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PES-07: Role-Based Physical Access

PES 9 — Critical Protect

Physical access control mechanisms exist to authorize physical access to facilities based on the position or role of the individual.

Renumbered: Formerly PES-02.1 in SCF 2025.4.

Code reused: In SCF 2025.4 and earlier, PES-07 was Supporting Utilities. That control is now PES-20.

Control Question: Does the organization authorize physical access to facilities based on the position or role of the individual?

General (25)
Framework Mapping Values
AICPA Privacy Management Framework (PMF) S7.2 S7.2-POF3
AICPA TSC 2017:2022 (used for SOC 2) (source) CC6.4 CC6.4-POF1 CC6.4-POF2
COBIT 2019 DSS05.05
ISO 27002 2022 5.15 5.18
ISO 27017 2015 9.1.1
ISO 27018 2025 5.15 5.18
NIST 800-53 R4 PE-2(1)
NIST 800-53 R5.2 PE-02(01)
NIST SP 800-66 R2 164.310(a)
NIST 800-82 R3 PE-02(01)
NIST 800-161 R1 PE-2(1)
NIST 800-161 R1 Level 2 PE-2(1)
NIST 800-161 R1 Level 3 PE-2(1)
NIST 800-171 R2 (source) 3.10.1
NIST 800-171 R3 (source) 03.04.05 03.08.01 03.08.02 03.10.01.b 03.10.01.d
NIST 800-171A R3 (source) A.03.04.05[01] A.03.08.01[01] A.03.08.01[02] A.03.08.02 A.03.10.01.ODP[01] A.03.10.01.b A.03.10.01.d
NIST CSF 2.0 (source) PR.AA-06
PCI DSS 4.0.1 (source) 8.3.11 9.1 9.2 9.2.1 9.3 9.3.1 9.3.1.1
PCI DSS 4.0.1 SAQ A-EP (source) 8.3.11 9.2.1
PCI DSS 4.0.1 SAQ C (source) 9.2.1
PCI DSS 4.0.1 SAQ C-VT (source) 9.2.1
PCI DSS 4.0.1 SAQ D Merchant (source) 8.3.11 9.2.1 9.3.1 9.3.1.1
PCI DSS 4.0.1 SAQ D Service Provider (source) 8.3.11 9.2.1 9.3.1 9.3.1.1
SCF DPMP 2026 7.3
SWIFT CSF 2025 3.1
US (10)
EMEA (9)
APAC (1)
Framework Mapping Values
APAC New Zealand HISF Suppliers 2023 HSUP04
Americas (2)
Framework Mapping Values
Americas Canada ITSP-10-171 2025 03.04.05 03.08.01 03.08.02 03.10.01.B 03.10.01.D
Americas Canada OSFI Self-Assessment Guidance 3.2.10

Capability Maturity Model

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.

Assessment Objectives

  1. PES-07_A01 physical access to the facility where the system resides is authorized based on position or role.
  2. PES-07_A02 physical access restrictions associated with changes to the system are defined and documented.
  3. PES-07_A03 the frequency at which to review the access list detailing authorized facility access by individuals is defined.
  4. PES-07_A04 authorization credentials for facility access are issued.

Evidence Requirements

E-IAC-02 Defined Roles & Authorizations (RBAC)

Documented evidence of defined access control-specific roles (e.g., Role Based Access Control (RBAC)) that affect both logical and physical access authorizations.

Identity & Access Management
E-PES-03 Defined Physical Security Roles

Documented evidence of defined physical access control-specific roles that limit physical access to rooms and/or facilities.

Physical Security
E-PES-10 Physical Access Authorizations

Documented evidence of physical access authorization activities (e.g., list reviews, termination changes, etc.).

Physical Security

Technology Recommendations

Micro/Small

  • Key or badge issuance based on job role
  • Server closet access limited to owner/IT contact

Small

  • Role-based badge access groups in door access system
  • Documented access matrix by role

Medium

  • Physical access control system with role-based access levels (e.g., Brivo, Verkada, Kisi)
  • Access matrix reviewed with HR role changes

Large

  • 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

  • Enterprise PACS integrated with identity governance for role-based physical access
  • Automated provisioning/deprovisioning from HR events
  • Quarterly access recertification by facility zone

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