If…, then how…
If we work from a shared building or a rented office, which physical controls do we still need under ISO 27001?
Add to board memoOpen the memo
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
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.
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
- P08-A03 Annex A Control Implementation LibraryControl Library
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
- P08-A03 Annex A Control Implementation LibraryControl Library
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.
- Yes, or not known: Ask the operator in writing how entry, cameras, fire and power work
- No: Is there equipment or paper to lock away, such as network gear?
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
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
- P08-A03 Annex A Control Implementation LibraryControl Library
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.
- Yes: Is there equipment or paper to lock away, such as network gear?
- No, or not known: Add your own controls inside your space, and record the residual risk
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
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
- P08-A03 Annex A Control Implementation LibraryControl Library
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.
- Yes, or not known: Use a locked room or cabinet, with a short list of key holders
- No: Record that no secure area is needed, and why
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
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
- P08-A03 Annex A Control Implementation LibraryControl Library
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
- P08-A03 Annex A Control Implementation LibraryControl Library
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.
- Yes, or not known: Set a visitor routine: sign in, wear a badge, be escorted
- No: Set clear desk and clear screen rules that are enforced and checked
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
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
- P08-A03 Annex A Control Implementation LibraryControl Library
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
- P08-A03 Annex A Control Implementation LibraryControl Library
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.
- Yes, or not known: Encrypt portable devices; wipe or destroy old ones; keep certificates
- No: Do you control premises with sensitive equipment worth watching?
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
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
- P15-A07 Secure Information Disposal ChecklistDisposal checks
- P15-A07 Secure Information Disposal ChecklistMethods and providers
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.
- Yes: Use alarm or cameras at entrances; name who responds; set retention
- No: Are you excluding a physical control because nothing needs it?
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
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
- P08-A03 Annex A Control Implementation LibraryControl Library
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.
- Yes: Write the reason in the Statement of Applicability for each one
- No: Walk the site as an auditor would; ask a colleague to find the rules
In the pack
- P08-A04 Statement of Applicability TemplateWording Guide
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
- P08-A04 Statement of Applicability TemplateWording Guide
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
- P08-A03 Annex A Control Implementation LibraryControl Library
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.
- Yes, or not known: Fix them, update the record, then walk through again
- No: Physical controls decided for the premises, shared or rented
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
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.
- Then: Walk the site as an auditor would; ask a colleague to find the rules (back to an earlier step)
In the pack
- P08-A03 Annex A Control Implementation LibraryControl Library
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
- P08-A03 Annex A Control Implementation LibraryControl Library
Practical checklist
- List the premises and areas in scope, including shared areas and homes.
- Ask the operator in writing how entry, cameras, fire and power are handled, and for evidence.
- Add your own controls where the operator evidence does not cover your area.
- Lock away equipment and papers that need it, and set visitor, clear desk and screen lock rules.
- Encrypt portable devices and wipe or destroy storage before disposal, with certificates.
- 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
- Rules for people working from home or on personal devices. That is “How do we decide the rules for remote working and personal devices under ISO 27001?”.
- Using a cloud provider's certificate for its data centres. That is “How do we use our cloud providers' certificates and reports in our ISMS scope and Statement of Applicability?”.
- Justifying an excluded control in general. That is “How do we justify excluding an Annex A control?”.
- Keeping the asset inventory. That is “How do we keep an asset inventory that stands up to an ISO 27001 audit?”.
Related questions
- How do we decide the rules for remote working and personal devices under ISO 27001?
- How do we use our cloud providers' certificates and reports in our ISMS scope and Statement of Applicability?
- How do we justify excluding an Annex A control?
- How do we keep an asset inventory that stands up to an ISO 27001 audit?
- When must a leaver's access be removed, and what changes if they leave on bad terms?