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October 11, 2026·18 min read

Data centre physical security audit checklist, mapped to the PSPF, ISM, ISO 27001 and SOC 2

A data centre physical security audit checklist, each item mapped to the PSPF, ISM controls, CIRMP s 11, ISO 27001 A.7 and SOC 2 CC6.4, from site to rack.

Salman Khan·CompliancePhysical Security

The checklist below has 39 checks for a data centre physical security audit, grouped by the five boundaries from site to rack and then the plant and pathways that keep the facility running. Each row gives the check, the evidence to ask for, and the references in four standards: PSPF Release 2026 with ISM September 2026, the SOCI Act's CIRMP Rules s 11, ISO/IEC 27001:2022 Annex A.7, and SOC 2. It is free, needs no form, and prints from the browser.

The references are item-level. Where a row cites a PSPF requirement, a table or an ISM control, that reference is to the current edition. Where a column shows a dash, that standard has no direct item for the check; it may still be covered by a general control.

How to use this checklist

Walk the facility from outside in. A breach comes from the street, so an audit that starts at the rack and works out finds the gaps last. At each boundary, ask for the evidence in the row before you accept the answer, and record what you saw, not what you were told.

Score each row as met, partly met, not met, or not applicable, with one line saying why. "Not applicable" is a claim about scope, so give the reason: a facility with no Commonwealth customers can mark the PSPF column not applicable, but it cannot mark a check not applicable because the evidence is hard to find.

Three words are kept strictly in what follows. The five boundaries are the site perimeter, the building, the data hall, the cage and the rack. Layers means only the PSPF's five layers of physical security (deter, detect, delay, respond, recover) or the ISM's three layers. Zone plus a number means a PSPF Security Zone and nothing else.

Site perimeter

Fence line, gates, parking and standoff

Building

Entries, exits, emergency exits, air intakes, service ducts

ISM layer 1 · ISM-0810

Data hall

The zone the equipment's aggregated classification needs

ISM layer 2 · ISM-1053

Cage

A tenant's own fence inside the hall

Rack

A locked cabinet or SCEC-approved container

ISM layer 3 · ISM-1530

Plant and pathways

Mostly outside the halls, and often the easiest way in

  • Power and generators
  • Cooling
  • Fuel
  • Meet-me room
  • Risers and cable paths
  • Security control room
  1. Site perimeter

    Fence line, gates, parking and standoff

  2. Building

    Entries, exits, emergency exits, air intakes, service ducts

    ISM layer 1 · ISM-0810

  3. Data hall

    The zone the equipment's aggregated classification needs

    ISM layer 2 · ISM-1053

  4. Cage

    A tenant's own fence inside the hall

  5. Rack

    A locked cabinet or SCEC-approved container

    ISM layer 3 · ISM-1530

  6. Plant and pathways

    Mostly outside the halls, and often the easiest way in

    Power and generators · Cooling · Fuel · Meet-me room · Risers and cable paths · Security control room

The five boundaries from site to rack, and the plant and pathways beside them. The ISM's three layers are marked where they fall

To print it, use your browser's print command. The checklist prints as tables, one per boundary, with an empty square beside each check for ticking on paper. The six columns fit best on a horizontal page.

Which references apply to your facility

Not every column applies to every facility. Decide which ones bind you before the walk-through, because that decides which evidence you need.

ReferenceWhen it applies
PSPF Release 2026It binds Commonwealth entities. A commercial operator meets it through its government customers, who must host classified information on certified services (Requirement 0111) and place equipment in the right zone.
ISM September 2026ASD's control set for systems; its physical guidelines carry the three layers. It is not legally binding unless legislation or a direction requires it, and reaches operators through IRAP assessments and contracts.
CIRMP Rules s 11The facility is a critical data storage or processing asset under the SOCI Act, and no HCF Strategic certificate covers the services (s 30AB(4)).
ISO/IEC 27001:2022, A.7A certified management system covers the facility. Annex A has 14 physical controls, A.7.1 to A.7.14.
SOC 2, CC6.4, CC6.5, A1.2You, or a tenant whose auditor relies on your controls, has a SOC 2 report.
PCI DSS v4.0.1, Requirement 9Cardholder data is processed or stored in the facility. Map it at requirement level; v4.0.1 is the only active version since 31 December 2024.

