PE-8: Visitor Access Records

PE-8 requires you to maintain visitor access records for the facility where your system resides, and keep those records for an organization-defined retention period. Operationalize it by defining which facilities are in scope, standardizing what fields you capture at sign-in/sign-out, protecting the logs from tampering, and proving you can retrieve records quickly for audits and investigations. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Key takeaways:

• Define scope first: which sites, rooms, and “system resides” locations count, including colocation and shared spaces.
• Capture complete, consistent visitor log fields (identity, host, purpose, times, areas accessed) and enforce sign-out discipline.
• Treat visitor logs as security records: retention, access control, integrity, and audit-ready retrieval.

The pe-8: visitor access records requirement is a physical security control with outsized impact during incident response and audits. If you cannot prove who entered controlled areas, when they entered, and which internal staff sponsored that access, you create blind spots for investigations and weaken your ability to dispute or confirm suspected physical compromise.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to convert PE-8 into an operable “records system” problem: define the facilities in scope, define the minimum required log fields, set a retention period that matches your risk and contractual obligations, and implement a repeatable method to collect, protect, and retrieve the records. The work is rarely only about a front-desk binder; it also touches badge systems, security contractors, visitor management kiosks, and data center access lists from third parties.

This page gives requirement-level implementation guidance you can hand to Facilities, Security, and IT, then test with simple evidence checks. It also highlights common audit hangups, so you can answer the inevitable examiner question: “Show me visitor logs for this site and this time window, and prove they’re complete.” (NIST SP 800-53 Rev. 5)

Regulatory text

Requirement (PE-8): “Maintain visitor access records to the facility where the system resides for {{ insert: param, pe-08_odp.01 }};” (NIST SP 800-53 Rev. 5 OSCAL JSON)

What the operator must do:

1. Maintain visitor access records (create and keep them, not just collect ad hoc sign-in sheets).
2. Cover the facility where the system resides (your defined physical locations housing the information system components).
3. Keep records for an organization-defined retention period (the parameter is intentionally left to you, so auditors will expect you to define it, approve it, and follow it). (NIST SP 800-53 Rev. 5 OSCAL JSON)

Plain-English interpretation

You need a reliable way to answer: who visited, who sponsored them, why they were there, when they entered and exited, and what areas they accessed at any location that houses your in-scope system. You must keep those records for a defined period and be able to retrieve them when needed. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Who it applies to

Entity types

• Federal information systems implementing NIST SP 800-53 controls. (NIST SP 800-53 Rev. 5)
• Contractor systems handling federal data where NIST SP 800-53 is imposed by contract, authorization boundary, or customer requirements. (NIST SP 800-53 Rev. 5)

Operational context (what “facility where the system resides” means in practice)

Treat PE-8 scope as a mapping exercise across physical and outsourced environments:

• Your offices: server rooms, network closets, labs, secure file rooms, and any restricted areas supporting the system.
• Data centers you operate: all controlled entry points and visitor procedures.
• Colocation / third-party data centers: where the system resides in cabinets/cages you rent. You may need the third party’s access logs as part of your evidence set.
• Remote/edge locations: branch sites or industrial locations housing system components.

If you do not explicitly define “in-scope facilities,” PE-8 becomes impossible to test and you will fail audits on ambiguity and missing coverage.

What you actually need to do (step-by-step)

Step 1: Define the PE-8 scope statement

Create a short, auditable scope statement that lists:

• Facilities in scope (by name/address or internal site code).
• The areas within each facility covered by visitor recording (e.g., lobby + escorted access to secure areas, or all non-employee entry).
• The system boundary rationale: why these facilities are “where the system resides.” (NIST SP 800-53 Rev. 5)

Practical tip: include colocations explicitly and name the third party operator responsible for base building access controls.

Step 2: Set your retention period (the organization-defined parameter)

PE-8 requires you to define and follow a retention period. Decide it, document it, and get it approved by the control owner and records/privacy stakeholders.

A workable approach:

• Set a default retention period for visitor logs based on your investigation needs and contractual requirements.
• Document exceptions (e.g., sites with stricter customer requirements, or privacy-driven minimization constraints).
• Tie retention to your records retention schedule and disposal process.

