Preparing for your audit and certification

Whether you’re looking ahead to securing a security certification, or in the surveillance/maintenance audit cycle, your people, process, and technology will all play an important role in guaranteeing your success. It’s not just important to do it right the first time. It’s important to do it right every time.

CERTIFY ME!

We have previously spoken of the impact to businesses and security teams of SolarWinds, along with increasing ransomware and other cyberattacks. The demand is increasing to demonstrate an implemented security posture to make it through the sales process. Whether it’s SOC 2 Certification, ISO Certification, or CMMC Certification for DIB’s, government and corporations are both being held accountable and calling for greater accountability in their supply chain. This is, hopefully, good for consumers, good for society, good for humanity even!

As the demand for “certified” compliance increases, the cybersecurity industry has responded with new tools, automation, and “virtual CISO” services, all designed to simplify and expedite the readiness and certification process, because, of course, as a customer, you need certification, and you need it NOW!

BEYOND THE CHECKBOX

If you are about to launch headlong into a SOC 2 or another type of compliance certification, read this first! If you are planning to use a spreadsheet… Don’t. If you are looking for a SaaS product, tool, MSP, or combination of both, keep reading! It is important to know what is ahead and find a tool that enables you to fulfill all of your tasks and objectives and/or guide your MSP partners to make your investment and cost-effective and successful as possible. We think of it in three stages:

  1. Readiness: Scope of the certification (only do what you need to do); what is already in place; what do we need to build? (This is the checklist)
  2. Continuous Monitoring: Implementation, corrective action, validation; review, recycle, add, rinse. (This is beyond the checkbox)
  3. Risk in Action: Risk Register, established risk metrics, empirical data, and actionable activity to make the organization stronger, faster, better… (This is where you want to be)
I CHECKED ALL THE BOXES!

The impression of ‘getting certified’ after 14, 30 90 days (SOC 2 Type 1, maybe…) 6-12 months (SOC 2 Type 2/ISO 27001, CMMC), is misleading at best, and generally speaking, creates a “false” sense of security. In reality, passing the certification audit is just the beginning of an ongoing compliance cycle that requires ongoing maintenance, or, in other words, a risk management program. If you are not thinking beyond the checkbox, you are underestimating the task at hand.

POLICY CREATES LIABILITY

Step one: all certifications require developed policies. Once written, that policy must be implemented. There is no going back! Failure to implement the standards and procedures outlined by your policies and accompanying procedural documents creates liability, not just audit penalties. There are many templates and offerings to help craft policies. These do largely serve as a good starting point, but “buyer-beware” unless you understand what is in your policy–can you validate that your policy statements are actionable within your organization?–then you are potentially opening your company up to a world of pain!

COMPLIANCE & RISK MANAGEMENT

The jolly old Oxford English Dictionary describes compliance as “the act of obeying a rule, order or request”. OK, that mostly works, with one rather important addendum. “Ongoing”… Security OR Privacy compliance are not point-in-time activities, rather, they are any point-in-time activities. We call this continuous monitoring (Step two).  Immediately, this is why compliance is not sustainable in a spreadsheet. It’s simply too hard to keep up with ongoing activity, issues, and changes across the business, product, and in-scope technology. Automation is the key to effectively reviewing or monitoring compliance. Tools like CyberOne can automate evidence collection through API integrations or “manually” through project management notifications and alerts that go out to evidence owners. However, if automation can help sustain existing compliance, the business of managing gaps, risk management is the next level. Now, we are in the realm of risk management. Managing threats, vulnerabilities, issues that arise, events (heaven forbid), and business continuity, all of which are compliance requirements, can only be done through effective, empirical risk management. Risk management takes you through (Steps three, four, five, etc…). Compliance tells you what you are and are not doing, so to speak, where effective risk management, tells how to maintain, scale, and do it better. On the right tool (ahem!), this can refer to both operational and enterprise risk. With the right risk data, measured in real-time, against established requirements and objectives, your company will become more efficient and work smarter across security and general operations. As such, compliance is only as valuable as the risk management that it informs, and as a stand-alone activity, it is not sustainable.