SOC 2 is written in US English, so its criterion talks about "data center facilities"; the checks here use the Australian spelling and mean the same rooms. Two ratings often appear in the same conversation and are not on the list. An Uptime Institute Tier grades topology and operational sustainability, and Uptime says its Tier standards do not cover security, although its Tier Certification scope lists physical security among its evaluation components. TIA-942-C (May 2024) covers physical security among its subsystems and rates facilities Rated-1 to Rated-4. Both are availability and resilience ratings, so neither replaces a row below.

The checklist

01

Site perimeter

The fence line, the gates and everything between the street and the building.

01 Site perimeter: checks, evidence to ask for and references
CheckEvidence to ask forPSPF / ISMCIRMP s 11ISO A.7SOC 2
S1The site was chosen, or has been reviewed, against the site selection factors: neighbourhood, standoff perimeter, site access and parking, building access points, Security Zones and environmental risks.A dated site selection or site review record addressing each factor.Req 0191 · Table 36s 11(1)(b)A.7.1, A.7.5-
S2The perimeter is continuous: fences, gates and vehicle barriers have no gaps, and fencing is specified to a named standard.Perimeter drawing with the fence specification (the PSPF names AS 1725.1 for chain-link and AS 3016 for electric fences) and a recent walk-down with photographs.s 25.5s 11(1)(b)A.7.1CC6.4
S3Vehicle and pedestrian entry to the site, the parking area and any standoff perimeter is controlled.Gate access logs for a sample week, the list of people who can open each gate, and the standoff assessment if a vehicle threat was identified.Table 36s 11(1)(d)A.7.1, A.7.2CC6.4
S4Natural hazards for the site are identified, each with a measure: fire, flood, cyclone, storm, heatwave, earthquake and the rest of the CIRMP list.A hazard register naming each hazard, the component it reaches, the measure in place and the review date.Table 36s 11(1)(b), s 11(2)(d)A.7.5A1.2
S5The perimeter is monitored, and an alarm reaches someone who responds at any hour.Camera coverage plan for the fence line and gates, alarm test records, and the response time measured at the last test.s 23.2 · s 25.6s 11(1)(e)A.7.4-
  1. S1

    The site was chosen, or has been reviewed, against the site selection factors: neighbourhood, standoff perimeter, site access and parking, building access points, Security Zones and environmental risks.

    Evidence to ask for

    A dated site selection or site review record addressing each factor.

    PSPF / ISM
    Req 0191 · Table 36
    CIRMP s 11
    s 11(1)(b)
    ISO A.7
    A.7.1, A.7.5
    SOC 2
    -
  2. S2

    The perimeter is continuous: fences, gates and vehicle barriers have no gaps, and fencing is specified to a named standard.

    Evidence to ask for

    Perimeter drawing with the fence specification (the PSPF names AS 1725.1 for chain-link and AS 3016 for electric fences) and a recent walk-down with photographs.

    PSPF / ISM
    s 25.5
    CIRMP s 11
    s 11(1)(b)
    ISO A.7
    A.7.1
    SOC 2
    CC6.4
  3. S3

    Vehicle and pedestrian entry to the site, the parking area and any standoff perimeter is controlled.

    Evidence to ask for

    Gate access logs for a sample week, the list of people who can open each gate, and the standoff assessment if a vehicle threat was identified.

    PSPF / ISM
    Table 36
    CIRMP s 11
    s 11(1)(d)
    ISO A.7
    A.7.1, A.7.2
    SOC 2
    CC6.4
  4. S4

    Natural hazards for the site are identified, each with a measure: fire, flood, cyclone, storm, heatwave, earthquake and the rest of the CIRMP list.

    Evidence to ask for

    A hazard register naming each hazard, the component it reaches, the measure in place and the review date.

    PSPF / ISM
    Table 36
    CIRMP s 11
    s 11(1)(b), s 11(2)(d)
    ISO A.7
    A.7.5
    SOC 2
    A1.2
  5. S5

    The perimeter is monitored, and an alarm reaches someone who responds at any hour.

    Evidence to ask for

    Camera coverage plan for the fence line and gates, alarm test records, and the response time measured at the last test.

    PSPF / ISM
    s 23.2 · s 25.6
    CIRMP s 11
    s 11(1)(e)
    ISO A.7
    A.7.4
    SOC 2
    -
02

Building

The shell, its doors and every opening that is not a door. In the ISM's model, the first layer.

