crypto everywhere; disable deprecated protocols/ciphers

• Gap: Evidence gaps

  • Why it happens: Decentralized logging

  • Audit impact: Insufficient proof

  • First fix: Central SIEM, tagged artifacts and retention

Rule of thumb: if you cannot produce the specific artifact mapped to a requirement within 24 hours, plan for a finding.

Scope and Discover Controlled Unclassified Information

Data flow diagrams are visual maps of how information is created, processed, stored, and transmitted across systems and users. For CMMC, DFDs clarify CUI boundaries, identify in-scope assets, and reveal ungoverned paths that may bypass controls—enabling right-sized, defensible scope and fewer surprises during assessments, as explained by MAD Security’s overview of DFDs for CMMC.

Practical scoping steps (5D model: Discover, Diagram, De-scope, Defend, Demonstrate):

1. Build an authoritative inventory of assets that touch CUI: endpoints, servers, file shares, cloud apps, email, and SFTP sites (Kiteworks CMMC Level 2 file security tools).

2. Deploy automated discovery and classification to find and label CUI consistently across repositories and workflows.

3. Create DFDs for contracts and programs; mark where CUI is created, stored, processed, and transmitted.

4. Identify ungoverned or shadow channels (personal email, unmanaged SFTP, ad hoc file sharing) and either decommission or bring them in-scope.

5. Validate scope with stakeholders; update inventories and DFDs upon system or vendor changes.

If a system cannot support FIPS-validated crypto, centralized logging, or identity controls, isolate it from CUI (segment or VDI) or replace it; otherwise your scope and risk expand.

Map and Crosswalk CMMC Controls to Existing Security Practices

A crosswalk maps CMMC or NIST SP 800-171 requirements to the controls, frameworks, and owners you already have. This reduces duplication, clarifies responsibilities, and focuses remediation precisely where gaps exist. Set pass/fail criteria per requirement and require RACI ownership so accountability is unambiguous.

Operationalize the crosswalk with a Plan of Action and Milestones (POA&M): record each gap, assign an owner, set a due date, and rate risk—then track remediation to closure to prevent drift, per the Kiteworks sustainment guide for CMMC data workflows. GRC platforms streamline this work by automating evidence collection, approvals, and reminders; SecurityBricks outlines how modern GRC and adjacent tools accelerate continuous readiness. Common failure modes: stale ownership, orphaned controls, and evidence not linked to requirement IDs.

Example control matrix snippet:

Deploy Foundational Security Controls for CUI Protection

• FIPS-validated cryptography uses algorithms and modules validated under FIPS (e.g., 140-3) to meet federal standards for encryption.

• Role-based access control limits data and system access based on job functions, reducing unnecessary privileges.

• Multi-factor authentication verifies user identity with two or more credentials to mitigate credential theft.

Implementation guidance:

• Use FIPS-validated cryptography (e.g., AES-256 at rest, TLS 1.2+ in transit) across all in-scope systems, as called for in Kiteworks’ CMMC Level 2 file security guidance. Disable SSL/TLS 1.0/1.1 and weak ciphers; document module validations and verify continuously.

• Enforce RBAC, MFA, and Single Sign-On for every CUI touchpoint; augment with Data Loss Prevention and Digital Rights Management to govern sharing and downstream use. Eliminate shared credentials, vault service accounts, and log all emergency access.

Level 2 control checklist (technical coverage):

• Cryptography: FIPS-validated modules, strong ciphers, modern TLS (no deprecated protocols)

• Identity: SSO, MFA, conditional access, service account governance (no shared creds, vaulting)

• Authorization: RBAC, least privilege, periodic access reviews (with revoke SLAs)

• Data controls: DLP, DRM, secure email and file exchange (policy-enforced)

• Endpoint: EDR/XDR, disk encryption, device compliance (block noncompliant devices)

• Network: Secure configurations, segmentation, safe protocols (deny-by-default egress)

Enforce Zero Trust Access and Microsegmentation

Zero Trust assumes no implicit trust—every user, device, and session must be continuously verified. Microsegmentation divides networks and workloads into isolated segments, limiting lateral movement and blast radius.

Adopt a deny-by-default posture; apply least-privilege; and segment sensitive assets and workflows—even where CMMC does not explicitly name microsegmentation, it directly supports Level 2 technical controls and reduces breach risk, as noted in Elisity’s guidance on aligning CMMC 2.0 with lateral movement prevention. If you can’t enforce identity-aware controls and device posture checks, you aren’t operating Zero Trust in practice.

• Policy: conditional access, device posture checks, just-in-time access (kill standing admin privileges)

• Controls: identity-aware segmentation, privileged access management (vaulted creds, session recording)

• Hygiene: permission reviews to counter privilege creep (automated detects and revokes)

• Enforcement: strong egress controls, service-to-service authentication (mTLS, token-based auth)

Centralize Monitoring, Logging, and Evidence Collection

A Security Information and Event Management platform ingests security-relevant logs from systems, networks, and applications, correlates events, and surfaces alerts for investigation and response. For CMMC, a SIEM centralizes evidence, enforces retention, and provides the audit trails assessors expect for controls in the AU, IR, SI, and RA families.

Operationalize monitoring:

• Forward endpoint, network, application, and workflow logs to a SIEM; ensure time synchronization and integrity protections (hashing, secure storage) as emphasized in the Kiteworks sustainment guide. If clocks drift or integrity checks fail, evidence credibility collapses.