CERTIFICATION TOOLS: CHECK THESE BOXES

As you launch into your certification tool search, here’s a quick summary of the capabilities you really need to be successful:

  1. Policy Management: Can you write, review, update and communicate policies and connect them to your internal controls and regulatory requirements?
  2. Asset Management: Can you attach controls to specific assets and monitor those assets in your tool?
  3. Control Management: Can you work with multiple regulations and consolidate your internal controls to meet multiple requirements?
  4. Evidence Collection: Can you automate evidence collection and use one piece of evidence to meet many controls?
  5. Control tests: can you validate evidence and create reports that demonstrate validation by control and assets?
  6. Issue Management: Can you create findings from findings, as well as view, prioritize and mitigate findings (corrective actions, issues) form all areas of the business (compliance review, vulnerability scans, vendor review, internal audit, etc.)
  7. Risk Management: Can you define risk metrics and objectives, and cascade risk > threat > issue > incident > controls > assets to understand for a comprehensive understanding of your risk and compliance status and environment?
  8. Data application: Can you take that data and apply it to organizational strategy?

Once you implement the above, well, remember where we said you wanna be? Faster, stronger, better… You are here!

CyberOne is cloud-based GRC automation. We bring governance, compliance, and risk together with purpose. If you are ready to go beyond the checkbox, reach out to CyberOne and we will tell you more.

See what our clients say about CyberOne here:

 

 

 

Credits:

Harvard Business Review: https://hbr.org/2018/03/why-compliance-programs-fail

The Compliance and Ethics Blog:

Check Your Use of “Check the Box”

 

 

 

A security message from HRH the Queen on Independence Day

 

All freedom comes at a price. Good security helps maintain freedom by protecting your company from exposure to an increasingly threatening landscape. Help keep we pesky Brits and other “ne-er-do-wells” from invading (again) your systems and networks this coming Independence Day weekend.

 

It’s all about getting the Crown Jewels without paying a Queen’s ransom!

 
As you launch your search, here’s a quick, totally unbiased, summary of the capabilities you should require from your tool:
  1. Policy Management: Can you write, review, update and communicate policies and connect them to your internal controls and regulatory requirements?
  2. Asset Management: Can you attach controls to specific assets and monitor those assets in your tool?
  3. Control Management: Can you work with multiple regulations and consolidate your internal controls to meet multiple requirements?
  4. Evidence Collection: Can you automate evidence collection and use one piece of evidence to meet many controls?
  5. Control tests: can you validate evidence and create reports that demonstrate validation by control and assets?
  6. Issue Management: Can you create findings from findings, as well as view, prioritize and mitigate findings (corrective actions, issues) form all areas of the business (compliance review, vulnerability scans, vendor review, internal audit, etc.)
  7. Risk Management: Can you define risk metrics and objectives, and cascade risk > threat > issue > incident > controls > assets to understand for a comprehensive understanding of your risk and compliance status and environment?
  8. Data application: Can you take that data and apply it to organizational strategy?

 

CyberOne is cloud-based GRC automation. We bring governance, compliance, and risk together with purpose. If you are ready to go beyond the checkbox, reach out to CyberOne and we will tell you more.

See what HRH and our clients say about CyberOne here:

    

Completely unbiased advice for how to select the right GRC Tool

 

Do you need Compliance Certification? Does your soul begin to resemble a spreadsheet? Do you need a GRC tool? Do you think you only need a compliance tool? Do you know the difference?

It’s all about getting the Crown Jewels without paying a Queen’s ransom!