02 Building: checks, evidence to ask for and references
CheckEvidence to ask forPSPF / ISMCIRMP s 11ISO A.7SOC 2
B1Every building access point is secured, including emergency exits, air intakes and outlets, and service ducts.The access point schedule from the facility security plan, door hardware specifications, and photographs of intakes and ducts.Table 36 · Req 0190s 11(1)(d)A.7.1, A.7.3CC6.4
B2A facility security plan exists for the facility, and for every major refurbishment since.The plan, its date, and the list of refurbishments and construction since it was written.Req 0189, 0190s 11(2)(c)A.7.3-
B3Visitors are registered, identified, escorted where the area requires it, and signed out.Visitor log for a sample month, the written escort rule, and badge return records.Table 37s 11(1)(d)A.7.2CC6.4
B4Access to areas holding physical critical components is limited to critical workers or accompanied visitors, and the critical worker list is current.The critical worker list with roles, reconciled against the access control system's users.Table 37s 11(1)(d)A.7.2, A.7.6CC6.4
B5The intruder alarm system is certified by the right person for the zone and graded for the impact level.The alarm certificate (a suitably qualified installer for a commercial system in Zones One to Three; a SCEC-endorsed Security Zone consultant for a Type 1A system in Zones Four and Five) and the AS/NZS 2201.1 class.Table 40 · s 25.6s 11(1)(e)A.7.4-
B6Alarms are tested and maintained by an authorised provider.Service records. The PSPF says preferably every two years, at a minimum.s 25.6s 11(1)(e)A.7.13-
B7Classified systems sit in a facility that meets the requirements of a zone suitable for their classification.The zone certificate and accreditation for the area, with their dates.ISM‑0810, ISM‑1973 · Req 0196, 0198-A.7.1-
  1. B1

    Every building access point is secured, including emergency exits, air intakes and outlets, and service ducts.

    Evidence to ask for

    The access point schedule from the facility security plan, door hardware specifications, and photographs of intakes and ducts.

    PSPF / ISM
    Table 36 · Req 0190
    CIRMP s 11
    s 11(1)(d)
    ISO A.7
    A.7.1, A.7.3
    SOC 2
    CC6.4
  2. B2

    A facility security plan exists for the facility, and for every major refurbishment since.

    Evidence to ask for

    The plan, its date, and the list of refurbishments and construction since it was written.

    PSPF / ISM
    Req 0189, 0190
    CIRMP s 11
    s 11(2)(c)
    ISO A.7
    A.7.3
    SOC 2
    -
  3. B3

    Visitors are registered, identified, escorted where the area requires it, and signed out.

    Evidence to ask for

    Visitor log for a sample month, the written escort rule, and badge return records.

    PSPF / ISM
    Table 37
    CIRMP s 11
    s 11(1)(d)
    ISO A.7
    A.7.2
    SOC 2
    CC6.4
  4. B4

    Access to areas holding physical critical components is limited to critical workers or accompanied visitors, and the critical worker list is current.

    Evidence to ask for

    The critical worker list with roles, reconciled against the access control system's users.

    PSPF / ISM
    Table 37
    CIRMP s 11
    s 11(1)(d)
    ISO A.7
    A.7.2, A.7.6
    SOC 2
    CC6.4
  5. B5

    The intruder alarm system is certified by the right person for the zone and graded for the impact level.

    Evidence to ask for

    The alarm certificate (a suitably qualified installer for a commercial system in Zones One to Three; a SCEC-endorsed Security Zone consultant for a Type 1A system in Zones Four and Five) and the AS/NZS 2201.1 class.

    PSPF / ISM
    Table 40 · s 25.6
    CIRMP s 11
    s 11(1)(e)
    ISO A.7
    A.7.4
    SOC 2
    -
  6. B6

    Alarms are tested and maintained by an authorised provider.

    Evidence to ask for

    Service records. The PSPF says preferably every two years, at a minimum.

    PSPF / ISM
    s 25.6
    CIRMP s 11
    s 11(1)(e)
    ISO A.7
    A.7.13
    SOC 2
    -
  7. B7

    Classified systems sit in a facility that meets the requirements of a zone suitable for their classification.

    Evidence to ask for

    The zone certificate and accreditation for the area, with their dates.