• Maintain always-on endpoint and network telemetry (EDR/XDR); tag evidence to mapped CMMC practices to simplify audits. Every alert should trace to a ticket and disposition; otherwise treat it as a gap.

Evidence-to-control linkage example:

Test, Remediate, and Sustain Compliance Continuously

Schedule regular vulnerability scans, penetration tests, and mock assessments; route findings into POA&Ms and track through closure to maintain readiness, as reinforced by Kiteworks’ technologies for CMMC assessment preparation and Level 2 tooling guidance. Define risk-based SLOs for remediation and escalate items that exceed thresholds to leadership.

A POA&M documents gaps, owners, milestones, risk, and remediation status; GRC tools automate evidence capture, reminders, and reporting. To prevent drift, adopt a monthly or quarterly cadence for reassessments, policy updates, and control tests, aligned with the Kiteworks sustainment guidance. Treat every failed control as a defect until the fix is demonstrated durable over multiple cycles.

Sustainment cycle:

1. Assess: scans, tests, tabletop exercises

2. Record: log findings in POA&M with risk and due dates

3. Remediate: implement fixes; validate and attach evidence

4. Review: leadership sign-off; update control matrix

5. Improve: refine scope, remove unneeded systems, harden standards

Leverage Converged Platforms to Reduce Compliance Scope and Complexity

A converged secure collaboration platform centralizes email, file sharing, automated transfers, and API exchanges under one control plane aligned to CMMC—simplifying policy enforcement, monitoring, and evidence collection across all data workflows, as outlined in Kiteworks’ assessment preparation technologies.

Organizations using converged platforms report they can address around 90% of Level 2 technical requirements through a single stack—reducing manual evidence collection and eliminating ungoverned channels—per the Kiteworks sustainment guide. Tradeoff: vendor concentration risk; mitigate with export/runbook plans, tested data portability, and compensating controls.

Before/after: legacy sprawl vs. Private Data Network

Operational Governance and Documentation Best Practices

Operational governance is the set of processes and tools that assign compliance ownership, track deviations, set deadlines, and measure progress across people, processes, and technology.

Record residual risks, deviations, and corrective actions in a POA&M or GRC tracker; integrate monitoring alerts with ticketing so every incident auto-generates evidence and traceability, consistent with Kiteworks’ sustainment framework. When full remediation is not feasible, document exceptions such as an Enduring Exception under 32 CFR § 170.4 as described in the DoD Level 2 Assessment Guide, with compensating controls and review cadence. If it’s not written, versioned, and evidenced, it didn’t happen.

Documentation essentials for CMMC assessments:

• System Security Plan with current DFDs and asset inventories

• Control matrix and crosswalk to NIST SP 800-171 practices

• Policies and procedures (access, crypto, logging, IR)

• POA&Ms with status, evidence, and approvals

• Training records and role assignments

• Audit logs, vulnerability scans, and remediation tickets

• Vendor risk and data flow documentation for third parties

How Kiteworks Helps Defense Contractors Fix These CMMC Gaps With a Private Data Network

Kiteworks’ Private Data Network unifies email, file sharing, automated transfers (MFT/SFTP), and API exchanges under a single Zero Trust control plane tailored to CMMC. This consolidation standardizes policy enforcement, streamlines monitoring and evidence collection, and helps eliminate shadow channels—reducing scope and audit effort while improving security outcomes. The capabilities below map directly to common Level 2 gaps.

• Unifies email, file sharing, automated transfers (MFT/SFTP), and API exchanges under one Zero Trust control plane—reducing scope, tool sprawl, and shadow channels while enforcing consistent policies (see Kiteworks’ CMMC compliance overview and assessment preparation guide).

• Enforces FIPS‑validated encryption end‑to‑end (AES‑256 at rest, TLS 1.2+ in transit) with centralized key management—helping satisfy SC-family crypto practices and eliminating legacy protocol exposure (CMMC compliance overview).

• Strengthens access controls with SSO/MFA, RBAC, least privilege, and governance of service accounts; applies DLP/DRM and policy-based sharing to constrain downstream use—addressing AC-family gaps across all CUI workflows (CMMC 2.0 mapping guide).

• Automates CUI discovery, labeling, and protection across repositories and channels; propagates tags and maintains a tamper-evident chain of custody to curb control drift and support defensible scope (mapping guide).

• Centralizes monitoring and evidence with unified, tamper‑evident audit logs, pre‑mapped controls, dashboards, and SIEM integrations—so every event, approval, and configuration change is traceable to CMMC requirements, shrinking audit effort (CMMC compliance overview).

• Accelerates sustainment with control crosswalks, out‑of‑the‑box reports, and automated evidence capture that feed POA&Ms and GRC workflows—keeping you continuously audit‑ready (mapping guide).

To learn more about controlling and securing your data workflows for CMMC compliance, schedule a custom demo today.

Additional Resources

• Blog Post
  CMMC Compliance for Small Businesses: Challenges and Solutions
• Blog Post
  CMMC Compliance Guide for DIB Suppliers
• Blog Post
  CMMC Audit Requirements: What Assessors Need to See When Gauging Your CMMC Readiness
• Guide
  CMMC 2.0 Compliance Mapping for Sensitive Content Communications
• Blog Post
  The True Cost of CMMC Compliance: What Defense Contractors Need to Budget For