Step 3: Standardize the minimum required visitor log fields

Define a required data schema. Keep it simple and enforce it everywhere. Typical minimum fields:

• Visitor full name
• Visitor organization (company)
• Government ID type checked (do not copy ID numbers unless you have a justified need and privacy approval)
• Date
• Time in / time out
• Host/escort employee name
• Purpose of visit
• Areas authorized (e.g., “Floor 3 lab,” “DC cage A12”)
• Badge number issued (if applicable)
• Acknowledgement of site rules (signature or digital attestation)
• Exceptions noted (e.g., “emergency access,” “after-hours approval reference”)

If you use a paper log, define legibility rules and error correction rules (single strike-through, initial/date). If you use an electronic visitor management system, configure required fields and prevent “save with blanks.”

Step 4: Implement a consistent workflow (front desk and after-hours)

Document and train the workflow:

1. Visitor arrives, identity is verified per your procedure.
2. Visitor is issued a temporary badge and informed of escort rules.
3. Visitor is logged with required fields.
4. Visitor is escorted or monitored per site policy.
5. Visitor returns badge and signs out; time out is captured.
6. Logs are secured and forwarded/archived per schedule.

Address after-hours and unmanned entries:

• Define who can authorize after-hours access.
• Require the sponsor/host to record the visit details if no receptionist is present.
• For sites with guard services, ensure the guard contract requires your logging fields and retention.

Step 5: Protect the records (integrity and access control)

PE-8 is a “records” control, but auditors will test whether the records are trustworthy:

• Restrict who can edit logs.
• Store logs in a controlled repository (for electronic systems) or locked storage (for paper).
• Define who can request logs and under what approvals (Security, HR, Legal, Compliance).
• Ensure you can produce logs without gaps or unexplained missing days.

Step 6: Make it auditable (retrieval test + periodic review)

Add two operational checks:

• Retrieval test: pick a date range and site, then prove you can retrieve complete visitor logs promptly.
• Quality review: sample logs for completeness (missing sign-outs, missing host names, unreadable entries). Track corrective actions with Facilities/Security.

Step 7: Assign ownership and recurring evidence

Map PE-8 to:

• Control owner (often Physical Security or Facilities; sometimes Corporate Security)
• Contributors (Reception/Facilities, IT for systems, third-party DC provider manager)
• Evidence cadence (monthly export, quarterly sample review, or event-driven collection)

Daydream (as a workflow layer) fits here by turning PE-8 into a control record with an assigned owner, a documented procedure, and scheduled evidence requests, so you do not chase logs during audits. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Required evidence and artifacts to retain

Keep evidence that proves design and operation:

Core artifacts

• PE-8 procedure (visitor logging standard, including required fields and sign-in/out process). (NIST SP 800-53 Rev. 5)
• Scope list of in-scope facilities/areas tied to the system boundary. (NIST SP 800-53 Rev. 5)
• Retention requirement and where it is documented (records schedule, policy, or control standard). (NIST SP 800-53 Rev. 5)

Operational evidence

• Visitor logs for selected periods (paper scans or system exports) showing required fields populated.
• Evidence of access control to logs (system roles, permissions screenshots, or physical storage controls).
• Training/briefing records for front desk/guards (attendance, SOP acknowledgement).
• Third-party data center or building management access logs (or contract language + delivery mechanism) when the system resides there.

Audit-readiness proof

• A completed retrieval test record (who requested, what was produced, timing, outcome, issues found).
• Exception records (lost badge, emergency entry) with approvals and reconciliation.

Common exam/audit questions and hangups

Use these as your internal test script:

1. “Which facilities are in scope for PE-8, and why?”
   Hangup: orgs list corporate HQ but forget colocations or small branch closets.

2. “Show me visitor logs for Site X for a specific week.”
   Hangup: logs exist but are split across paper binders, guard contractor systems, and badge system reports with no consolidation plan.

3. “How do you prevent log tampering or backfilling?”
   Hangup: editable spreadsheets with no access control or change history.

4. “How do you handle after-hours visitors and deliveries?”
   Hangup: loading dock access and cleaning crews bypass visitor logging.