    PSPF / ISM
    ISM‑0810, ISM‑1973 · Req 0196, 0198
    CIRMP s 11
    -
    ISO A.7
    A.7.1
    SOC 2
    -
03

Data hall

The room the equipment lives in. In the ISM's model, the additional zone and the second layer.

03 Data hall: checks, evidence to ask for and references
CheckEvidence to ask forPSPF / ISMCIRMP s 11ISO A.7SOC 2
H1The hall's zone matches the aggregated classification or business impact level of what it holds, backups included.The security risk assessment showing the aggregate, the zone chosen, and the Table 22 or Table 23 row relied on.Req 0094 · Tables 22, 23-A.7.3-
H2The server or communications room is an additional security zone inside the facility's zone.The hall's own zone certificate, separate from the building's.ISM‑1053, ISM‑1974-A.7.3-
H3The zone was certified and accredited before use, and both are current.The certification (CSO or delegate for Zones One to Four; ASIO-T4 for Zone Five areas holding TOP SECRET or catastrophic aggregates) and the accreditation, with the residual risks accepted and the expiry.Req 0196, 0197, 0198---
H4Electronic access control has current software patches and no obsolete components, and was certified by a suitably qualified installer or designer.The installer certificate, the current patch level, and vendor support dates for the head-end and readers.Table 40s 11(1)(d)A.7.2, A.7.13CC6.4
H5Access to the hall is created, modified, removed and reviewed on a record.Access requests with approvals, removals for a sample of leavers with dates, and the last two access reviews with the changes they made.Table 37s 11(1)(d)A.7.2CC6.4
H6The hall is never left unsecured, and people without access cannot observe the systems inside.Door-held-open alarm records, walk-down notes, and a sightline check from corridors and windows.ISM‑0813 · ISM‑0164s 11(1)(d)A.7.3, A.7.7CC6.4
H7Cameras cover every door into the hall, and recordings are kept for the period the policy sets.The camera schedule, the retention setting, and a retrieval test of a recording from the period.s 23.2s 11(1)(e)A.7.4-
H8Rules for working in the hall are written and followed.The secure area rules, induction records for a sample of engineers and contractors, and any recorded breaches.Table 37-A.7.6-
H9Recertification triggers are logged: expiry, a change in business impact level, a significant change to the architecture or controls, or a condition the accreditor set.The trigger log and the change records it draws on.s 24.2.3---
  1. H1

    The hall's zone matches the aggregated classification or business impact level of what it holds, backups included.

    Evidence to ask for

    The security risk assessment showing the aggregate, the zone chosen, and the Table 22 or Table 23 row relied on.

    PSPF / ISM
    Req 0094 · Tables 22, 23
    CIRMP s 11
    -
    ISO A.7
    A.7.3
    SOC 2
    -
  2. H2

    The server or communications room is an additional security zone inside the facility's zone.

    Evidence to ask for

    The hall's own zone certificate, separate from the building's.

    PSPF / ISM
    ISM‑1053, ISM‑1974
    CIRMP s 11
    -
    ISO A.7
    A.7.3
    SOC 2
    -
  3. H3

    The zone was certified and accredited before use, and both are current.

    Evidence to ask for

    The certification (CSO or delegate for Zones One to Four; ASIO-T4 for Zone Five areas holding TOP SECRET or catastrophic aggregates) and the accreditation, with the residual risks accepted and the expiry.

    PSPF / ISM
    Req 0196, 0197, 0198
    CIRMP s 11
    -
    ISO A.7
    -
    SOC 2
    -
  4. H4

    Electronic access control has current software patches and no obsolete components, and was certified by a suitably qualified installer or designer.

    Evidence to ask for

    The installer certificate, the current patch level, and vendor support dates for the head-end and readers.

    PSPF / ISM
    Table 40
    CIRMP s 11
    s 11(1)(d)
    ISO A.7
    A.7.2, A.7.13
    SOC 2
    CC6.4
  5. H5

    Access to the hall is created, modified, removed and reviewed on a record.

    Evidence to ask for

    Access requests with approvals, removals for a sample of leavers with dates, and the last two access reviews with the changes they made.

    PSPF / ISM
    Table 37
    CIRMP s 11
    s 11(1)(d)
    ISO A.7
    A.7.2
    SOC 2
    CC6.4
  6. H6

    The hall is never left unsecured, and people without access cannot observe the systems inside.

