How to Build a Compliance ProgramPublished April 2, 2019 by Karen Walsh • 4 min read
As data breach threats increase, governments and industry standards organizations seek to force organizations into maintaining better data security controls. Thus, creating an effective compliance program has become a business operations imperative rather than a series of “best practices.”
How to Build an Effective Compliance Program
Why Companies Need to Establish a Compliance Officer and Compliance Team
The compliance officer is the captain of the compliance program. She reviews the relevant laws and industry standards on a continuous basis to ensure that you maintain the appropriate controls.
However, the company also needs to create a team of internal stakeholders including the Board of Directors and c-suite. To ensure appropriate program oversight, the company must ensure that the primary decision-makers understand and review all compliance efforts.
Why Creating a Risk Management Program Fosters Compliance
Risk management acts as the foundation of a mature compliance program. Organizations need to engage in the risk identification, assessment, analysis, and tolerance process to appropriately protect themselves from the fines and penalties associated with compliance violations, such as regulatory sentencing guidelines.
If an organization chooses to accept a risk, it must prove that it has created mitigation strategies, such as internal controls, to reduce risk.
Why an Organization Needs to Adopt Written Policies, Procedures, and Processes
Written policies, procedures, and processes provide documentation proving the organization’s governance. They establish the internal controls that the organization’s stakeholders use to mitigate risks.
These controls become the playbook for guiding the rest of the program. Therefore, the company needs to make sure that all stakeholders not only engage in the process but understand all the elements necessary to maintain the controls.
Why A Compliance Program Needs an Audit Program
In cybersecurity, the motto is “trust but verify.” Establishing an audit program, with both internal and external auditors, provider-independent assurance over compliance or alerts the organization to compliance issues. As part of the audit program, the organization needs to use its written policies, procedures, and processes to define the audit scope as well as the documentation needed to show governance.
How to Create a Continuous Monitoring Process
Cybercriminals don’t stop trying to gain unauthorized access to networks, systems, and software. In order to maintain compliance with internal controls, the organization needs to continuously monitor the evolving threats associated with these new threat vectors.
How to Use Continuous Monitoring to Create a Response Program
Compliance requires continuous control monitoring and response. An organization cannot simply know that new risks exist. It must respond to them so that it can mitigate them as fast as possible. Continuous monitoring enables the risk mitigation process by easing response.
Why Organizations Need to Document Their Continuous Monitoring
Although a company may establish a continuous monitoring and response program, they also need to document the processes to provide assurance to their auditor. To do this, it needs to make sure that it provides documentation proving its actions.
Using the Elements of an Effective Compliance Program for Stronger Cybersecurity
Although corporate compliance establishes guidelines for maintaining data integrity, confidentiality, and availability, it cannot be used as the primary cybersecurity program.
Organizations starting with compliance often find themselves cross-referencing an ever-increasing number of standards and regulations. As governments and industry organizations seek to protect the public from the damaging effects of data breaches, compliance becomes a spider’s web of controls that feel overwhelming.
Moreover, these regulations and standards remain strangled by bureaucratic processes that leave them unable to keep up with the continuously evolving nature of cybersecurity.
How to Build a Compliance Program Based on Security First
Taking a security-first approach to cybersecurity can ease compliance and cybersecurity burdens. Increasingly, compliance focuses on keeping data protected from cyber criminals rather than simply ensuring specific controls. Even if control is in place, a new control may be necessary – one not on the checklists.
Continuously Mitigate Risks
While the compliance program seeks to document and establish procedures for mitigating risks, focusing solely on required controls may not keep data secure. Therefore, risk mitigation and monitoring control effectiveness become more important than simply checking boxes on audit lists. Organizations need to start with their risk mitigation strategies and continuously review them.
Engage in Continuous Compliance Training
Staff training needs to be more than simply multiple-choice questions at the end of a video or lecture. Employees, including the c-suite and Board of Directors, need to engage in cybersecurity education. To understand security risks such as phishing and spear-phishing, employees need hands-on education that provides them with real-life examples and makes them respond meaningfully.
Create Standards of Conduct
Creating a code of conduct governing password hygiene and public WiFi use can be the difference between data security and data breach. For example, most data breaches arise from weak passwords. Employees using common passwords such as 123456 or Summer2018 can place networks, systems, and software at risk. Therefore, creating standards of conduct over these employee actions can be effective.
Ensure Consistent Discipline
Establishing a code of conduct does no good if the company does not reinforce it with discipline. Password hygiene, for example, needs to be both established and enforced. The same is true for email hygiene. If organizations set policies but failure to follow them have no repercussions, then the organization places itself at risk.
How ZenGRC Enables Two-Way Communication for Compliance
Compliance programs require communication between the internal and external stakeholders and an audit system that enables this.
ZenGRC offers workflow tagging so that you can delegate compliance tasks and monitor their progress and completion. Moreover, it allows you to prioritize tasks so that your team members know how to plan their activities.
ZenGRC’s workflow management capabilities include a centralized dashboard that continuously documents your control effectiveness making compliance documentation easier.
Additionally, it helps you create an audit trail by documenting and remediation activities to support your responses to auditor questions.
Using ZenGRC’s single source of information platform can speed up internal and external stakeholder communications and provide all documentation necessary thus reducing external auditor follow up requests.
For more information on how ZenGRC’s audit management workflows can streamline your process, contact us for a demo.