+Role-Based Physical Access
---+Dual Authorization for Physical Access
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Role-Based Physical Access
Description
Physical access control mechanisms exist to authorize physical access to facilities based on the position or role of the individual.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Key or badge issuance based on job role
∙ Server closet access limited to owner/IT contact
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Role-based badge access groups in door access system
∙ Documented access matrix by role
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Physical access control system with role-based access levels (e.g., Brivo, Verkada, Kisi)
∙ Access matrix reviewed with HR role changes
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Enterprise physical access control system with role-based zones (e.g., Lenel, Genetec, Honeywell)
∙ HR-driven role provisioning for physical access
∙ Periodic access recertification by area owner
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise PACS integrated with identity governance for role-based physical access
∙ Automated provisioning/deprovisioning from HR events
∙ Quarterly access recertification by facility zone
SCR-CMM
Level 0 Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 Performed Informally
SCR-CMM Level 1 criteria definitions are not available for this control:
▪ A reasonable person would conclude this control requires a structured process.
▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.
Level 2 Planned Tracked
Physical & Environmental Security (PES) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with PES domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with PES domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with PES domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Physical security / facilities management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Physical security / facilities management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Physical security controls and technologies primarily focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
▪ The Human Resources (HR) department maintains a current list of personnel with authorized access to organizational facilities and facilitates the implementation of physical access management controls.
Level 3 Well Defined
Physical & Environmental Security (PES) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with PES domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with PES domain capabilities are well-documented and kept current by process owners.
▪ A facilities management team, or similar function, is appropriately staffed and supported to implement and maintain NET domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of physical and environmental security operations (e.g., facility management solution, visitor log management automation and proximity badge access).
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with PES domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ An implemented and operational physical security capability exists to authorize physical access to facilities based on the position or role of the individual.
Level 4 Quantitatively Controlled
Physical & Environmental Security (PES) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.
Level 5 Continuously Improving
Physical & Environmental Security (PES) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.
▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.
1. Overview
| Summary |
Standard |
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Dual Authorization for Physical Access
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Description
Mechanisms exist to enforce a "two-person rule" for physical access by requiring two authorized individuals with separate access cards, keys or PINs, to access highly-sensitive areas (e.g., safe and high-security cage).
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Note: Typically not required at this size; two-person rule for safe/critical storage if applicable
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ Two-person rule for server room or safe access where required
∙ Dual-key or dual-code lock
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Two-person rule enforced by access control system for high-security areas
∙ Dual-authentication door readers
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ PACS dual-authorization (two-badge) rule for data center and high-security rooms
∙ Alarm on single-person entry
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Enterprise PACS with enforced two-person rule and anti-passback
∙ Video verification of dual entry
∙ Audit reporting on two-person rule compliance
SCR-CMM
Level 0 Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 Performed Informally
SCR-CMM Level 1 criteria definitions are not available for this control:
▪ A reasonable person would conclude this control requires a structured process.
▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.
Level 2 Planned Tracked
Physical & Environmental Security (PES) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with PES domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with PES domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with PES domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Physical security / facilities management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines).
▪ Physical security / facilities management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ Physical security controls and technologies primarily focus on protecting High Value Assets (HVAs), including environments where sensitive/regulated data is stored, transmitted and processed.
Level 3 Well Defined
Physical & Environmental Security (PES) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with PES domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with PES domain capabilities are well-documented and kept current by process owners.
▪ A facilities management team, or similar function, is appropriately staffed and supported to implement and maintain NET domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of physical and environmental security operations (e.g., facility management solution, visitor log management automation and proximity badge access).
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with PES domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ An implemented and operational capability exists to enforce a "two-person rule" for physical access by requiring two authorized individuals with separate access cards, keys or PINs, to access highly-sensitive areas (e.g., safe and high-security cage).
Level 4 Quantitatively Controlled
Utilize SCR-CMM Level 3 criteria definitions:
▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control.
▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.
Level 5 Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
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1.1 References
1.2 Identified Requirements
1.3 Related Regulations
2. Identified Requirements
Requirements
| Source |
Requirement |
3. Related Regulations
Regulations
| Source |
Regulation |
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EULAW
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Article 21 Access control
Article 21
As part of their control of access management rights, financial entities shall develop, document, and implement a policy that contains all of the following:
(a)
the assignment of access rights to ICT assets based on need-to-know, need-to-use and least privilege principles, including for remote and emergency access;
(b)
the segregation of duties designed to prevent unjustified access to critical data or to prevent the allocation of combinations of access rights that may be used to circumvent controls;
(c)
a provision on user accountability, by limiting to the extent possible the use of generic and shared user accounts and ensuring that users are identifiable for the actions performed in the ICT systems at all times;
(d)
a provision on restrictions of access to ICT assets, setting out controls and tools to prevent unauthorised access;
(e)
account management procedures to grant, change or revoke access rights for user and generic accounts, including generic administrator accounts, including provision on all of the following:
(i)
assignment of roles and responsibilities for granting, reviewing, and revoking access rights;
(ii)
assignment of privileged, emergency, and administrator access on a need-to-use or an ad-hoc basis for all ICT systems;
(iii)
withdrawal of access rights without undue delay upon termination of the employment or when the access is no longer necessary;
(iv)
update of access rights where changes are necessary and at least once a year for all ICT systems, other than ICT systems supporting critical or important functions and at least every 6 months for ICT systems supporting critical or important functions;
(f)
authentication methods, including all of the following:
(i)
the use of authentication methods commensurate to the classification established in accordance with Article 8(1) of Regulation (EU) 2022/2554 and to the overall risk profile of ICT assets and considering leading practices;
(ii)
the use of strong authentication methods in accordance with leading practices and techniques for remote access to the financial entity’s network, for privileged access, for access to ICT assets supporting critical or important functions or ICT assets that are publicly accessible;
(g)
physical access controls measures including:
(i)
the identification and logging of natural persons that are authorised to access premises, data centres, and sensitive designated areas identified by the financial entity where ICT and information assets reside;
(ii)
the granting of physical access rights to critical ICT assets to authorised persons only, in accordance with the need-to-know and least privilege principles, and on an ad-hoc basis;
(iii)
the monitoring of physical access to premises, data centres, and sensitive designated areas identified by the financial entity where ICT and information assets or both reside;
(iv)
the review of physical access rights to ensure that unnecessary access rights are promptly revoked.
For the purposes of point (e)(i), financial entities shall establish the retention period taking into account the business and information security objectives, the reasons for recording the event in the logs, and the results of the ICT risk assessment.
For the purposes of point (e)(ii), financial entities shall, where possible, use dedicated accounts for the performance of administrative tasks on ICT systems. Where feasible and appropriate, financial entities shall deploy automated solutions for the privilege access management.
For the purposes of point (g)(i), the identification and logging shall be commensurate with the importance of the premises, data centres, sensitive designated areas, and the criticality of the operations or ICT systems located therein.
For the purposes of point (g)(iii), the monitoring shall be commensurate to the classification established in accordance with Article 8(1) of Regulation (EU) 2022/2554 and the criticality of the area accessed.
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