Comprehensive Compliance Frameworks

Obviously, the cost is steep for not following through. However, implementing a comprehensive compliance framework at scale – capable of crossing multiple business units and remaining effective and within budget can be a daunting task, involving technical, operational, and cultural challenges that must be overcome to achieve success. GlobalScape reported that organizations lose an average of $4 million in revenue due to a single non-compliance event. This number is staggering and typically the result of reputational damage, regulatory fines, and business downtime – all a direct result of one failure. Some organizations work diligently to ensure a mature compliance program is in place, yet, there are many more whose compliance strategies consist of nothing more than hoping for the best.

Most existing governance and compliance programs lack the automation and software beyond spreadsheets that are necessary to successfully manage compliance across complex industries such as financial services, healthcare, and retail chains. A large number of organizations admit to utilizing only office productivity software, such as documents and spreadsheets, for compliance management. These antiquated practices are inefficient and prone to human error at best and certainly exacerbate the technical challenges already present for audit and compliance teams.

If you follow the news, you might believe the banking system is most at risk of compliance failure, yet, they are far from the only industry. Here are the organizations most susceptible and why:

Business Process Outsourcing: BPOs handle a significant amount of confidential data and complex business processes, subject to regular third-party audits.

Financial: Banks, insurance companies, and other financial institutions are subject to a wide range of regulatory requirements, making compliance a top priority.

Healthcare: Healthcare organizations must comply with strict regulations related to patient privacy and data security, as well as industry-specific standards such as HIPAA.

Retail: Retailers must protect customer data, comply with payment card industry standards, and manage risks associated with supply chain and logistics operations.

Technology: Technology firms must navigate complex legal and regulatory environments while also addressing evolving cybersecurity threats and privacy concerns. Most face a complex array of requirements as technology companies intersect multiple industries and specialties.

Manufacturing: Manufacturers must manage complex supply chains, meet industry-specific regulations, and ensure the safety and security of their products.

Here is a comprehensive list of the challenges these organizations face when trying to meet compliance mandates while maintaining security, stability, and long-term profitability.

Building the internal fortitude to embark on a comprehensive framework/governance initiative requires significant buy-in from the top down, especially for new initiatives in a low-maturity environment. Identifying the appropriate stakeholders and champions needed for collaboration and approval is paramount, as is providing the appropriate education, awareness, and coordination.

Determining the correct framework(s) for implementation, to what extent, and to where they should be applied can be difficult. Advanced consideration must be given to any contractual or regulatory requirements relative to operations.

Determining the costs and impact to operations to properly budget for compliance efforts (technology, staff, training, etc.) and managing productivity expectations up front typically results in unnecessary burdens on an organization’s team members if done incorrectly.

Mitigating internal resistance to change throughout the business and identifying areas or individuals of concern for non-compliance can pose an issue for complex businesses. Communication and operational silos hinder oversight efforts, creating gaps and the likelihood of a compromise.

Aligning operational processes and procedures requires a thorough understanding of business workflows to identify key controls that can be applied consistently. In tandem, identifying enhancement opportunities based on departmental requirements can be time-consuming.

Establishing an internal audit program that is effective and efficient is seen as impossible to most. Moving away from manual processes and implementing automation to manage compliance-related documentation and activities in a centralized manner requires significant organizational buy-in and planning.

Technology debt in each of the departments comes under the fold of a centralized set of technical and security controls. Legacy systems may not be capable of meeting control requirements. Additionally, a diverse and complex technology stack could differ drastically in key hardware and software solutions.

Organizations must also balance data privacy requirements, especially cross-border data transfers. Issues arise when a comprehensive software solution lacks the ability to manage and monitor controls tied to common and unique requirements across the organization. This includes the solution’s ability to integrate with different systems and technologies to allow for a comprehensive view in real-time.

Complex businesses may face the challenge of lacking a diverse team of cybersecurity and governance professionals who understand both the internal technology and applicable controls necessary to ensure a timely implementation process.

Conglomerates, private equity, and other capital structures that typically decentralize some of their compliance oversight may struggle with control issues, specifically, outsiders intruding on deep layers of their organization.

Multi-national organizations may have all the concerns previously listed but also face language and cultural barriers.

Publicly traded entities have SEC cybersecurity requirements to consider. These mandates typically create short turnaround times to implement comprehensive programs and are required to report their strategy’s progress, success, and failures to their board of directors and the public on a routine basis.