    Evidence to ask for

    Door-held-open alarm records, walk-down notes, and a sightline check from corridors and windows.

    PSPF / ISM
    ISM‑0813 · ISM‑0164
    CIRMP s 11
    s 11(1)(d)
    ISO A.7
    A.7.3, A.7.7
    SOC 2
    CC6.4
  7. H7

    Cameras cover every door into the hall, and recordings are kept for the period the policy sets.

    Evidence to ask for

    The camera schedule, the retention setting, and a retrieval test of a recording from the period.

    PSPF / ISM
    s 23.2
    CIRMP s 11
    s 11(1)(e)
    ISO A.7
    A.7.4
    SOC 2
    -
  8. H8

    Rules for working in the hall are written and followed.

    Evidence to ask for

    The secure area rules, induction records for a sample of engineers and contractors, and any recorded breaches.

    PSPF / ISM
    Table 37
    CIRMP s 11
    -
    ISO A.7
    A.7.6
    SOC 2
    -
  9. H9

    Recertification triggers are logged: expiry, a change in business impact level, a significant change to the architecture or controls, or a condition the accreditor set.

    Evidence to ask for

    The trigger log and the change records it draws on.

    PSPF / ISM
    s 24.2.3
    CIRMP s 11
    -
    ISO A.7
    -
    SOC 2
    -
04

Cage

A tenant's own enclosure inside the hall. Most tenant audit questions land here.

04 Cage: checks, evidence to ask for and references
CheckEvidence to ask forPSPF / ISMCIRMP s 11ISO A.7SOC 2
C1Each cage has its own lock or credential, separate from the hall's.The cage key or credential register, by tenant.ISM‑1074-A.7.3CC6.4
C2The operator holds each tenant's authorised list for its cage, and the tenant reviews that list on a schedule.The tenant's authorised list, the tenant's dated review confirmations, and the operator's record of changes made from them.--A.7.2CC6.4
C3Keys and equivalent access mechanisms are issued, returned and audited, and lost keys lead to lock or code changes.The key register, the last key audit, and lost-key records with the changes they caused.ISM‑1074s 11(1)(d)A.7.2CC6.4
C4Escorted work in a cage is recorded: who, when, for whom and under which ticket.The escort log reconciled against change or access tickets for a sample week.Table 37s 11(1)(d)A.7.2CC6.4
  1. C1

    Each cage has its own lock or credential, separate from the hall's.

    Evidence to ask for

    The cage key or credential register, by tenant.

    PSPF / ISM
    ISM‑1074
    CIRMP s 11
    -
    ISO A.7
    A.7.3
    SOC 2
    CC6.4
  2. C2

    The operator holds each tenant's authorised list for its cage, and the tenant reviews that list on a schedule.

    Evidence to ask for

    The tenant's authorised list, the tenant's dated review confirmations, and the operator's record of changes made from them.

    PSPF / ISM
    -
    CIRMP s 11
    -
    ISO A.7
    A.7.2
    SOC 2
    CC6.4
  3. C3

    Keys and equivalent access mechanisms are issued, returned and audited, and lost keys lead to lock or code changes.

    Evidence to ask for

    The key register, the last key audit, and lost-key records with the changes they caused.

    PSPF / ISM
    ISM‑1074
    CIRMP s 11
    s 11(1)(d)
    ISO A.7
    A.7.2
    SOC 2
    CC6.4
  4. C4

    Escorted work in a cage is recorded: who, when, for whom and under which ticket.

    Evidence to ask for

    The escort log reconciled against change or access tickets for a sample week.

    PSPF / ISM
    Table 37
    CIRMP s 11
    s 11(1)(d)
    ISO A.7
    A.7.2
    SOC 2
    CC6.4
05

Rack

The container. In the ISM's model, the third layer.

