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Best Practices for Building a Cybersecurity Compliance Plan

06/10/2020

Cyber threats and data breaches aren’t just issues for your IT department. The impact can have a rippling effect across your entire organization – from your legal counsel, entangled in litigation, to frontline workers, who can’t utilize the tools needed to complete their jobs. Every employee in your company must play a part in managing cyber risks, in addition to staying compliant with ever-evolving privacy and security regulations.

These requirements and regulations vary by location and industry, making it tough for businesses to maintain their compliance. New privacy mandates, including the Data Security and Breach Notification Act and the California Consumer Privacy Act, can make it difficult to wrap your head around the numerous changes.

Organizations that are not compliant are feeling the burn. For instance, if a business defies several of the GDPR provisions, it can be fined 4% of its annual revenue or $24 million, whichever number is larger. How much could non-compliance cost your firm?

Let’s take a closer look at the importance of a cybersecurity compliance plan and how your organization can leverage these best practices to ensure you maintain compliance at all costs.

What is cybersecurity compliance?

With regard to cybersecurity, maintaining compliance requires risk-based controls that ensure the confidentiality, accessibility, and security of information that is stored, transferred or processed. It is important to note that the cybersecurity standards and regulations that organizations adhere to vary by industry, so there is no one-size-fits-all approach to compliance management. As a result, building comprehensive compliance programs requires ongoing risk management so that all potential threats are identified and remediated.

Why is a cybersecurity compliance plan important?

Customers need to know that compliance and security are top of mind for any organization they choose to work with. For obvious reasons, they want to be assured their sensitive information is protected and valued as an asset. But without a cybersecurity compliance plan, it is hard to ensure customer confidence that you are effectively protecting their data.

A cybersecurity compliance plan ensures your organization prioritizes how to understand, mitigate, respond, and recover from any risks or threats associated with a data breach. Everyone in the company is responsible for managing risks, and implementing a cybersecurity compliance plan can help you stay ahead of cybercriminals and avoid government fines from non-compliance.

What are the different requirements for cybersecurity compliance?

While a cybersecurity compliance plan is necessary to protect against inherent risks, it’s also to maintain governmental compliance. Here are some of the top government requirements to consider for cybersecurity compliance around the world:

HIPAA

The Health Insurance Portability and Accountability Act (HIPAA) was passed in 1996 to secure patient privacy and confidentiality, as well as define a uniform standard for transferring health information among healthcare providers, health plans, and clearinghouses. These rules detail how the healthcare industry is required to address any technical/ non-technical protection to effectively secure patients’ individual health information.

NYDFS Cybersecurity Regulation

The New York Department of Financial Services (NYDFS) released the Cybersecurity Regulation (23 NYCRR 500) in 2017 to outline the requirements for implementing and developing an effective cybersecurity program. This regulation requires organizations to assess their cybersecurity risks and consequently develop plans to address any vulnerabilities associated with their organization. This involved performing risk assessments, documenting security policies, and designating a Chief Information Officer (CIO) to oversee and manage cybersecurity for the company.

GDPR

General Data Protection Regulation (GDPR) was enacted by the EU in 2018 as a set of data privacy regulations to unionize data privacy laws across Europe. Any organization that works with a European company is required to follow the standards set within the GDPR, even if they are located in another part of the world. The goal of GDPR is to allow individuals more control over their personal and sensitive information, as well as simplify regulations for international businesses. The principles of GDPR include:

  • Lawfulness

  • Fairness and transparency

  • Purpose limitation

  • Data minimization

  • Accuracy

  • Storage limitation

  • Integrity and confidentiality (Security)

  • Accountability

FERPA

Family Educational Rights and Privacy Act (FERPA) is a federal law that gives parents and eligible students the right to inspect and review educational records, as well as request school records if they feel the record was inaccurate or misleading.

CCPA

California Consumer Privacy Act (CCPA) was created in 2018 to protect the privacy rights and protections of consumers. Similar to Europe’s GDPR, CCPA is required in any organization that makes at least $25 million in annual revenue, gathers data on more than 50,000 users, or makes more than half of the companies money by collecting user data. The CCPA defines personal data from anything from a person’s real name, address, and email to their account name, passport, or even their IP address.