5. “What is your retention period, and can you prove you follow it?”
   Hangup: policy says one thing, operations keep records inconsistently, or dispose of them informally.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Treating PE-8 as “front desk sign-in sheet only”	Misses secure areas, data centers, and third-party sites	Create a facility inventory and map “system resides” locations
Missing sign-outs	You cannot prove exit time or detect overstays	Make sign-out required to return badge; add daily reconciliation
Logging without sponsor/host	No accountability for access	Require host name and contact; reject entries without it
Storing logs in editable files	Weak integrity and easy audit finding	Use a visitor management system or locked paper process with controlled scanning
Ignoring privacy implications	Visitor logs contain personal data	Minimize fields, restrict access, and align with records retention

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for PE-8, so you should treat this as an assessment and authorization readiness requirement rather than a control with a known enforcement pattern in this dataset.

Operationally, the risk is concrete:

• Incident response blind spots: without visitor records, you cannot correlate suspicious activity with physical presence.
• Insider and third-party risk: weak visitor controls allow tailgating, unsponsored access, and untraceable entry into controlled areas.
• Audit findings: missing or incomplete logs commonly become “operating effectiveness” failures because the control is easy to test and evidence-based. (NIST SP 800-53 Rev. 5)

Practical 30/60/90-day execution plan

First 30 days (stabilize and define)

• Assign a PE-8 control owner and backup.
• Publish the scope list of in-scope facilities/areas tied to the system boundary.
• Decide the retention period and document it in your records schedule/control standard.
• Define the minimum required log fields and produce a standard template (paper and electronic).
• Identify all log sources (front desk, guard contractor, badge system, third-party data center).

Days 31–60 (implement consistently)

• Train reception/guards/hosts on the workflow and required fields.
• Configure visitor management tooling (or tighten paper controls) to prevent incomplete entries.
• Implement secure storage: access-controlled repository for scans/exports; locked storage for originals.
• Start a recurring evidence collection routine (e.g., monthly export or scanning schedule) with named owners.

Days 61–90 (prove it works)

• Run a retrieval test for at least one site and one historical period; document results and remediation.
• Perform a completeness review sample; fix recurring gaps (sign-outs, missing host, unclear purpose).
• For colocations, obtain and validate the third party’s access logs and confirm you can request them on demand.
• Add PE-8 to your audit calendar and continuous control monitoring plan, with Daydream tasks for evidence requests and attestations.

Frequently Asked Questions

Do delivery drivers and couriers count as “visitors” under PE-8?

Treat anyone who enters controlled areas as a visitor unless they are an authorized employee with standard access. If deliveries stop at a public lobby, you may log them differently, but document that boundary and enforce it consistently. (NIST SP 800-53 Rev. 5)

If we have a badge system, do we still need visitor logs?

Yes, if the badge system does not capture the visitor-specific fields you need (host, purpose, ID check, temporary badge issuance). Many teams use both: a visitor management record plus badge event logs for corroboration. (NIST SP 800-53 Rev. 5)

How do we handle colocations where the data center operator controls the front desk?

Put visitor access logging requirements into the contract or security addendum, and establish an operational process to obtain logs upon request. Keep evidence of requests and received logs as part of your PE-8 record set. (NIST SP 800-53 Rev. 5)

Can we keep paper logs, or do we need an electronic system?

Paper can pass if it is complete, legible, protected from alteration, and retrievable. Electronic systems usually reduce missing fields and simplify retention and retrieval, but the requirement is about maintaining records, not a specific tool. (NIST SP 800-53 Rev. 5)

Who should own PE-8: IT, Facilities, or Security?

Assign ownership to the team that runs physical access operations end-to-end, often Corporate Security or Facilities with Security oversight. IT should be a contributor where system boundary and data center access are involved. (NIST SP 800-53 Rev. 5)

What evidence do auditors ask for most often?

They ask for a defined retention period, a procedure that matches what people actually do, and sample logs that show consistent completion and retrieval. They also test whether you included all facilities where the system resides, including third-party sites. (NIST SP 800-53 Rev. 5)