An effective compliance program has a critical impact on an organization’s ability to operate with integrity, consistency, quality and maintain trust and credibility with organizational stakeholders including customers, partners, vendors, employees, and investors. It is also an important component of an effective risk management program.
When I was leading IT security and compliance engagements at a Big 4 firm, I helped many companies in the technology, fintech and financial services space design internal control environments to safeguard their information systems and data. I also conducted assessments of my clients’ internal control environments, to help them strengthen and streamline their risk posture. My clients asked me all kinds of questions that really revolved around one theme: At the end of the day, how do I make sure that what we’re doing as an organization is actually effective in mitigating the risks that matter?
In this article, I will discuss four key characteristics of an effective compliance program, why each one is important, and how these elements can be achieved. If your compliance program has these elements, you can be confident that you’re on the right track in mitigating the risks that matter.
This topic is timely, given how quickly the current cyber risk landscape is evolving. For instance, due to increasing connectivity between organizations and reliance on third-party vendors, third-party data breaches accounted for more than half of all data breaches in the first half of 2019. Meanwhile, newer data privacy laws like the GDPR and CCPA are difficult and costly to comply with, and they use steep fines and penalties to sanction non-compliant organizations.
The four signs of a mature and effective compliance program
An effective compliance program should align to a broader risk management strategy. Risk assessments should be performed at least annually, and more frequently for higher risk areas. The ultimate goal of an effective risk management strategy is maintaining a risk environment that is within an acceptable risk tolerance level for the organization. To accomplish this, an organization must identify their risks, define risk tolerances (risk levels that are acceptable) and then design controls in a manner that effectively addresses the risks.
Below, are some questions to consider in evaluating the quality of your compliance program:
- Does your risk strategy include a comprehensive view that considers both existing and emerging risks?
- How are risk tolerance levels defined?
- Are key stakeholders involved in setting risk tolerance levels?
- How effectively does the design of the control mitigate the risk?
- Is there a control redundancy strategy, in case a critical control fails there is another control in place to address the risk?
- Are your controls independently validated to confirm their effectiveness?
By using innovative compliance management software like Hyperproof, it is easy to ensure your control environment effectively aligns to your overall risk management strategy. As new risks are identified, Hyperproof provides visibility to see if existing controls are already in place to address the risks, or if new controls are needed.
Hyperproof also enables you to see the gaps between your existing control set, and what would be needed to adopt leading cybersecurity frameworks like NIST SP 800 series or the ISO 27000 series.
The design of the control impacts how effective the control is. Additionally, consistency in performing the control process is an important factor in having an effective compliance program. In this context, consistency means that your controls are operating at the specific time interval, and in the same manner, as they were designed to. To ensure that your controls are operating consistently, you’ll need to have sufficient oversight and visibility into the performance of control processes.
For instance, deploying patches is an important component of vulnerability management. If patches are not consistently deployed, at the time that they become available, your systems may be left exposed to vulnerabilities. As such, it is important to have visibility into control processes that were not performed timely so that you can quickly resolve issues. This is particularly important for high risk areas like vulnerability management.
Continuous compliance helps you manage risk more effectively. With continuous compliance, control processes are consistently performed, and evidence from the control processes are evaluated and actioned accordingly. If you are evaluating control processes on a continuous basis, you have an opportunity to refine your risk management strategies in real-time.
For example, if you are using a SIEM solution that does not have both logging and monitoring alerts turned on, it could potentially prevent notifications of attack indicators. The lack of notifications and alerts reduces the ability to make timely adjustments to network controls. This scenario could have been prevented with continuous compliance. Specifically, continuous compliance would have discovered, in a timely manner, that logging and monitoring alerts were not turned on.
I have found that many organizations delay collecting and evaluating evidence, until right before they need to submit that evidence to their auditor or security assessor. By delaying evidence collection and evaluation, organizations miss the opportunity to adjust and adapt their risk environment. If evidence is only collected and evaluated before an audit or assessment, the control process becomes a lagging indicator with little room for adjustment.
Technology can make a big impact, when adopting continuous compliance. For instance, you can use a compliance management solution like Hyperproof to keep all your evidence organized (e.g. linked to the right control/requirement) and use automated reminders to alert control operators to review controls on a regular basis and submit evidence on time.
