Practice PE.L1-3.10.4 Details

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Source of Reference: The official CMMC Level 1 Self-Assessment Guide from the Office of the Under Secretary of Defense Acquisition & Sustainment.

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PE.L1-3.10.4 – PHYSICAL ACCESS LOGS

SECURITY REQUIREMENT

Maintain audit logs of physical access.

ASSESSMENT OBJECTIVES

Determine if: [a] audit logs of physical access are maintained.

POTENTIAL ASSESSMENT METHODS AND OBJECTS

Examine

[SELECT FROM: Physical and environmental protection policy;procedures addressing physical access control;system security plan;physical access control logs or records;inventory records of physical access control devices; system entry and exit points; records of key and lock combination changes; storage locations for physical access control devices;physical access control devices; list of security safeguards controlling access to designated publicly accessible areas within facility; other relevant documents or records].

Interview

[SELECT FROM: Personnel with physical access control responsibilities; personnel with information security responsibilities].

Test

[SELECT FROM: Organizational processes for physical access control; mechanisms supporting or implementing physical access control; physical access control devices].

DISCUSSION

Organizations have flexibility in the types of audit logs employed.Audit logs can be procedural (e.g., written log of individuals accessing the facility), automated (e.g., capturing ID provided by a PIV card), or some combination thereof. Physical access points can include facility access points, interior access points to systems or system components requiring supplemental access controls, or both. System components (e.g., workstations, notebook computers) may be in areas designated as publicly accessible with organizations safeguarding access to such devices.

FURTHER DISCUSSION

Make sure you have a record of who accesses your facility (e.g., office, plant, factory). You can do this in writing by having employees and visitors sign in and sign out or by electronic means such as badge readers. Whatever means you use, you need to retain the access records for the time period that your company has defined.

Example

You and your coworkers like to have friends and family join you for lunch at the office on Fridays. Your small company has just signed a contract with the DoD, however, and you now need to document who enters and leaves your facility. You work with the reception staff to ensure that all non-employees sign in at the reception area and sign out when they leave [a].You retain those paper sign-in sheets in a locked filing cabinet for one year. Employees receive badges or key cards that enable tracking and logging access to company facilities.

Potential Assessment Considerations

  • Are logs of physical access to sensitive areas (both authorized access and visitor access) maintained per retention requirements [a]?
  • Are visitor access records retained for as long as required [a]?

KEY REFERENCES

  • FAR Clause 52.204-21 Partial b.1.ix
  • NIST SP 800-171 Rev 2 3.10.4
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