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CISO Times

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The CISO Decision Brief

If…, then how…

If we work from a shared building or a rented office, which physical controls do we still need under ISO 27001?

8 decision pointsThe pack behind this answer: ISO 27001 Implementation & Certification Readiness

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The short answer

Recommendation
List every place information is handled and ask any landlord or coworking operator, in writing, what they run and how they know it works. Add your own locked space where something needs it, set visitor, clear desk and device rules, and justify any exclusion in the Statement of Applicability with a reason.
Reasoning
In a rented or shared building the operator controls much of the perimeter, so the decision is which controls are yours and which you can show are theirs. Auditors expect evidence for what you rely on, not an assumption. The usual gaps are shared areas ignored, a landlord's tests assumed, equipment in open corridors, visitors left alone and exclusions with no reason.
Considerations
  • The standard's text is paywalled. The controls are described from the pack's Library and public guides, which are secondary.
  • Public guides say auditors may accept an operator's certificate or assurance report for the physical controls you rely on. Ask your certification body what it accepts.
  • The 6 month access review and the 30 day footage period are the Library's examples. Your risk and privacy law set yours.
  • Cameras and visitor records involve personal data, so tell people and agree retention with whoever advises on data protection.

The decision, step by step

Select any step for the reasoning behind it and where the pack covers it.

  • Start
  • Step
  • Decision
  • Outcome
  • Loop back
StartWe rent or share our premises and must decide our physical controlsStepList every place information is handled, shared floors and homes tooDecisionDoes a landlord or coworking operator control entry to the building?StepAsk the operator in writing how entry, cameras, fire and power workDecisionDoes what the operator shows cover the area you use?StepAdd your own controls inside your space, and record the residual riskDecisionIs there equipment or paper to lock away, such as network gear?StepUse a locked room or cabinet, with a short list of key holdersStepRecord that no secure area is needed, and whyDecisionDo visitors, contractors or deliveries come into the space you use?StepSet a visitor routine: sign in, wear a badge, be escortedStepSet clear desk and clear screen rules that are enforced and checkedDecisionDo devices leave the premises, go for repair or get disposed of?StepEncrypt portable devices; wipe or destroy old ones; keep certificatesDecisionDo you control premises with sensitive equipment worth watching?StepUse alarm or cameras at entrances; name who responds; set retentionDecisionAre you excluding a physical control because nothing needs it?StepWrite the reason in the Statement of Applicability for each oneStepWalk the site as an auditor would; ask a colleague to find the rulesDecisionDid the walk-through find a gap?StepFix them, update the record, then walk through againOutcomePhysical controls decided for the premises, shared or rented

Keyboard: Tab to a step, arrow keys move along the flow, Enter pins its explanation, + and − zoom, 0 fits the diagram, Esc closes. The text version below has the same content.

Where a step quotes a number, it is the default in the CISO Times pack. Your own standard may set a different one.

Read as text

The same flow written out: each step, its reasoning and where the pack covers it. 22 steps.
  1. Start

    We rent or share our premises and must decide our physical controls

    The physical controls cover perimeters, entry, rooms, monitoring, equipment and disposal. The Library marks most as almost always applying, and a few as depending on scope. In a shared or rented building the decision is which you run yourself and which the operator must show you.

    In the pack

  2. Step

    List every place information is handled, shared floors and homes too

    The first physical control asks you to identify the premises and areas in scope, including shared building areas and any equipment room. For premises you rely on but do not run, such as a landlord or a cloud provider, record whose control applies. Homes are covered by the remote working question.

    In the pack

  3. Decision

    Does a landlord or coworking operator control entry to the building?

    In a shared building you do not control the front door, the lifts or the shared areas. Ignoring shared building areas is the Library's named mistake. If you do not know who controls entry, answer yes.

    In the pack

  4. Step

    Ask the operator in writing how entry, cameras, fire and power work

    Ask what controls the operator runs, who holds keys and passes, how visitors reach your floor, whether there is a recent assurance report or certificate, and how they tell tenants of incidents. A landlord may say its systems are tested; ask for the record. Assuming it is the Library's named mistake.

    In the pack

  5. Decision

    Does what the operator shows cover the area you use?

    A certificate or report must cover the building and the controls you rely on, not another site or another service. If the operator gives only a statement, or the scope is unclear, answer no.

    In the pack

  6. Step

    Add your own controls inside your space, and record the residual risk

    Lock your suite or a room, put equipment in a locked cabinet, control keys and passes yourself, and keep sensitive paper in lockable storage. Record what the operator could not show and who accepted the remaining risk.

    In the pack

  7. Decision

    Is there equipment or paper to lock away, such as network gear?

    Equipment rooms used as storerooms and left open are the Library's named mistake, as are network switches in open corridors and a server under a desk. If you keep any equipment on site, answer yes.