05 Rack: checks, evidence to ask for and references
CheckEvidence to ask forPSPF / ISMCIRMP s 11ISO A.7SOC 2
R1Racks are the container the zone requires: a lockable commercial cabinet, or the SCEC class that Table 22 or Table 23 sets.The rack specification and, where a SCEC class is required, the SCEC approval.Tables 22, 23 · s 25.1 · ISM‑1530, ISM‑1975-A.7.8-
R2TOP SECRET equipment sits in SCEC-endorsed racks or compartments inside an accredited Zone Five area.The Zone Five accreditation and the rack or compartment approvals.Req 0095-A.7.8-
R3Rack locks and their keys or codes are controlled like any other access mechanism.The rack key or code register and its last audit.ISM‑1074-A.7.8CC6.4
R4IT equipment and media are secured when not in use, and media is stored to its classification.The media register and the storage location for a sample of items.ISM‑0161-A.7.10-
R5Equipment leaving for repair or disposal has its data removed first, and protection over it ends only once data cannot be recovered.Removal authorisations, and sanitisation or destruction certificates matched to asset tags.--A.7.9, A.7.14CC6.5
  1. R1

    Racks are the container the zone requires: a lockable commercial cabinet, or the SCEC class that Table 22 or Table 23 sets.

    Evidence to ask for

    The rack specification and, where a SCEC class is required, the SCEC approval.

    PSPF / ISM
    Tables 22, 23 · s 25.1 · ISM‑1530, ISM‑1975
    CIRMP s 11
    -
    ISO A.7
    A.7.8
    SOC 2
    -
  2. R2

    TOP SECRET equipment sits in SCEC-endorsed racks or compartments inside an accredited Zone Five area.

    Evidence to ask for

    The Zone Five accreditation and the rack or compartment approvals.

    PSPF / ISM
    Req 0095
    CIRMP s 11
    -
    ISO A.7
    A.7.8
    SOC 2
    -
  3. R3

    Rack locks and their keys or codes are controlled like any other access mechanism.

    Evidence to ask for

    The rack key or code register and its last audit.

    PSPF / ISM
    ISM‑1074
    CIRMP s 11
    -
    ISO A.7
    A.7.8
    SOC 2
    CC6.4
  4. R4

    IT equipment and media are secured when not in use, and media is stored to its classification.

    Evidence to ask for

    The media register and the storage location for a sample of items.

    PSPF / ISM
    ISM‑0161
    CIRMP s 11
    -
    ISO A.7
    A.7.10
    SOC 2
    -
  5. R5

    Equipment leaving for repair or disposal has its data removed first, and protection over it ends only once data cannot be recovered.

    Evidence to ask for

    Removal authorisations, and sanitisation or destruction certificates matched to asset tags.

    PSPF / ISM
    -
    CIRMP s 11
    -
    ISO A.7
    A.7.9, A.7.14
    SOC 2
    CC6.5
06

Plant and pathways

Power, cooling, fuel, the meet-me room, the risers and the security control room. Mostly outside the halls, and what stops the facility if it fails.

06 Plant and pathways: checks, evidence to ask for and references
CheckEvidence to ask forPSPF / ISMCIRMP s 11ISO A.7SOC 2
P1The physical critical components are listed, with the plant and pathways the halls depend on.The dated critical component list in the risk management program.-s 11(1)(a), s 11(2)(a)A.7.11-
P2Power, cooling and fuel have their own access control and alarms, separate from the halls.Plant room access lists and the alarm points on generator, fuel and cooling areas.-s 11(1)(b), (d)A.7.11A1.2
P3Cabling between rooms and to carriers is protected, and network devices in public or shared areas are secured.Riser and pathway drawings, and the locks on network equipment in shared paths.ISM‑1296s 11(1)(b)A.7.12-
P4The meet-me room is a controlled area with its own access list, and carrier staff are escorted.The meet-me room access list and carrier escort records for a sample month.-s 11(1)(d)A.7.3, A.7.12CC6.4
P5The security control room is itself protected, and monitoring continues through business hours and out of hours.The control room access list, the roster showing cover at all hours, and the failover for monitoring.s 23.2s 11(1)(e)A.7.4-
P6Plant and security systems are maintained to schedule by authorised people.Maintenance records and contractor access records for the same dates.Table 40s 11(1)(b)A.7.13A1.2
P7A procedure covers unauthorised access to any critical component, and it has been used or rehearsed.The procedure, the last exercise record, and any incident records since.s 23.2s 11(1)(c)--
P8The arrangements have been tested to detect, delay, deter, respond to and recover from a breach.A test plan and dated results for each of the five.s 23.2s 11(1)(e)--
P9Where government customers rely on HCF certification, physical access security and the other core capabilities have not changed without the approval the certificate requires.The Relevant Change log and the approvals behind it.Req 0111---
  1. P1

    The physical critical components are listed, with the plant and pathways the halls depend on.

