Posted on Jan 2, 2020
Compliance is a key component to any cybersecurity program. However, due to the complex nature of laws and industry regulations, ensuring compliance is often very difficult for organizations. As non-compliance can result in considerable fines, organizations must be able to align their cybersecurity and compliance efforts. One way to do this is by creating a compliance monitoring plan which can be used to continually assess an organization’s overall compliance efforts. Here are key considerations to keep in mind for successful cybersecurity compliance monitoring:
Compliance monitoring refers to the process of overseeing business operations to ensure that organizations are aligned with industry and other regulatory mandates. Cybersecurity compliance monitoring begins with evaluating which regulations apply to your organization directly, as well as determining what compliance with these regulations looks like. Once you have an understanding of this, it’s important to then evaluate the compliance controls your company has in place.
The purpose of compliance monitoring is to ensure your organization is meeting various standards and regulations on an ongoing basis. It can also help identify any regulatory gaps within your cybersecurity controls and inform the changes you can make to your cybersecurity framework to better maintain adherence with applicable regulations.
The cybersecurity and data management regulations that apply to your organization directly are usually dependent on the industry that you are in. However, several regulations span multiple industries and even continents, making it likely your organization will have to take them into consideration for monitoring efforts. Some of these regulations include:
PCI DSS is a globally recognized set of guidelines that govern how organizations handle credit card information. Compliance with PCI DSS requires that organizations are able to meet the various security guidelines put in place to protect cardholder data from theft or destruction. While PCI DSS compliance does not require complex security solutions, many times, it can be difficult to manage in combination with other security measures.
Fines for non-compliance can range anywhere from $5,000 to $25,000 per month depending on the size of your organization. In the event of a breach, you can be fined up to $500,000, which is why it is essential that you are able to align your compliance and security efforts.
Sarbanes-Oxley is a U.S. law that was passed to create a set of internal checks and balances for organizations to use in order to certify the accuracy of their financial information. While the majority of the law deals with financial governance, some sections have implications for data storage and information security. With that in mind, compliance with SOX requires that organizations’ cybersecurity initiatives do not directly violate the data security requirements stated in the law.
GDPR was passed to improve privacy laws in Europe, mainly by establishing a broader definition of personal data and giving individuals control over how their data is used. What makes compliance with this law difficult is the fact that it does not have a clearly defined set of rules for how companies should secure personal information. Additionally, it is important to note that any company that stores data on EU citizens is obligated to comply with this regulation. As it relates to cybersecurity, GDPR compliance is often directly tied to the security solutions you have in place. Furthermore, if an organization has a contract with a third party that includes data processing actions, they will have to be GDPR compliant as well. With fines for non-compliance costing up to €20 million, you must ensure that your own and your partners’
security efforts do not violate the conditions stated in the law.
After you have identified the regulations your organization must adhere to, the next step in assessing your organization’s overall compliance is to conduct an internal cybersecurity audit. The goal of the audit is to evaluate your organization’s current IT security governance structure with regard to relevant regulations. This is done by measuring your current security programs’ adherence to the cybersecurity regulations identified by The Federal Information Security Management Act (FISMA). Some areas your program will be tested on include:
Risk management covers how well your company identifies and manages the risks associated with regulatory compliance. Different aspects of your security plan such as how you communicate risk and the processes you have in place to ensure risk assessments are completed will be assessed.
Configuration management is the process of identifying, evaluating, and controlling any changes made to your cybersecurity practices. The evaluation will test your organization’s configurations and standard configuration settings for information systems against a predetermined baseline. The goal is to have an established audit system in place that continually monitors your compliance with established configurations.
This is an evaluation of the IT training you have in place. Your workforce will have to take an assessment focused on identifying gaps in IT security needs.
While it is only required that you conduct a cybersecurity audit once a year, FISMA recommends that you continually monitor all controls. This will help ensure compliance through the timely remediation of any gaps you find in your controls. Additionally, it is recommended that you regularly document your ongoing evaluation of security controls, as this can be used in future audits.
Once an audit is complete, you can then begin creating a compliance monitoring plan. When creating a compliance monitoring plan, you should aim to address all the risks identified in the audit stage, however, risks that pose the greatest threat to your organization should be prioritized. Once you have identified priority risks to monitor, you then need to decide how you are going to implement the monitoring program. When assigning monitoring roles, it is recommended that you map the required expertise against your employees’ skill sets, as to not waste any resources. Additionally, risk monitoring activities should be combined if applicable.
The output of your monitoring activity will be dependent on the level and frequency required by relevant regulatory boards. With that in mind, it is very important to always keep regulatory boards informed of any failings identified, as well as the efforts you take to improve any gaps you may find.
The ever-changing nature of laws and regulations can make ensuring regulatory compliance very difficult for organizations. While implementing a compliance monitoring plan can help considerably, it’s important to recognize that these will not fully protect you from regulatory fines. With that in mind, SecurityScorecard’s compliance solutions are designed to continuously monitor your organization’s adherence to current security mandates. Partnering with SecurityScorecard will allow you confidently demonstrate compliance, as we provide you with the tools you need to quickly identify and remediate any vendor or partner security risks that may signal policy violations. As laws continue to evolve, having the tools in place to ensure compliance has become a necessity for organizations. For this reason, you must shape your security culture around regulatory compliance, as many times this translates to the success of an organization.
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