Requirement
Essential Cybersecurity Controls (ECC – 2 : 2024) - Control - 2-14-4 – The cybersecurity requirements for physical protection of information and technology assets must be reviewed periodically.
Understanding the Requirement
This control requires that an organization periodically reviews its cybersecurity rules and controls that protect information and technology assets from unauthorized physical access, loss, theft, and vandalism. This is part of the Essential Cybersecurity Controls (ECC – 2 : 2024). For an SMB, the emphasis is on a documented review plan, scheduled assessments (for example, quarterly), cooperation between cybersecurity/IT and facilities/security teams, and documented approvals for any updates.
Technical Implementation
- Create a documented review schedule: Define a review cadence (e.g., quarterly for high-risk locations, biannually for low-risk), capture it in a simple audit calendar, and assign ownership to the IT/security lead. Include triggers for ad-hoc reviews (major office moves, incidents, regulatory changes).
- Maintain an asset and location inventory: Keep a current list of physical assets (servers, NAS, workstations, removable media) and their locations. Use this inventory as the basis for physical checks and to prioritize reviews for high-value or sensitive assets.
- Use a checklist-driven assessment: Build a short, repeatable checklist that covers locks, badge/access controls, visitor logs, CCTV coverage, secure storage (cabinets/saferooms), cable/port security, power/environmental protections, and disposal practices. Perform and record the checklist results each review.
- Coordinate roles and evidence collection: Conduct reviews jointly with IT/cybersecurity and facilities/security staff. Record findings in a central location (shared drive, spreadsheet, or simple compliance tool), include photos where helpful, and route corrective actions to owners using tickets or email with deadlines.
- Formalize changes and approvals: When the review results in updated requirements (policy changes, added controls, procurement of locks/CCTV), document the change and obtain sign-off from the business owner or the head of the organization (or deputy). Keep approval records with the review evidence.
- Automate reminders and track regulatory changes: Set calendar reminders for scheduled reviews and subscribe to a regulatory/industry update source relevant to your sector. When laws or standards change, trigger an immediate review to ensure physical controls remain compliant.
Example in a Small or Medium Business
A 30-person accounting firm maintains client records and several on-premise servers in a single office. The IT manager creates a quarterly review plan and a one-page checklist covering server room door locks, badge access logs, visitor sign-in, CCTV operation, and secure storage for client paper files. On review day, IT and the facilities coordinator walk the office, tick items off the checklist, take photos of insecure areas (for example an unlocked file cabinet), and open tickets for remediation. Low-cost fixes—like replacing a failed door sensor and moving a file cabinet into a locked room—are completed within two weeks; larger items, such as adding two cameras, are budgeted and approved by the office director. All review notes and approvals are stored in a shared folder labeled by quarter, and next quarter’s review is scheduled with a calendar reminder. When a new privacy regulation requires stricter chain-of-custody for client files, the firm triggers an out-of-cycle review, updates the policy, and has the director sign off on additional physical controls to comply.
Summary
Periodic review of physical cybersecurity requirements is achievable for SMBs by combining a documented schedule, an asset-driven checklist, cross-functional assessments, and proper documentation and approvals. Practical technical steps—inventorying assets, conducting checklist-based inspections, tracking corrective actions, and automating reminders—ensure the organization detects gaps and updates requirements promptly. Together, these policy and technical measures create a repeatable, auditable process that keeps physical protections aligned with business risk and regulatory obligations.