As you launch your search, here’s a quick, totally unbiased, summary of the capabilities you should require from your tool:
  1. Policy Management: Can you write, review, update and communicate policies and connect them to your internal controls and regulatory requirements?
  2. Asset Management: Can you attach controls to specific assets and monitor those assets in your tool?
  3. Control Management: Can you work with multiple regulations and consolidate your internal controls to meet multiple requirements?
  4. Evidence Collection: Can you automate evidence collection and use one piece of evidence to meet many controls?
  5. Control tests: can you validate evidence and create reports that demonstrate validation by control and assets?
  6. Issue Management: Can you create findings from findings, as well as view, prioritize and mitigate findings (corrective actions, issues) form all areas of the business (compliance review, vulnerability scans, vendor review, internal audit, etc.)
  7. Risk Management: Can you define risk metrics and objectives, and cascade risk > threat > issue > incident > controls > assets to understand for a comprehensive understanding of your risk and compliance status and environment?
  8. Data application: Can you take that data and apply it to organizational strategy?

CyberOne is cloud-based GRC automation. We bring governance, compliance, and risk together with purpose. If you are ready to go beyond the checkbox, reach out to CyberOne and we will tell you more.

See what our clients say about CyberOne here:

Compliance Certification: Step outside the checkbox

 

CERTIFY ME!

We have previously spoken of the impact to businesses and security teams of SolarWinds, along with increasing ransomware and other cyberattacks. The demand is increasing to demonstrate an implemented security posture to make it through the sales process. Whether it’s SOC 2 Certification, ISO Certification, or CMMC Certification for DIB’s, government and corporations are both being held accountable and calling for greater accountability in their supply chain. This is, hopefully, good for consumers, good for society, good for humanity even!

As the demand for “certified” compliance increases, the cybersecurity industry has responded with new tools, automation, and “virtual CISO” services, all designed to simplify and expedite the readiness and certification process, because, of course, as a customer, you need certification, and you need it NOW!

BEYOND THE CHECKBOX

If you are about to launch headlong into a SOC 2 or another type of compliance certification, read this first! If you are planning to use a spreadsheet… Don’t. If you are looking for a SaaS product, tool, MSP, or combination of both, keep reading! It is important to know what is ahead and find a tool that enables you to fulfill all of your tasks and objectives and/or guide your MSP partners to make your investment and cost-effective and successful as possible. We think of it in three stages:

  1. Readiness: Scope of the certification (only do what you need to do); what is already in place; what do we need to build? (This is the checklist)
  2. Continuous Monitoring: Implementation, corrective action, validation; review, recycle, add, rinse. (This is beyond the checkbox)
  3. Risk in Action: Risk Register, established risk metrics, empirical data, and actionable activity to make the organization stronger, faster, better… (This is where you want to be)
I CHECKED ALL THE BOXES!

The impression of ‘getting certified’ after 14, 30 90 days (SOC 2 Type 1, maybe…) 6-12 months (SOC 2 Type 2/ISO 27001, CMMC), is misleading at best, and generally speaking, creates a “false” sense of security. In reality, passing the certification audit is just the beginning of an ongoing compliance cycle that requires ongoing maintenance, or, in other words, a risk management program. If you are not thinking beyond the checkbox, you are underestimating the task at hand.

POLICY CREATES LIABILITY

Step one: all certifications require developed policies. Once written, that policy must be implemented. There is no going back! Failure to implement the standards and procedures outlined by your policies and accompanying procedural documents creates liability, not just audit penalties. There are many templates and offerings to help craft policies. These do largely serve as a good starting point, but “buyer-beware” unless you understand what is in your policy–can you validate that your policy statements are actionable within your organization?–then you are potentially opening your company up to a world of pain!

