Overview
  1. 03.01: Access Control
  2. 03.02: Awareness and Training
  3. 03.03: Audit and Accountability
  4. 03.04: Configuration Management
  5. 03.05: Identification and Authentication
  6. 03.06: Incident Response
  7. 03.07: Maintenance
  8. 03.08: Media Protection
  9. 03.09: Personnel Security
  10. 03.10: Physical Protection
  11. 03.11: Risk Assessment
  12. 03.12: Security Assessment
  13. 03.13: System and Communications Protection
  14. 03.14: System and Information Integrity

Security Requirements for 03.10.04 Physical Access Logs

Organizations have flexibility in the types of audit logs employed. Audit logs can be procedural (e.g., a 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.

Assessment GuidanceExamine 0/11

How an assessor determines this requirement is met. Source: CMMC Assessment Guide – Level 2, Version 2.13 (NIST SP 800-171 Rev. 2).

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.

Examples

  1. Example 1

    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.

Assessment Methods

Examine
The process of reviewing, inspecting, observing, studying, or analyzing assessment objects (e.g., policies, procedures, plans, system designs, mechanisms) to facilitate understanding, achieve clarification, or obtain evidence.Example: An assessor reads the access control policy and inspects system configuration settings to confirm they match.

Not all of the evidence listed is required to meet this requirement — check the items your organization has collected.

Interview
The process of holding discussions with individuals or groups within an organization to facilitate understanding, achieve clarification, or identify the location of evidence.Example: An assessor asks a system administrator to describe how user accounts are approved, reviewed, and disabled.
  • Personnel with physical access control responsibilities
  • Personnel with information security responsibilities
Test
The process of exercising assessment objects (e.g., activities, mechanisms) under specified conditions to compare actual behavior with expected behavior.Example: An assessor attempts to sign in with a disabled account to confirm that access is denied.
  • Organizational processes for physical access control
  • Mechanisms supporting or implementing physical access control
  • Physical access control devices

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

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

Evidence

  1. 03.10.04.a

    Audit logs of physical access are maintained