CMMC v2.11 Practices


Reference: CMMC v2.11

Family: PE

Level Introduced: 1

Title: Manage Visitors & Physical Access [FCI Data]

Escort visitors and monitor visitor activity; maintain audit logs of physical access; and control and manage physical access devices.

Further Discussion:
Do not allow visitors, even those people you know well, to walk around your facility without an escort. All non-employees should wear special visitor badges and/or are escorted by an employee at all times while on the property.

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.

Identifying and controlling physical access devices (e.g., locks, badges, key cards) is just as important as monitoring and limiting who is able to physically access certain equipment. Physical access devices are only strong protection if you know who has them and what access they allow. Physical access devices can be managed using manual or automatic processes such a list of who is assigned what key, or updating the badge access system as personnel change roles.

Example 1
Coming back from a meeting, you see the friend of a coworker walking down the hallway near your office where FCI is stored. You know this person well and trust them, but are not sure why they are in the building. You stop to talk, and the person explains that they are meeting a coworker for lunch, but cannot remember where the lunchroom is. You walk the person back to the reception area to get a visitor badge and wait until someone can escort them to the lunch room [a]. You report this incident, and the company decides to install a badge reader at the main door so visitors cannot enter without an escort [a].

Example 2
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 in which your company will receive FCI 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 [c]. 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.

Example 3
You are a facility manager. A team member retired today and returns their company keys to you. The project on which they were working requires access to areas that contain equipment with FCI. You receive the keys, check your electronic records against the serial numbers on the keys to ensure all have been returned, and mark each key returned [f].

Potential Assessment Considerations
• Are personnel required to accompany visitors to areas in a facility with physical access to organizational systems [a]?
• Are visitors clearly distinguishable from regular personnel [b]?
• Is visitor activity monitored (e.g., use of cameras or guards, reviews of secure areas upon visitor departure, review of visitor audit logs) [b]?
• Are logs of physical access to sensitive areas (both authorized access and visitor access) maintained per retention requirements [c]?
• Are visitor access records retained for as long as required [c]?
• Are lists or inventories of physical access devices maintained (e.g., keys, facility badges, key cards) [d]?
• Is access to physical access devices limited (e.g., granted to, and accessible only by, authorized individuals) [e]?
• Are physical access devices managed (e.g., revoking key card access when necessary, changing locks as needed, maintaining access control devices and systems) [f]?

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Source: CMMC v2.11