ISC2 Governance, Risk and Compliance (CGRC) Practice Question
While performing scoping and applicability analysis for a new moderate-impact SaaS, you note that physical security of the hosting data center is already covered by the cloud provider. What is the appropriate way to treat NIST SP 800-53 control PE-3 in your System Security Plan?
Replace PE-3 with a compensating control such as enhanced logical access monitoring at the application layer.
List PE-3 as Not Applicable and delete it from the control summary since no on-premises equipment exists.
Identify PE-3 as an inherited control and reference the cloud provider's authorization evidence in the SSP.
Reassess the information system as low-impact so that PE-3 is no longer selected from the baseline.
Because the cloud provider is responsible for managing physical entry controls to the data center, PE-3 is a common control that your system will inherit. The correct approach is to keep the control in the baseline, mark it as inherited in the SSP, and cite the provider's FedRAMP or other authorization package as the evidence of implementation. Listing the control as Not Applicable removes needed traceability and weakens the assurance argument, re-categorizing the system only to avoid a control violates FIPS 199/200 requirements, and using a logical compensating control does not address the required physical safeguards already supplied by the provider.
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ISC2 Governance, Risk and Compliance (CGRC)
Selection and Approval of Framework, Security, and Privacy Controls
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