CMMC

Cybersecurity Maturity Model Certification (CMMC) was developed by the Department of Defense and applies to any organization that handles Controlled Unclassified Information (CUI). As of 2020, any department of defense contractors will need to perform a third-party audit to prove that they are meeting the security requirements necessary to attain and maintain CUI.

While these cybersecurity compliance requirements may not all pertain to your organization, it’s important to keep them in mind as you build your compliance plan to ensure all jurisdictions are followed.

6 steps to build a cybersecurity compliance plan

It’s critical to use best practices for building a cybersecurity compliance plan. Here are some effective ways we believe will help you establish a plan that is effective, compliant, and most importantly, secure.

1. Ensure your IT department is educated on compliance

Your firm’s IT department is typically the first line of defense when it comes to cyber-attacks. Their knowledge and programs may have been cultivated from previous attacks or general best practices from the industry. However, their cybersecurity programs may not be implementing compliance best practices. This is because they may not be as familiar as your compliance department is where regulatory compliance is concerned.

It is imperative that you educate and inform your IT team about new regulations that can affect the entire business. For the cybersecurity programs to be current, your IT department must thoroughly understand the technical constraints of their programs and whether or not new advancements need to be made. When your compliance and IT departments are working together cohesively, the result is a robust cybersecurity ecosystem that thoroughly protects sensitive data.

2. Create a thorough risk assessment plan

Risk assessment programs are conducted across every department in a firm, including compliance. Risk mitigation plans help to pinpoint potential weaknesses in your business and help the organization take proactive measures to prevent them from materializing.

Identifying cybersecurity vulnerabilities in conjunction with the IT department will dictate where compliance needs to be strengthened. Sensitive data such as client information, banking data, and technology infrastructure needs to be kept safe from external forces and accounted for in your risk management plan. A potential data breach can bring compliance penalties from the SEC or other regulatory organizations.

In order to create a comprehensive risk assessment plan, you must:

  • Identify all of your firm’s information systems, networks, and information that they access.
  • Assess the risk level of each type of data and determine where high-risk data is stored, transmitted, and collected.
  • Analyze the risk by using the risk = (likelihood of breach x impact)/cost formula.
  • Determine to transfer, refuse, accept, or mitigate the risk.

3. Set security controls and policies

Once you have identified which risks pose the greatest threat to your organization. It is important to establish security controls to help manage those risks. Some examples of security controls include:

  • Network firewalls
  • Data encryption
  • Incident response plan
  • Patch management schedule
  • Network access control

In addition, setting policies across your organization will help document the compliance activities and controls of your devices. By setting security control and policies, your organization can build the foundation for successful internal and external audits in the future.

4. Update your cybersecurity policies and procedures

Creating an efficient risk assessment plan enables your organization’s compliance team to adjust specific policies and procedures or to come up with entirely new ones. Numerous regulatory bodies want the compliance department to provide them with details as to how the firm’s policies and procedures perform contingently with their installed cybersecurity programs.

5. Do not operate in a silo

Cybersecurity and compliance is everybody’s role. Every employee, in each department, should thoroughly understand the role they play in protecting sensitive information. Your firm should conduct routine cybersecurity awareness training to ensure everyone knows how to properly respond to a potential threat.

6. Constantly monitor and respond to threats

Compliance requirements focus on how cybersecurity threats evolve. Hackers are constantly working to find new innovations on how to obtain sensitive data. However, they often prefer to rework existing strategies rather than find new vulnerabilities. For instance, cybercriminals may combine two different kinds of known ransomware to create an entirely new program.

Continuous monitoring can help your organization respond to threats before they become an issue. Without responding to a known vulnerability, your business can be fined for negligence arising from a lack of security.

How SecurityScorecard can help

SecurityScorecard continuously monitors internal and external adherence to established policies and practices. By leveraging SecurityScorecard, your organization can diligently manage ecosystem compliance by using the platform to instantly capture, report, and remediate real-time vendor and partner security risks that signal potential policy violations.

As the cybersecurity threat landscape continues to change, having the right tools to guarantee compliance has become necessary for organizations across a wide spectrum of industries. This is why it is imperative to adhere to best practices when building your cybersecurity compliance. The good news is, SecurityScorecard is here to help. Request your free instant scorecard today to discover the security posture of your organization. Understanding the cybersecurity of your business will help you effectively design a cybersecurity compliance plan that will last for years to come.


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