AI Control Library / CF-04: Auditability & Evidence
Designation: Supplemental | Control types represented: Operational and Technical
Control requirement
Capture and review relevant physical access events for facilities and equipment supporting AI services, linking access to authorized identities, work purposes and incident investigation needs while protecting personal information.
Why this matters
Logical controls do not explain who physically reached servers, consoles or removable media. Physical records can support investigation, but badge events alone do not prove which person handled a particular system.
How the control types work together
Operational controls define scope, authority and the actions required when conditions are not met. Technical controls produce evidence or enforce the relevant boundaries. Both must apply to the same deployment and operating conditions.
When it applies
Organizational facilities, AI infrastructure, model or data storage and relevant provider-hosted environments through appropriate assurance evidence.
Define the assessed boundary, dependencies and evidence limitations. Tailor depth and review frequency to potential impact, and document why a particular safeguard or exclusion is appropriate to the actual deployment.
Ownership
Facilities security owns access records; infrastructure and security teams define relevant assets, review needs and response coordination.
Implementation guidance
- Identify AI-supporting assets and areas needing access evidence, including maintenance, visitor and removable-media handling paths.
- Define relevant entry, denial, escort and administrative-change events with time references, authorized identities and work references where appropriate.
- Protect record access and retention, correlating physical events with maintenance and logical activity only for authorized purposes.
- Test denied access, emergency entry and provider evidence availability, investigating gaps without treating a missing badge event as proof that no access occurred.
How to verify it
Use representative records and authorized controlled tests. Identify the relevant version, operating conditions and expected result before testing, and retain enough evidence to support the conclusion.
| Test | Expected result |
|---|---|
| Trace a sampled maintenance activity | Access authorization and relevant physical records align with the work performed. |
| Review a denied or emergency entry | Required recording and escalation occur without defeating life-safety arrangements. |
| Investigate a provider-hosted asset | Appropriate scoped assurance or an explicit evidence limitation supports the conclusion. |
Record a finding when required results cannot be demonstrated or practice differs materially from the approved conditions. Missing evidence limits the conclusion; it should not be treated as a successful test.
Evidence to retain
- Physical access scope and responsibilities
- Access and visitor records
- Maintenance and incident correlations
- Review and access-control tests
Protect evidence according to its sensitivity, access needs and retention rules. Avoid unnecessary copies of personal information, secrets or confidential material, while preserving the records needed for authorized review.
If the control fails
Escalate unexplained access or material evidence gaps to facilities and security response. Secure affected assets through approved procedures and preserve evidence while maintaining emergency and life-safety requirements.
Example in practice
Hypothetical example: A model server reports an unexpected restart during overnight maintenance. Facilities records and the approved work order provide investigation context, while console and system logs establish what occurred on the host.
Related controls
- CF04-014: AI Decision Record & Traceability
- CF04-015: AI System Clock Synchronization
- CF03-009: AI Supply Chain Compliance Assessment
Framework mappings
- CSA AICM (LOG-12)
- NIST AI RMF (MANAGE 4.1)
Review and maintenance
Review at the interval approved by the control owner and after relevant changes, incidents or failed assessments. Update affected procedures and configuration, address evidence gaps and verify corrective action before closing findings.
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