COMPLIANCE & RISK MANAGEMENT

The jolly old Oxford English Dictionary describes compliance as “the act of obeying a rule, order or request”. OK, that mostly works, with one rather important addendum. “Ongoing”… Security OR Privacy compliance are not point-in-time activities, rather, they are any point-in-time activities. We call this continuous monitoring (Step two).  Immediately, this is why compliance is not sustainable in a spreadsheet. It’s simply too hard to keep up with ongoing activity, issues, and changes across the business, product, and in-scope technology. Automation is the key to effectively reviewing or monitoring compliance. Tools like CyberOne can automate evidence collection through API integrations or “manually” through project management notifications and alerts that go out to evidence owners. However, if automation can help sustain existing compliance, the business of managing gaps, risk management is the next level. Now, we are in the realm of risk management. Managing threats, vulnerabilities, issues that arise, events (heaven forbid), and business continuity, all of which are compliance requirements, can only be done through effective, empirical risk management. Risk management takes you through (Steps three, four, five, etc…). Compliance tells you what you are and are not doing, so to speak, where effective risk management, tells how to maintain, scale, and do it better. On the right tool (ahem!), this can refer to both operational and enterprise risk. With the right risk data, measured in real-time, against established requirements and objectives, your company will become more efficient and work smarter across security and general operations. As such, compliance is only as valuable as the risk management that it informs, and as a stand-alone activity, it is not sustainable.

CERTIFICATION TOOLS: CHECK THESE BOXES

As you launch into your certification tool search, here’s a quick summary of the capabilities you really need to be successful:

  1. Policy Management: Can you write, review, update and communicate policies and connect them to your internal controls and regulatory requirements?
  2. Asset Management: Can you attach controls to specific assets and monitor those assets in your tool?
  3. Control Management: Can you work with multiple regulations and consolidate your internal controls to meet multiple requirements?
  4. Evidence Collection: Can you automate evidence collection and use one piece of evidence to meet many controls?
  5. Control tests: can you validate evidence and create reports that demonstrate validation by control and assets?
  6. Issue Management: Can you create findings from findings, as well as view, prioritize and mitigate findings (corrective actions, issues) form all areas of the business (compliance review, vulnerability scans, vendor review, internal audit, etc.)
  7. Risk Management: Can you define risk metrics and objectives, and cascade risk > threat > issue > incident > controls > assets to understand for a comprehensive understanding of your risk and compliance status and environment?
  8. Data application: Can you take that data and apply it to organizational strategy?

Once you implement the above, well, remember where we said you wanna be? Faster, stronger, better… You are here!

CyberOne is cloud-based GRC automation. We bring governance, compliance, and risk together with purpose. If you are ready to go beyond the checkbox, reach out to CyberOne and we will tell you more.

See what our clients say about CyberOne here:

 

 

 

Credits:

Harvard Business Review: https://hbr.org/2018/03/why-compliance-programs-fail

The Compliance and Ethics Blog:

Check Your Use of “Check the Box”

 

 

 

DarkSide: The Consumerization of Hacking

 

The Colonial Pipeline Co. attack brought to light well-documented susceptibilities to our aging energy infrastructure in the US. It also demonstrates the real and growing threat that cyber-crime poses to our society, as well as a growing trend in the cybercrime market, that of RaaS, Ransomware as a Service. This is the consumerization of cybercrime, where hacker collectives literally operate as a business serving clients with ready-for-use ransomware tools that can be used to deliver attacks on global companies.

For more information on the hack and its perpetrators, DarkSide, read the Krebs on Security article that takes a close look at “DarkSide” and its operations.

Hacktivists turned Capitalists

Hacker groups or collectives are nothing new. The first documented incident of hacking dates back to 1971 and is attributed to a Vietnam Vet, John Draper, who figured out a way to make free phone calls. Inevitably, hacking has come a long way since John decided he needed to make free long-distance calls, becoming very much a part of the mainstream of social lexicon, even glamorized to a large extent by hackers themselves as well as a largely uninformed Hollywood portrayal of “hacktivist” culture. Far from the Hollywood “freedom fighter” portrayal of the hacker, the blackhat industry has always largely been about making money, but in recent years has become bolder and better, while seemingly losing all ethical values.

Who is at risk?

