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:
- 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)
- Continuous Monitoring: Implementation, corrective action, validation; review, recycle, add, rinse. (This is beyond the checkbox)
- 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:
- Policy Management: Can you write, review, update and communicate policies and connect them to your internal controls and regulatory requirements?
- Asset Management: Can you attach controls to specific assets and monitor those assets in your tool?
- Control Management: Can you work with multiple regulations and consolidate your internal controls to meet multiple requirements?
- Evidence Collection: Can you automate evidence collection and use one piece of evidence to meet many controls?
- Control tests: can you validate evidence and create reports that demonstrate validation by control and assets?
- 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.)
- 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?
- 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:
Harvard Business Review: https://hbr.org/2018/03/why-compliance-programs-fail
The Compliance and Ethics Blog: