NIST Special Publication 800-171 Revision 2

Date Published: January 28th, 2021

Withdrawn on May 14, 2024. Superseded by SP 800-171 Rev. 3

Author(s): Ron Ross (NIST), Victoria Pillitteri (NIST), Kelley Dempsey (NIST), Mark Riddle (NARA), Gary Guissanie (IDA)

Note: A Class Deviation is in effect as of May 2, 2024 (DEVIATION 2024O0013). The deviation clause requires contractors, who are subject to 252.204-7012, to comply with National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 Revision 2, instead of the version of NIST SP 800-171 in effect at the time the solicitation is issued or as authorized by the contracting officer. Click Here

3.10.4: Maintain audit logs of physical access

Control Family: Physical Protection

Control Type: Derived

SPRS Value: 1

SPRS Supplemental Guidance: N/A

CMMC Level(s):

  • PE.L1-b.1.ix

  • PE.L2-3.10.4

Top Ten Failed Requirement:

No

Referenced in:

DFARS 252.204-7012

Derived From: NIST SP 800-53r4

  • PE-3

NIST Supplemental Guidance:

N/A

Discussion:

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.

Upon assessment, assessors must determine if-

Determine if audit logs of physical access are maintained.

Assessors are instructed to-

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].

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]?