    Evidence to ask for

    The dated critical component list in the risk management program.

    PSPF / ISM
    -
    CIRMP s 11
    s 11(1)(a), s 11(2)(a)
    ISO A.7
    A.7.11
    SOC 2
    -
  2. P2

    Power, cooling and fuel have their own access control and alarms, separate from the halls.

    Evidence to ask for

    Plant room access lists and the alarm points on generator, fuel and cooling areas.

    PSPF / ISM
    -
    CIRMP s 11
    s 11(1)(b), (d)
    ISO A.7
    A.7.11
    SOC 2
    A1.2
  3. P3

    Cabling between rooms and to carriers is protected, and network devices in public or shared areas are secured.

    Evidence to ask for

    Riser and pathway drawings, and the locks on network equipment in shared paths.

    PSPF / ISM
    ISM‑1296
    CIRMP s 11
    s 11(1)(b)
    ISO A.7
    A.7.12
    SOC 2
    -
  4. P4

    The meet-me room is a controlled area with its own access list, and carrier staff are escorted.

    Evidence to ask for

    The meet-me room access list and carrier escort records for a sample month.

    PSPF / ISM
    -
    CIRMP s 11
    s 11(1)(d)
    ISO A.7
    A.7.3, A.7.12
    SOC 2
    CC6.4
  5. P5

    The security control room is itself protected, and monitoring continues through business hours and out of hours.

    Evidence to ask for

    The control room access list, the roster showing cover at all hours, and the failover for monitoring.

    PSPF / ISM
    s 23.2
    CIRMP s 11
    s 11(1)(e)
    ISO A.7
    A.7.4
    SOC 2
    -
  6. P6

    Plant and security systems are maintained to schedule by authorised people.

    Evidence to ask for

    Maintenance records and contractor access records for the same dates.

    PSPF / ISM
    Table 40
    CIRMP s 11
    s 11(1)(b)
    ISO A.7
    A.7.13
    SOC 2
    A1.2
  7. P7

    A procedure covers unauthorised access to any critical component, and it has been used or rehearsed.

    Evidence to ask for

    The procedure, the last exercise record, and any incident records since.

    PSPF / ISM
    s 23.2
    CIRMP s 11
    s 11(1)(c)
    ISO A.7
    -
    SOC 2
    -
  8. P8

    The arrangements have been tested to detect, delay, deter, respond to and recover from a breach.

    Evidence to ask for

    A test plan and dated results for each of the five.

    PSPF / ISM
    s 23.2
    CIRMP s 11
    s 11(1)(e)
    ISO A.7
    -
    SOC 2
    -
  9. P9

    Where government customers rely on HCF certification, physical access security and the other core capabilities have not changed without the approval the certificate requires.

    Evidence to ask for

    The Relevant Change log and the approvals behind it.

    PSPF / ISM
    Req 0111
    CIRMP s 11
    -
    ISO A.7
    -
    SOC 2
    -
Data centre physical security audit checklist. References: PSPF Release 2026 (1 July 2026); ISM September 2026; CIRMP Rules compilation 2 (10 June 2026); ISO/IEC 27001:2022 Annex A; AICPA Trust Services Criteria CC6.4, CC6.5 and A1.2

What good evidence looks like

Good evidence is dated, names a person, and comes from a sample the auditor chose. An access review that lists who was removed and who approved the result is evidence; a policy that says reviews happen quarterly is not. An alarm service record from an authorised provider, a zone certificate with its expiry, an installer's certificate that confirms current patches, and a test result for each of the five verbs all carry their own date, which is what makes them hold up.

SOC 2 deserves one note. Criterion CC6.4 restricts physical access to facilities and protected information assets to authorised personnel, and its points of focus are creating or modifying, removing, and reviewing that access. It names no device. A SOC 2 auditor will test the lifecycle, so the evidence for H5 and C2 matters more than the camera count.

For the SOCI column, CIRMP Rules s 11(2) asks the entity to have regard to whether the program itself describes the critical components, the physical security hazards, the security arrangements and the natural hazards, so ask for the program, not only the site documents. The SOCI physical security post covers what each paragraph of s 11 asks.

