It is becoming increasingly difficult to tell where physical business systems end and digital ones begin. This is nothing new. In fact, we’ve previously discussed the merging, or convergence, of physical and network security. What is new are the second—and third-wave challenges organizations face from convergence.
A case in point is the impact of new data privacy regulations on the use of Physical Access Control Systems (PACS).
Modern access control systems can collect, store, and analyze sensitive personal data, such as biometric data or access logs. While PACS enhance security and operational efficiency, their use also introduces new risks related to data privacy regulations.
This article explores the critical relationship between physical access control and data protection. We’ll examine the complex challenge of regulatory compliance and best practices to ensure that your access control measures don’t compromise user privacy.
The heart of the issue is that PACS no longer operate in isolation. They connect with broader security systems and frameworks, such as identity management platforms, visitor tracking requirements, and emergency response protocols. As access control technologies continue to evolve, organizations must consider not only security but also the privacy and ethical implications of collecting and storing such highly detailed personal data.
Let’s break down the components of a PACS, which will make it clear just how many interactions you can have with these systems that generate user data.
| Component | Description |
|---|---|
| Access point | This is the physical barrier where people interact with PACS, such as turnstiles, security gates, and electronically controlled doors. |
| Credential reader |
To authorize their access, individuals must present credentials, such as swipe cards, RFID fobs, PIN codes, or biometrics. When using biometric data, such as fingerprints, facial recognition, or iris scans, the PACS will match the individual's scan against stored records. |
| Control panel | The control panel processes credential data from the reader verifies it against the credential holder database, and determines access authorization. In many settings, a modern PACS allows you to interact in other ways. For example, you could log the reason for visiting a high-security access point. |
| Access control server | A networked computer system stores credential data, access logs, and additional data collected at the access point. Server software also allows administrators to manage registrations, credential enrollment, validation, and system event logging, all of which generate their own data. Smart technologies, such as intelligent lockers and key management systems, complement broader cybersecurity measures by securing access to sensitive equipment and data-carrying devices. |
While specific PACS vary in design and capabilities, they generally manage five access control activities:
Authorization
Depending on your organization's priorities, individuals are granted access based on predefined criteria, such as employment status, role, department, or visitor classification. System administrators using the access control server assign access rights, which are adjusted as needed for individuals or groups.
Authentication
When approaching an access point, users present a credential, such as a key card, PIN, smartphone, or biometric identifier. The system verifies the credentials against stored permissions and records the access attempt.
Access
If authentication is successful, the system unlocks the door, gate, or other entry point.
Managing & Monitoring
Administrators and the system itself monitor for issues such as a series of unauthorized access attempts or a late return of a key or critical asset. They can also manage access permissions based on changing needs.
Auditing & Reporting
Access logs are crucial for security reviews and regulatory compliance. In the event of a security breach or suspicious activity, logs provide a digital trail that can assist in investigations and incident response. Organizations must determine appropriate data retention policies to balance security needs with privacy regulations.
That’s the data collected and processed by standard PACS. On the surface, it's clear that much of this data is sensitive and needs some level of protection. However, many jurisdictions have mandated data privacy in recent years and instituted strict controls and penalties for it.
General Data Protection Regulation (GDPR) - European Union
GDPR is the most comprehensive data privacy law and the one that had the furthest-reaching global impact upon its release. It applies to any company handling the personal data of EU residents, regardless of location or nationality. It mandates strict data collection, storage, and security standards and provides rights for individuals to access, change, and erase their personal data.
Health Insurance Portability and Accountability Act (HIPAA) - United States
HIPAA governs the handling of medical and health-related data, ensuring patient information is securely stored, processed, and shared only with authorized parties.
Personal Information Protection and Electronic Documents Act (PIPEDA) - Canada
Canada’s federal privacy law regulates the collection and use of personal data in commercial activities. It emphasizes data transparency and user consent.
California Consumer Privacy Act (CCPA) - United States
The CCPA grants California residents control over their personal information, allowing them to access, delete, and limit business data sharing. It has set a precedent for similar state-level privacy laws across the U.S., many of which will be coming soon.
