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An OSC processes data in its owned data center.

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An OSC processes data in its owned data center. The data center includes a very early smoke detection apparatus (VESDA). The apparatus only captures log information from its sensors around the data center. It is not intended, nor capable of, processing CUI. The VESDA is on a separate VLAN and is in a separate locked room in the data center.

Should the assessor agree that the VESDA is out-of-scope?

A.

Yes. The VESDA is physically and logically separated from the other data center equipment, and it is not intended nor capable of processing CUI.

B.

No. Even though the sensors are out-of-scope, the VESDA could provide access to the outside network if sensors were misused, and CUI could be exfiltrated.

C.

No. Even though the VESDA controller is in a locked room and on a separate VLAN, the VESDA is an essential security function as an early warning system.

D.

Yes. The VESDA serves a non-data processing purpose and is only connected to sensors. Sensors are out-of-scope, so the VESDA is out-of-scope.

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