PES-12: Access To Critical Systems

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.

Physical & Environmental Security (PES) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with PES domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Physical security-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. ▪ Physical security controls are primarily administrative in nature (e.g., policies & standards), focusing on protecting High Value Assets (HVAs). ▪ IT and/or cybersecurity personnel implement appropriate physical security practices to protect the confidentiality, integrity, availability and safety of the organization's technology assets and data.

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. ▪ Where applicable, physical security controls and technologies are configured to generate a log entry for each access attempt through controlled ingress and egress points.

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 enforce physical access to critical systems or sensitive/regulated data, in addition to the physical access controls for the facility.

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.

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.