In today’s digital age, security tends to be thought about in terms of firewalls, malware, encryption and other safeguards for electronic systems. But the security of those systems, as well as an organization’s facilities, people and other critical assets depends significantly on physical security as well. We are delighted to share below some thoughts from an ASIS board certified expert in security management, Scott Soltis, CPP and CEO of HMS Security & Risk Management Solutions.

The protection of assets in all forms, people, property and information is critical to the success of all organizations.  This article highlights access control and physical security models and summarizes many industry “best practice” concepts.

The need for physical security and premise protection has been in existence for thousands of years. Access control can be found in historical architecture.  Dating back to the time of Caesar, the need to protect a physical structure can be found by use of gates, walls and other barriers.  In the dark ages, many kingdoms were protected atop high mountains or hills, or used motes and drawbridges to keep unauthorized persons from gaining access to their castles.

With modernization, physical security has quickly transcended from traditional locks and keys to the most sophisticated computerized and network based electronic access control systems, which can utilize unique credentialing approaches to identify/authorize an individual into an area. As companies expand and compete in the global marketplace, security program are being pressured for more efficiency and cost reduction.  Companies with global competition, also face the threat of industrial espionage.

Workplace violence and active violence in the workplace remains a consistent threat to U.S. companies and organizations. While this article doesn’t focus on the importance of organizations having a comprehensive workplace violence prevention program, the existence of a successful physical security program provides a core-mitigating factor to protect employees against the threat of harm.  Physical security programs help to reduce business risks and susceptibility to lawsuits and civil litigation, and assist in the protection of the assets of an organization.

Developing a Physical Security Program

A typical physical security program requires multiple layers of protection with layers becoming progressively more difficult to access closer inward toward the asset. Each layer will have multiple controls that will aid in the protection of the assets.  The function of each of the physical security layers is to deter, detect, delay, deny, and defend against loss.

In order for the physical security program to be effective, it is incumbent on the organization to develop and maintain controls to include policies and procedures, personnel management and training, physical barriers and controls, access control equipment, and adequate reporting and records management processes or systems.

Prior to deploying a physical security program, it is recommended that a qualified security professional conduct a Threat, Vulnerability/Risk Assessment (TVRA). This assessment should include but not be limited to:

  • determining the existing levels of security,
  • identifying areas of improvement in the physical security program,
  • establishing the appropriate levels of protection needed, and
  • recommending controls to enhance the overall security program.

Following the completion of the TVRA, a security program can be designed/modified to meet the needs of the organization and ensure that the security program and is adaptable to manage existing as well as future threats. A well-implemented security program will include a continual improvement process that ensures the program is adjusted to environmental changes, and ensures regular updates that tests the effectiveness of the program elements.

Having a qualified security professional implement a security program will reduce an organization’s security risks and more importantly provide a method for organizations to meet the duty of care, which would be expected by its employees.

For more information on this topic, contact Scott Soltis at: scott.soltis@hmsent.com

Tags: ASIS, physical security program, Scott Soltis, threat, TVRA, Vulnerability/Risk Assessment
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Photo of Joseph J. Lazzarotti Joseph J. Lazzarotti

Joseph J. Lazzarotti is a principal in the Berkeley Heights, New Jersey, office of Jackson Lewis P.C. He founded and currently co-leads the firm’s Privacy, Data and Cybersecurity practice group, edits the firm’s Privacy Blog, and is a Certified Information Privacy Professional (CIPP)…

Joseph J. Lazzarotti is a principal in the Berkeley Heights, New Jersey, office of Jackson Lewis P.C. He founded and currently co-leads the firm’s Privacy, Data and Cybersecurity practice group, edits the firm’s Privacy Blog, and is a Certified Information Privacy Professional (CIPP) with the International Association of Privacy Professionals. Trained as an employee benefits lawyer, focused on compliance, Joe also is a member of the firm’s Employee Benefits practice group.

In short, his practice focuses on the matrix of laws governing the privacy, security, and management of data, as well as the impact and regulation of social media. He also counsels companies on compliance, fiduciary, taxation, and administrative matters with respect to employee benefit plans.

Privacy and cybersecurity experience – Joe counsels multinational, national and regional companies in all industries on the broad array of laws, regulations, best practices, and preventive safeguards. The following are examples of areas of focus in his practice:

  • Advising health care providers, business associates, and group health plan sponsors concerning HIPAA/HITECH compliance, including risk assessments, policies and procedures, incident response plan development, vendor assessment and management programs, and training.
  • Coached hundreds of companies through the investigation, remediation, notification, and overall response to data breaches of all kinds – PHI, PII, payment card, etc.
  • Helping organizations address questions about the application, implementation, and overall compliance with European Union’s General Data Protection Regulation (GDPR) and, in particular, its implications in the U.S., together with preparing for the California Consumer Privacy Act.
  • Working with organizations to develop and implement video, audio, and data-driven monitoring and surveillance programs. For instance, in the transportation and related industries, Joe has worked with numerous clients on fleet management programs involving the use of telematics, dash-cams, event data recorders (EDR), and related technologies. He also has advised many clients in the use of biometrics including with regard to consent, data security, and retention issues under BIPA and other laws.
  • Assisting clients with growing state data security mandates to safeguard personal information, including steering clients through detailed risk assessments and converting those assessments into practical “best practice” risk management solutions, including written information security programs (WISPs). Related work includes compliance advice concerning FTC Act, Regulation S-P, GLBA, and New York Reg. 500.
  • Advising clients about best practices for electronic communications, including in social media, as well as when communicating under a “bring your own device” (BYOD) or “company owned personally enabled device” (COPE) environment.
  • Conducting various levels of privacy and data security training for executives and employees
  • Supports organizations through mergers, acquisitions, and reorganizations with regard to the handling of employee and customer data, and the safeguarding of that data during the transaction.
  • Representing organizations in matters involving inquiries into privacy and data security compliance before federal and state agencies including the HHS Office of Civil Rights, Federal Trade Commission, and various state Attorneys General.

Benefits counseling experience – Joe’s work in the benefits counseling area covers many areas of employee benefits law. Below are some examples of that work:

  • As part of the Firm’s Health Care Reform Team, he advises employers and plan sponsors regarding the establishment, administration and operation of fully insured and self-funded health and welfare plans to comply with ERISA, IRC, ACA/PPACA, HIPAA, COBRA, ADA, GINA, and other related laws.
  • Guiding clients through the selection of plan service providers, along with negotiating service agreements with vendors to address plan compliance and operations, while leveraging data security experience to ensure plan data is safeguarded.
  • Counsels plan sponsors on day-to-day compliance and administrative issues affecting plans.
  • Assists in the design and drafting of benefit plan documents, including severance and fringe benefit plans.
  • Advises plan sponsors concerning employee benefit plan operation, administration and correcting errors in operation.

Joe speaks and writes regularly on current employee benefits and data privacy and cybersecurity topics and his work has been published in leading business and legal journals and media outlets, such as The Washington Post, Inside Counsel, Bloomberg, The National Law Journal, Financial Times, Business Insurance, HR Magazine and NPR, as well as the ABA Journal, The American Lawyer, Law360, Bender’s Labor and Employment Bulletin, the Australian Privacy Law Bulletin and the Privacy, and Data Security Law Journal.

Joe served as a judicial law clerk for the Honorable Laura Denvir Stith on the Missouri Court of Appeals.

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