ISC2 Governance, Risk and Compliance (CGRC) Practice Question
While applying NIST SP 800-53, you find a legacy industrial controller cannot meet FIPS 140-2 encryption for its internal disk required by SC-28. Pending replacement, which alternate control best provides equivalent protection and maintains compliance?
Require daily password changes for all operator accounts and enforce account lockout after three failed logons.
Run weekly credentialed vulnerability scans against the controller and review findings within 24 hours.
Place the controller in a locked, access-controlled cabinet with 24 × 7 surveillance and tamper-evident seals to prevent unauthorized physical access.
Configure mutual TLS on every network interface so all data in transit to and from the controller is encrypted.
SC-28 requires protecting the confidentiality and integrity of information at rest. When encryption with a FIPS-validated module is infeasible, NIST permits compensating or alternate controls that offer comparable protection. Physically restricting and monitoring access-by locking the controller in an access-controlled cabinet, adding tamper-evident seals, and maintaining continuous surveillance-prevents unauthorized access to the storage media, thereby safeguarding data at rest through physical means. Frequent password changes, mutual TLS, and vulnerability scanning address other risks but do not directly protect data stored on the device. Therefore, the secured cabinet is the most appropriate alternate control.
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ISC2 Governance, Risk and Compliance (CGRC)
Implementation of Security and Privacy Controls
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