These hacking collectives will tell you that only the largest companies that can “afford to lose a few million” are targeted. They also claim that state actor projects, or geopolitics, are off the table with the sole aim of these groups to serve as a sort of online Robin Hood – taking from the rich… Oops, seems like they forgot about giving back to the poor. The reality seems far less “ethical” and far more indiscriminate. This week, a single, albeit major, pipeline operation was interrupted. Just three months ago, a small Florida city water company was hacked. School districts and universities have been targets and, of course, most industry sectors have been and continue to be targeted, from carpet manufacturers to the big banks. All in all,  it is estimated that 2,400 U.S.-based government, healthcare facilities, and schools were victims of ransomware in 2020 alone. Pre-IPO companies who are trying to safeguard sensitive data before going public are a popular target. The reality is that these attacks have a cascading fallout that impacts our safety, our health, our economy, our taxes, our livelihoods. Who is at risk? All of us it would seem.

Consumer Beware

Yes, based on the above, corporations are largely the chosen victims of ransomware. However, if you think this makes you immune as an individual, well, think again…

This attack crossed over into the public domain, closing a major US oil and gas pipeline, leading to a widespread fallout ranging from lines at the gas stations and a shortage of fuel, rising gas prices, to fallout – thankfully minimal –  in the stock market.

Corporations that have suffered ransomware attacks are lobbying governments to provide bail-out funds to enable them to beef up security practices to help protect against future attacks. What we may never know (of course we know) is whether appropriate security measures were in place prior to these attacks? From a consumer perspective, that cost is now being passed on to you in the form of higher product prices, lack of wage increases, and of course in your taxes.  If this sounds like the great TARP bailout of 2008, where citizens effectively paid the billion-dollar bonuses of bankers, well… your hearing might be good.

As Krebs reports, experts say ransomware attacks will continue to grow in sophistication, frequency, and cost unless something is done to disrupt the ability of crooks to get paid for such crimes. Last month, a group of tech industry heavyweights lent their imprimatur to a task force that delivered an 81-page report to the Biden administration on ways to stymie the ransomware industry. Among many other recommendations, the report urged the White House to make finding, frustrating, and apprehending ransomware crooks a priority within the U.S. intelligence community, and to designate the current scourge of digital extortion as a national security threat.

Corporate “Oversight”

As corporations either invest or receive bailout money to build out security, corporations will invest in tools to scan networks, environments, systems, and assets in an attempt to pre-empt and detect threats. However, this data needs to be managed effectively, prioritized, and applied to people, process, and technology to have any impact. This is where companies can fall short and is a gap that CyberOne is trying hard to help them fill.

We want all companies to build a culture of risk across their organization. This starts with effective governance and leadership commitment to risk awareness and providing resources for effective risk management. While many companies are able to provide compliance certifications as a demonstration of commitment to security, risk management is really the key to effective security.

For more information on risk management implementation contact CyberOne

 

 

May is Free: Get Your CMMC Free Readiness Assessment

 

For the entire month of May, CyberOne is offering a free readiness assessment for CMMC Certification. The Assessment is compatible with the 800-171 Assessment required by the SPRS. Click on the link below and put CMMC in the message field. We will respond with your assessment:

FREE CMMC Assessment

Fully Guided CMMC Implementation and Certification – no need for costly consultants:

CyberOne’s full suite GRC platform enables you to complete every step of the CMMC Certification process. We provide you all the tools and information you need to achieve and maintain certification on CyberOne’s highly automated, modern SaaS platform. Before you engage an MSP or consultant, check out what we can do for you. Request a demo today.

  • NIST 800-171 Control Self Assessment, SSP (get it for free here)
  • Policy Development Support
  • CMMC Control development and implementation guidance (level 1-3)
  • Automated Evidence Collection and review
  • Mitigation and Issue Management for POA&M’s, Findings and Risk Environment
  • Risk Register for proactive risk management
  • Vulnerability Scans & Analysis
  • Our Auditor-ready platform can be used in collaboration with C3PAO’s for Certification
  • Contact with C3PAO’s ready to certify you with CyberOne special pricing