Personal Information Protection Law (PIPL) - China
PIPL imposes strict rules on data processing, requiring companies to obtain user consent, limit data collection, and meet stringent cross-border data transfer regulations.
Protection of Personal Information Act (POPI) - South Africa
POPI establishes data protection standards for organizations operating in South Africa.
Lei Geral de Proteção de Dados (LGPD) - Brazil
LGPD mirrors GDPR principles, requiring companies to safeguard personal data and adhere to similar accountability and transparency requirements.
Network and Information Systems Directive (NIS2) - European Union
NIS2 strengthens cybersecurity requirements for organizations providing essential network infrastructure services in the EU. It includes perimeter security, building access, visitor management, and incident response provisions.
European Union Artificial Intelligence Act (EU AI Act)
This legislation sets guidelines for the ethical and transparent development and use of AI systems, classifying risks and enforcing compliance measures with significant penalties for violations. If an AI has access to personal access control data, even if it’s not actively using it, it would fall under the jurisdiction of the EU AI Act.
ISO 27001 - International
The other regulations listed here are all governmental. ISO is a private industry-based standard that outlines best practices for information security management. While certification is not mandatory, many companies adopt ISO 27001 to demonstrate their commitment to data protection and risk management, including handling personally identifiable data.
Physical security and data privacy are deeply interconnected. A breach in one domain can easily compromise the other. For example, unauthorized access to a restricted physical space, like an executive’s office, can lead to stolen sensitive data. On the flip side, a cyberattack might manipulate access control systems to allow intruders into secured locations.
Access control systems are reliable safeguards against unauthorized access to both physical and digital assets. However, this is only possible if you implement strict access control policies for using your systems, especially within an integrated security environment. By doing so, organizations can enhance security, comply with data protection regulations, and reduce breach risks without sacrificing one for the sake of another.
Consider adopting one or more of these practices to effectively manage access control and data privacy.
A strong security framework combines physical and digital security measures into a unified system—in other words, security convergence. By integrating surveillance cameras, access control systems, and cybersecurity protocols, you will have a more complete view of organizational activity with fewer gaps left for threats to exploit.
Enhances security by requiring multiple forms of use authentication at access control points. You’ll not only secure physical entry points themselves, but also ensure that only authorized personnel can access sensitive data.
Limits access based on job responsibilities, ensuring that individuals can only access data necessary for their roles—meaning their jobs and other individual responsibilities within your organization.
It grants users the minimum access necessary to perform their roles effectively. Just because an executive wants to be able to check on everything doesn't mean their credentials need access to everything. By restricting access to only what is essential, you‘ll reduce the number of potential vulnerabilities.
Utilize advanced surveillance and monitoring tools to detect and respond to suspicious activities immediately.
Encrypts data at entry points, such as badge scans and biometric data, to ensure that data intercepted between the control panel and PACS server remains protected.
Develop and maintain a comprehensive plan for responding to security breaches. This plan should outline the steps to be taken in the event of a breach, including fully identifying it, containing the damage, eliminating the threat, and recovering affected systems.
Conduct regular audits of your systems and policies. This will help you identify and rectify new vulnerabilities within each that have emerged due to changes to your organization or the threat landscape.
Regular training sessions educate employees on the importance of data privacy and access control security. They also inform them about changes in process and pol and any new threats they’re likely to encounter.
Ensures security systems can grow with the organization's operations and adjust to evolving security demands.
Keeping up with evolving data protection and privacy standards requires the right technology and trusted vendor partnerships. A reliable vendor should demonstrate a strong commitment to compliance, providing the necessary resources, legal expertise, and certified solutions to help organizations navigate regulatory changes. Look for vendors with recognized certifications from governing bodies, ensuring their products and business operations align with industry standards.
Regulatory compliance starts with the right access and asset control solutions. Real Time Networks offers electronic key cabinets and intelligent lockers that seamlessly integrate with your physical access control system (PACS) to enhance security and compliance.