Five gaps to look for first

These are the places where a facility that passes the hall walk-through often fails the full walk.

  1. Plant rooms on a looser access list than the halls. A generator room or fuel store that any contractor badge opens is a shorter way to stop the facility than any hall door.
  2. Tenant lists that nobody reviews. The operator holds the list, the tenant assumes the operator checks it, and the SOC 2 auditor asks for the review that neither party did.
  3. An access control head-end out of vendor support. Table 40 asks for current patches and no obsolete components, and an unsupported head-end fails both.
  4. Alarms that alert nobody at night. A control room roster with a gap turns detect into record.
  5. Escort rules that stop at the hall door. The riser, the meet-me room and the roof plant are on the same routes, and s 11(1)(d) covers every physical critical component.

Who signs off what

An audit finds and records; it does not certify. Under PSPF Release 2026, the Commonwealth entity's CSO or delegate certifies and accredits Zones One to Four, ASIO-T4 certifies Zone Five areas holding TOP SECRET or catastrophic aggregates, a suitably qualified installer or designer certifies commercial alarms and access control, and a SCEC-endorsed Security Zone consultant certifies a Type 1A alarm in Zones Four and Five. An accredited certification body issues an ISO 27001 certificate, a CPA firm attests a SOC 2 report, and a PCI DSS assessment is a Qualified Security Assessor's or a self-assessment. The PSPF security zones guide covers the zone signatures in full, and the HCF guide covers the certification government customers ask about.

If you want the walk done for you, our data centre physical security practice assesses a facility against the regimes that apply, designs the boundaries and prepares the evidence each certifier reads, with the certificate left to the authority each regime names.

Questions this guide gets asked

What should a data centre physical security audit cover?

It should cover five boundaries, from the site perimeter through the building, the data hall and the cage to the rack, plus the plant and pathways that keep the facility running: power, cooling, fuel, the meet-me room, risers and the security control room. For each check, ask for dated evidence rather than a description, and record which standard the check answers. The checklist in this post has 39 checks laid out that way, mapped to PSPF Release 2026, ISM September 2026, CIRMP Rules s 11, ISO/IEC 27001:2022 Annex A.7 and SOC 2.

Which standards apply to data centre physical security in Australia?

It depends on who the facility serves. The PSPF and the ISM bind Commonwealth entities and reach a commercial operator through its government customers. CIRMP Rules s 11 applies if the facility is a critical data storage or processing asset under the SOCI Act. ISO/IEC 27001:2022 Annex A.7 applies where a certified management system covers the facility, SOC 2 CC6.4 where you or a tenant relies on a SOC 2 report, and PCI DSS v4.0.1 Requirement 9 where cardholder data is in the facility.

Does SOC 2 require CCTV, biometrics or mantraps in a data centre?

No. SOC 2 criterion CC6.4 asks that physical access to facilities and protected information assets, such as data center facilities and backup media storage, is restricted to authorised personnel. Its points of focus are about the access lifecycle: creating or modifying, removing, and reviewing physical access. Points of focus are not mandatory, and none of them names a device. The auditor tests whether access is restricted and managed, however you do it.

Is an Uptime Tier or TIA-942 rating a security certification?

No. An Uptime Institute Tier grades infrastructure topology and operational sustainability, and Uptime says its Tier standards do not cover factors such as security, though its Tier Certification scope lists physical security among its evaluation components. TIA-942-C, published in May 2024, covers physical security among its subsystems and rates facilities Rated-1 to Rated-4. Treat both as availability and resilience ratings, and use the PSPF, the ISM, ISO 27001 or SOC 2 for security.

Who certifies a data centre's security zone?

Under PSPF Release 2026, the Commonwealth entity's Chief Security Officer, or a delegate, certifies Zones One to Four, and ASIO-T4 certifies Zone Five areas holding TOP SECRET or aggregated information with a catastrophic business impact (Requirements 0196 and 0197). Alarms and access control are certified first by a suitably qualified installer or, for a Type 1A alarm in Zones Four and Five, a SCEC-endorsed Security Zone consultant. The CSO then accredits the zone, and ASD accredits SCIFs.

SK

Written by

Salman KhanFounder & Principal, Alvor

Salman founded Alvor, the security architecture management and compliance platform, and leads its security architecture practice. He writes about design reviews, threat modeling, and running security programs that engineering teams don't route around.

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