Best Practices for Compliance Monitoring in Cybersecurity

By Jeff Aldorisio

Posted on Jan 2, 2020

Compliance is a key component to any cybersecurity program, however, due to the complex nature of laws and regulations, ensuring compliance is often very difficult for organizations. As non-compliance often results in considerable fines, organizations must be able to align their cybersecurity and compliance efforts. One way to do this is through creating a compliance monitoring plan which can be used to continually assess an organization’s overall compliance efforts. 

This 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. This will help you identify any regulatory gaps within your cybersecurity controls, as well as inform the changes you make to your cybersecurity framework to ensure adherence with regulations. 

Determining which regulations apply to you

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:

Payment Card Industry (PCI) Data Security Standards (DSS)

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 $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 (SOX) 

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.   

General Data Protection Regulation (GDPR)

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. 

Conducting a cybersecurity audit

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 regards 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

This 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

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.

Security and privacy training

This is an evaluation of the IT trainings 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. 

Creating a compliance monitoring plan 

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 which 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 upon any gaps you may find. 

Final thoughts

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 with 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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