    In the pack

  8. Step

    Use a locked room or cabinet, with a short list of key holders

    Choose the smallest space that works. Keep a key or pass list, review it at least every 6 months as the Library suggests and remove leavers at once. Avoid signs that say what is inside, and keep screens out of view from corridors and windows.

    In the pack

  9. Step

    Record that no secure area is needed, and why

    If all systems are cloud-hosted and staff carry only laptops, the Statement of Applicability can say that the controls for your own equipment rooms do not apply, with the reason, while controls delivered by a provider stay applicable. Keep the controls for entry, clear desk, off-premises equipment and disposal.

    In the pack

  10. Decision

    Do visitors, contractors or deliveries come into the space you use?

    Visitors left unescorted and tailgating accepted as normal are the Library's named mistakes. Even a small suite needs a simple rule. If anyone outside your staff enters, answer yes.

    In the pack

  11. Step

    Set a visitor routine: sign in, wear a badge, be escorted

    Keep the sign-in record and review it. Keep deliveries away from the equipment and the papers. Tell reception or the operator what your rule is, since they may be the ones to apply it.

    In the pack

  12. Step

    Set clear desk and clear screen rules that are enforced and checked

    Set the screen lock to a few minutes automatically, clear Confidential paper at the end of the day and collect printouts promptly. A policy with no checks, and a lock set to 60 minutes or not at all, are the Library's named mistakes. Do a short walk-round.

    In the pack

  13. Decision

    Do devices leave the premises, go for repair or get disposed of?

    Lost laptops, unencrypted drives sent for repair and devices given away without a wipe are the Library's named mistakes. If you have a stock of old devices or send any for repair, answer yes.

    In the pack

  14. Step

    Encrypt portable devices; wipe or destroy old ones; keep certificates

    Encrypt every portable device and manage it so it can be locked or wiped. Remove or protect data before repair. Wipe or destroy storage before disposal or reuse, get certificates that list serial numbers and update the inventory.

    In the pack

  15. Decision

    Do you control premises with sensitive equipment worth watching?

    Alarms and cameras help only where there is something to protect and someone to respond. Cameras nobody reviews and broken for months are the Library's named mistake. Cameras bring privacy duties. If the operator already watches the entrances and you keep nothing sensitive, answer no and record that you rely on the operator.

    In the pack

  16. Step

    Use alarm or cameras at entrances; name who responds; set retention

    Check they work, decide who responds to an alarm, and keep footage for a set period within privacy law. The Library gives 30 calendar days as an example. Tell staff and visitors about the cameras.

    In the pack

  17. Decision

    Are you excluding a physical control because nothing needs it?

    Exclusions with only 'not relevant' as the reason are what auditors reject. A control that a landlord or provider runs for you stays applicable and is marked as delivered by them; exclude only a control for an activity or equipment you do not have in scope. Homes and shared spaces are still places information is handled. If you intend to exclude a physical control, answer yes.

    In the pack

  18. Step

    Write the reason in the Statement of Applicability for each one

    For each excluded control state what you checked, such as 'no servers or network equipment are kept on our premises'. Controls that a provider's premises deliver for you are not excluded: record them as delivered by the supplier, as the cloud providers question explains. Keep the others.

    In the pack

  19. Step

    Walk the site as an auditor would; ask a colleague to find the rules

    Look at entry, the secure space, screens, cabinets and paper left out, and check the operator evidence. Ask a staff member what to do with a visitor or a lost pass. Record what you find.

    In the pack

  20. Decision

    Did the walk-through find a gap?

    Anything open, unlabelled or unknown to staff is a gap. If you did not walk through, answer yes.

    In the pack

  21. Step

    Fix them, update the record, then walk through again

    Correct the gap, brief the person involved and walk through again after the change. Repeat until the walk-through finds nothing.

    In the pack

  22. Outcome

    Physical controls decided for the premises, shared or rented

    Keep the site list, the operator evidence, the walk-through record and the Statement of Applicability reasons. Do not claim a control the operator runs as your own, and do not describe a landlord's statement as evidence of what you rely on.

    In the pack

Practical checklist

  1. List the premises and areas in scope, including shared areas and homes.
  2. Ask the operator in writing how entry, cameras, fire and power are handled, and for evidence.
  3. Add your own controls where the operator evidence does not cover your area.
  4. Lock away equipment and papers that need it, and set visitor, clear desk and screen lock rules.
  5. Encrypt portable devices and wipe or destroy storage before disposal, with certificates.
  6. Justify any exclusion in the Statement of Applicability, then walk the site as an auditor would.

Evidence to have ready

  • The site list, with who controls each area.
  • The operator's written answers and any certificate or report.
  • Visitor records, key or pass lists and the walk-through record.
  • Disposal certificates matched to the inventory.

Assumptions

  • You know which premises and areas hold information, equipment or paper in scope.
  • You can ask the building operator questions, or your contract already says what they provide.
  • Your ISMS scope and Statement of Applicability exist or are being drafted.

Not covered here