Additionally, Hyperproof has a feature called ‘Freshness’. You can set a ‘Freshness’ policy to remind yourself and your team to review controls on a cadence and ensure that all controls are appropriately evaluated throughout the year. This helps ensure that no one will forget any of their compliance tasks, which ultimately makes your entire organization more secure and resilient.
Compliance operations software like Hyperproof can also eliminate duplicative work (e.g., having to collect the same piece of evidence five times to meet five different compliance frameworks) by helping users identify common controls and common evidence across compliance frameworks.
3. Governance and oversight
Governance and oversight is a key component of an effective compliance program. At the highest level, senior risk leaders need the right information to effectively monitor the effectiveness of the compliance program and make adjustments as needed. Adjustments may include areas such as incorporating new controls to address emerging risks, redesigning weak control processes to make them stronger, or developing new training to improve security awareness among employees.
At a tactical level, a compliance manager needs another set of information to understand how prepared they are for upcoming audits or assessments, quickly see which controls they need to act on, and ensure that control processes are performed correctly and on time. They should also have visibility into the issues that need immediate attention or escalation.
Getting sufficient visibility into the effectiveness of a compliance program can be a difficult challenge for many organizations. This is especially an issue for organizations that manage their compliance efforts in a variety of different tools such as elaborate spreadsheets, email inboxes, and file storage systems like Box, Dropbox or OneDrive.
However, when organizations start to manage all of their compliance projects in one single place, it becomes a lot easier to gather the right set of metrics for decision making.
For instance, Hyperproof gives organizations a central location where all of their compliance requirements, controls, and proof can be stored and managed so that compliance managers and external auditors can see everything in one streamlined system. It allows compliance managers to quickly answer questions such as, “Where are we with our evidence collection?”, “What controls need to be updated or redesigned?”, and “What do the examiners need to see?”.
Hyperproof also helps senior risk leaders understand how well their current compliance program stacks up against several best-in-class cybersecurity and data privacy frameworks.
Efficiency has to do with how well an organization is managing its resources, including time, employees, and budget. Being efficient means that your team is able to achieve quality, consistency and effective oversight with an optimal amount of resources. With limited resources, it is particularly important to focus your compliance efforts on the more critical areas.
Making compliance activities more efficient is key to reducing the cost of compliance, which always seems to be going up due to factors such as the rise of data privacy regulations, the growing awareness of third-party risks, a rise in vendor-to-vendor audits, and the shortage of cybersecurity talent.
In terms of operational efficiency, technology will be incredibly important. In fact, Hyperproof was built to help organizations become far more efficient in compliance management. Not only does Hyperproof serve as a single source of truth for all of your compliance activities, it can reduce the administrative work around collecting evidence and managing tasks (e.g., updating controls) by half.
Hyperproof comes with a set of features that enable greater efficiency, including:
- Crosswalk: Helps users identify the overlapping requirements and controls between various compliance frameworks
- Integrations with file storage systems where evidence is stored and productivity tools
- Collaboration capabilities between compliance managers, control operators, senior leaders, and external auditors
- Automated reminders to review controls and evidence
- Smart folders and labels to efficiently link a batch of evidence to controls
Related content: The Complete Guide to Continuous Compliance
With compliance, it’s important to understand what it actually takes to become compliant and maintain that position. I have discussed four key elements of an effective compliance program. Organizational focus should be placed on quality, consistency, effective oversight, and efficiency. Deliberate attention to each area will ultimately lead to a well functioning compliance program.
Additionally, effective risk management is about being proactive instead of reactive. That includes quickly responding to the alerts indicating weaknesses of critical systems, and consistently evaluating/updating the control processes established for prevention/mitigation of potential security incidents.
When compliance costs are rising quickly for organizations of all industries, sizes and types, prioritizing the right areas — with a solution that is agile, intuitive and cost effective — becomes essential.
The post The Four Signs of an Effective Compliance Program: Quality, Consistency, Oversight and Efficiency appeared first on Hyperproof.
*** This is a Security Bloggers Network syndicated blog from Hyperproof authored by Petrina Youhan. Read the original post at: https://hyperproof.io/resource/four-signs-of-an-effective-compliance-program/