Why Continuous Compliance is the Key to Scaling your Compliance Program
The regulatory landscape is in a constant state of change, which can put organizations in a cycle of perpetual catch-up. How can you truly stay ahead of the curve, and if you got there, what steps can you employ to sustain it?
This blog explores the challenges associated with compliance and how building a “continuous compliance” mindset can help your organization meet these challenges head-on while making your organization more agile and resilient in the process.
What’s the traditional approach to compliance and the challenges with it?
At any given time, organizations need to ensure they’re compliant with the latest regulations, standards, and frameworks, such as ISO 27001, PCI DSS, CMMC, HIPAA, NIST CSF, and more. Today, for instance, businesses are preparing to comply with UK SOX, new legislation designed to restore confidence in the auditing of listed companies and protect investors from fraud.
There can also be contractual requirements imposed by suppliers or customers and internal policies and procedures such as information security and fair usage policies that organizations need to comply to.
Each regulation and standard often requires you to conduct periodic audits of your IT environment to ensure that you’re meeting the requirements.
Let’s take a traditional approach to compliance and see what’s involved. Security and compliance teams will need to adopt and manage the compliance framework.
They’ll have to:
1. Manage and schedule the compliance tests and audits (which typically take place annually)
2. Request, review, and check compliance documentation
3. Conduct testing and assurance activities to identify control gaps
4. Produce reports to the business on compliance status
5. Support the preparation of documentation and evidence for external reviews and audits (SOC2, SOX ISO 27001, etc.).
You then have business stakeholders who are asked to:
• Prepare evidence documentation for each of the compliance requirements.
• Update any controls and remediate any testing findings.
The downsides of a traditional approach to compliance are as follows:
1. Wasted manual effort
It is driven by manual, repetitive, and disparate compliance processes that are very labor-intensive. Each compliance requirement you add makes it more complex and time-consuming, with additional manual processes throughout the year.
2. Duplicate controls
As each compliance requirement can often have remarkably similar but not identical asks, organizations can end up with multiple if not identical controls, leading to duplicate efforts and confusion.
3. Creates hundreds of compliance artifacts
Business stakeholders can be asked for the same thing multiple times and create hundreds of compliance artifacts across email, shared drives, Word, Excel, PowerPoint, etc.
4. ‘Point-in-time’ assessment of compliance
The traditional annual audit delivers point-in-time assessments of compliance and does not account for the time in-between where things can substantially change. Technology is evolving much faster than the traditional annual audit caters for.
5. Seen by stakeholders to slow down business
It is seen as a once-a-year activity by business stakeholders that slows down business operations and doesn’t add much value beyond a check-box exercise.
6. No aggregate, real-time view of compliance
As the data comes from multiple disparate sources, it makes reporting an aggregated view of compliance within the organization very difficult and almost impossible to see in real-time.
It’s easy to see how manual and disparate compliance processes can lead to duplicate controls and wasted effort, and it’s where many businesses struggle to scale as they grow. Businesses fall behind the compliance curve and run the risk of penalties or, worse, security breaches and lost data.
So what is the answer?
The simple answer is moving to a state of continuous compliance.
Continuous compliance is about moving away from ad hoc audits and checks to creating live compliance documents using a combination of People, Processes, and Technology. The combination of the three will allow you to free up people’s time to focus on the core issues rather than repetitive admin tasks.
Standardized and aligned processes will simplify testing and evidence collections, then technology will allow you to automate the processes using workflow, emails, and notifications. It can also allow you to fully automate the collection and analysis of data to provide constant assurance of controls operating effectively.
What makes up a continuous compliance program?
1. Close collaboration between stakeholders
Continuous compliance is as much a cultural change as it is a process-driven one. Often security, compliance, and operations teams are not aligned, and each is working toward entirely different objectives. Organizations need to unite these teams around a common set of objectives.
2. Ongoing assurance throughout the year
Businesses need to conduct assessments and collect evidence on an ongoing basis – it’s not something we forget about for nine or ten months of the year. It’s something that we’re doing little and often throughout the year.
3. Live compliance documentation
Conducting activities on an ongoing basis allows you to create live compliance reports, documents, and accurate artifacts. When it comes to audits and reporting, your organization already has everything it needs to demonstrate compliance throughout the year.
4. Automation of manual processes
You can use technology to automate processes such as creating controls, scheduling tests, evidence collection, and reviews. It can also allow you to fully automate the collection and analysis of control data to provide real-time assurance that controls operating effectively.
5. Standardized and rationalized controls
Standardizing and rationalizing your control set into an overarching framework makes it much easier to update, deploy, test, and monitor controls in real-time.
Practical steps to embed a continuous compliance program
The path you take to continuous compliance should look something like this:
1. Be clear on the goal.
Develop a clear strategy and secure stakeholder buy-in for the move to continuous compliance.
2. Identify the appropriate regulations, frameworks, and standards
Consider developing a realistic scope. You’re probably not going to move your entire compliance program to this straight away. Focus on the most critical compliance requirements first.
3. Develop your organizational policies and standards
For any compliance program to be successful, you need to have created and distributed a set of policies, standards, and procedures that the organization has read and understood.
4. Identify your critical assets
It is essential to have a documented list of assets that have been impact-assessed to establish a known list of business-critical assets to prioritize continuous compliance and security efforts.
5. Establish and implement appropriate controls
Once you have established the regulations, frameworks, and standards, you will need to distill them into an overarching control framework yourself or use a baselined control set such as the Unified Compliance Framework (UCF) or Secure Controls Framework (SCF).
6. Test, review, and improve controls
It is crucial to test your controls to check they have been implemented correctly and identify any control failures or gaps. This will enable the business to improve and adapt the control set.
7. Enable continuous insights from testing and monitoring
When you have standardized and rationalized controls, you can identify the key control and look at technology to provide continuous monitoring and insight into the control in real-time.
8. Maintain live documents and communicate updates in real-time
Finally, as you are testing and monitoring controls on an ongoing basis, you can maintain a single source of truth centrally and report on compliance levels in real-time to create live compliance documents.
SureCloud’s Compliance Management Software supports standardized compliance frameworks so you can establish baseline controls. It also supports the scheduling, maintenance, control testing, and remediation processes. In addition, it automates the collection and analysis of data from third-party systems to monitor compliance in real-time via our continuous control monitoring capability.
If you would like to learn more about what we do and how you can implement continuous compliance in your organization, watch the full presentation here.
About Matthew Davies
Matthew is a risk and compliance expert with more than a decade of experience helping GRC leaders get the most from their GRC tooling. He is currently responsible for planning, executing, and delivering SureCloud’s GRC and Cyber products. Before SureCloud, he held positions at PwC & Deloitte within IT Risk /Assurance and GRC technology.