SOC 2 (2017 TSC) CC6.4 — Physical Access Controls

What this control requires

The entity restricts physical access to facilities and protected information assets (for example, data center facilities, backup media storage, and other sensitive locations) to authorized personnel to meet the entity's objectives.

In plain English

The entity restricts physical access to facilities and protected information assets (for example, data center facilities, backup media storage, and other sensitive locations) to authorized personnel to meet the entity's objectives. In practice, this means you can prove you information objectives-level controls on a defined cadence.

Why it matters

Every SOC 2 audit opinion is built control-by-control from the Trust Services Criteria. A missing or failing criterion produces an exception in the report, which buyers, partners and procurement teams read line-by-line during vendor reviews.

What an auditor looks for

A SOC 2 auditor (under AT-C §§ 105/205) tests both design and operating effectiveness over the audit window. For each criterion they expect a written control, a control owner, a population of events, and a sample tested against the population — including remediation tickets for exceptions.

Within Common Criteria (Security), the assessor will trace your implementation back to the catalogue reference (Criterion CC6.4) and look for objective evidence on the latest two assessment cycles.

How to implement

1. Write a short policy stating intent, scope and named owner.
2. Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
3. Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
4. Review on a documented cadence and capture the review in the risk register or compliance tracker.

Operational checklist

• Information. Document the trigger, the owner and the cadence.
• Access. Document the trigger, the owner and the cadence.
• Physical. Document the trigger, the owner and the cadence.
• Security. Document the trigger, the owner and the cadence.
• Management. Document the trigger, the owner and the cadence.
• Scope: objectives, access controls, protection, management.

Evidence to collect

• Identity Scan. IAM / IdP exports — Entra ID, Okta, IAM Identity Center, Workspace directory — showing accounts, roles, MFA state and last sign-in.
• Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.

Identity analytics (Okta, SailPoint, Access Analyzer) demonstrates least-privilege. Focus: Physical Access Controls (Original component: Logical and Physical Access Controls).

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• NIST SP 800-171 Rev. 3 3.13.4 — Information in Shared System Resources
• NIST SP 800-53 Rev. 5 CP-9(4) — Protection From Unauthorized Modification
• ISO/IEC 27001:2022 A.8.2 — Privileged access rights
• CIS Controls v8 6.7 — Centralize Access Control
• BSI C5:2020 PS-04 — Physical site access control

Related controls in SOC 2 (2017 TSC)

• Criterion CC6.1 — Logical Access Controls
• Criterion CC6.8 — Malicious Code Protection
• Criterion CC1.5 — Accountability for Internal Control Responsibilities
• Criterion P5.1 — Data Subject Access to Personal Information
• Criterion P6.7 — Data Subject Request for Information and Disclosure Accounting
• Criterion CC6.6 — Boundary Protection

References

• AICPA / ASEC — SOC 2 (2017 TSC)
• Catalogue identifier: Criterion CC6.4

Topics: identity accessdata protectionidentity managementaccess reviewprivileged accessbackup recovery