You are carrying out your first third-party ISMS surveillance audit as an Audit Team Leader. You are presently in the auditee's data centre with another member of your audit team.
You are currently in a large room that is subdivided into several smaller rooms, each of which has a numeric combination lock and swipe card reader on the door. You notice two external contractors using a swipe card and combination number provided by the centre's reception desk to gain access to a client's suite to carry out authorised electrical repairs.
You go to reception and ask to see the door access record for the client's suite. This indicates only one card was swiped. You ask the receptionist and they reply, "yes it's a common problem. We ask everyone to swipe their cards but with contractors especially, one tends to swipe and the rest simply 'tailgate' their way in" but we know who they are from the reception sign-in.
Based on the scenario above which one of the following actions would you now take?
Based on the scenario above, the auditor should raise a nonconformity against control A.7.2, as the secure area is not adequately protected from unauthorized access. The auditor should provide the following evidence and justification for the nonconformity:
Evidence: The auditor observed two external contractors using a swipe card and combination number provided by the centre's reception desk to gain access to a client's suite to carry out authorized electrical repairs. The auditor checked the door access record for the client's suite and found that only one card was swiped. The auditor asked the receptionist and was told that it was a common problem that contractors tend to swipe one card and tailgate their way in, but they were known from the reception sign-in.
Justification: This evidence indicates that the organization has not implemented appropriate physical entry controls to prevent unauthorized access to secure areas, as required by control A.7.2. The organization has not defined and documented the criteria for granting and revoking access rights to secure areas, as there is no verification or authorization process for providing swipe cards and combination numbers to external contractors. The organization has not monitored and recorded the use of access rights to secure areas, as there is no mechanism to ensure that each individual swipes their card and enters their combination number before entering a secure area. The organization has relied on the reception sign-in as a means of identification, which is not sufficient or reliable for ensuring information security.
The other options are not valid actions for auditing control A.7.2, as they are not related to the control or its requirements, or they are not appropriate or effective for addressing the nonconformity. For example:
Determine whether any additional effective arrangements are in place to verify individual access to secure areas e.g. CCTV: This option is not valid because it does not address or resolve the nonconformity, but rather attempts to find alternative or compensating controls that may mitigate its impact or likelihood. While additional arrangements such as CCTV may be useful for verifying individual access to secure areas, they do not replace or substitute the requirement for appropriate physical entry controls as specified by control A.7.2.
Raise an opportunity for improvement that contractors must be accompanied at all times when accessing secure facilities: This option is not valid because it does not address or resolve the nonconformity, but rather suggests a possible improvement action that may prevent or reduce its recurrence or severity. While accompanying contractors at all times when accessing secure facilities may be a good practice for ensuring information security, it does not replace or substitute the requirement for appropriate physical entry controls as specified by control A.7.2.
Raise an opportunity for improvement to have a large sign in reception reminding everyone requiring access must use their swipe card at all times: This option is not valid because it does not address or resolve the nonconformity, but rather suggests a possible improvement action that may increase awareness or compliance with the existing controls. While having a large sign in reception reminding everyone requiring access must use their swipe card at all times may be a helpful reminder for ensuring information security, it does not replace or substitute the requirement for appropriate physical entry controls as specified by control A.7.2.
Tell the organisation they must write to their contractors, reminding them of the need to use access cards appropriately: This option is not valid because it does not address or resolve the nonconformity, but rather instructs the organization to take a corrective action that may not be effective or sufficient for ensuring information security. While writing to contractors, reminding them of the need to use access cards appropriately may be a communication measure for ensuring information security, it does not replace or substitute the requirement for appropriate physical entry controls as specified by control A.7.2.
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