Franchises or other similarly organized businesses which have arm’s length control over business processes, often struggle with oversight. The franchise model creates multiple small pockets of risk to oversee, each with unique operating conditions, reporting, and challenges.

Work with the organization’s leadership to understand the need to move from a reactive to a proactive security and governance posture, focusing on current objectives, obligations, customer requirements, risk appetite, and known compliance requirements. The leadership team should be involved to ensure awareness and continued funding and buy-in of the process.

Assess the maturity of the current GRC program, initiatives, staffing, and overall maturity while also taking inventory of the business to identify key stakeholders, build relationships, and plan the overall structure of the team. Determine if additional resources might be required—even temporary ones—to help facilitate the initial reviews or niche efforts (i.e., implementation of a specific framework while the larger, in-house team focuses on the day-to-day maintenance activities or remediating control gaps.)

Assign clear roles and responsibilities for compliance activities to avoid confusion and duplication of effort. Make sure each business unit or region understands its obligations and designate clear points of contact along with a primary leader to ensure top-down consistency and open communication channels from departments all the way up to management, the board of directors, and shareholders. This helps ensure that everyone is aware of the organization’s compliance efforts, the progress being made toward achieving them, and their individual expectations. If software or other solutions are utilized in the process, responsibility must be assigned there as well.

Determine the appropriate compliance framework(s) to implement, based on any contractual or regulatory requirements relevant to the organization’s operations. The framework(s) should be implemented consistently across all business units and regions to ensure a uniform approach to compliance. For a Fortune 100 business operating in multiple regions, compliance frameworks such as NIST CSF or ISO 27001 would be applicable to address these challenges. These frameworks provide comprehensive guidelines for establishing and maintaining a robust security posture while accommodating regional differences in compliance requirements. Additionally, SOC 1 and 2 reports, as well as PCI-DSS compliance, may be required to address specific industry-related compliance requirements.

Organizations must also determine costs and impact on operations, including technology, staff, training, and any other resources required to achieve compliance and budget accordingly and fairly.

Managing productivity expectations can help reduce the burden and pressure on teams and ensure that compliance efforts do not deter operations. Financial exposure is a critical factor to consider, and being able to communicate it in the context of controls and maturity will further the connection with those responsible for guiding the business (e.g., board of directors, C-suite).

Administrative teams should identify compliance management and automation tools to handle tasks wherever possible to reduce administrative burden and ensure a consistent compliance experience from control monitoring, documentation, and reporting processes. This is why it is important to partner with compliance management experts like SDG to manage redundant compliance activities, automate policy enforcement, provide evidence of compliance for audits, and enact transparency throughout the organization.

Standardized policies and procedures adapted for each business unit or region can ensure that everyone is working from the same baseline. This will uphold consistent compliance across the organization and reduce confusion around expectations. It also allows for any necessary enhancements to adopt additional frameworks. This is especially helpful if organizations provide these in an easily accessible place and can tie system configurations to policies.

Organizations should proactively conduct regular risk assessments to ensure issues are identified and managed. This consistent practice of checks and balances will flag potential issues before they become major problems and will enhance the overall governance program.

Internal resistance can plague the best intentions. Establishing a cross-functional compliance committee with appropriate representation across the business can foster a shared vision for compliance and align priorities and practices. The committee should establish clear roles and responsibilities for compliance to drive shared and individual efforts. Stakeholder engagement, training, and ongoing communication are the baselines to building support.

Assessing the technology infrastructure across all business units and regions will help identify any variations in systems and processes and enable the development of a unified, flexible compliance framework or set of controls that can accommodate these differences. While doing this, performing a processing and data mapping exercise is also effective at capturing details that only the technology teams may see. This could be accomplished through workshops, surveys, or interviews with relevant team members and uncover previously unknown issues or risks.

Organizations that implement a centralized compliance management system to track efforts and progress and work to automate routine processes to eliminate manual efforts are the most successful.

This process requires a higher level of maturity but can be accomplished with the support of an experienced team like SDG who understands the environment, applicable controls, and tools. Having a system to support collaboration, communication, automation, tracking, and enforcing consistency will also address any miscommunication that may arise amid language or cultural differences.

Organizations should conduct and review system and software inventories to understand technology assets throughout the environment, how they fit into their governance program, if they are able to meet the necessary standards as-is, and the cost and effort required for any workarounds. Attention should be given to identifying non-compliant and/or high-risk systems to align upgrade and retirement plans with the business and internal groups. If a compliance budget can be allocated to support the remediation of legacy assets, it may advance risk reduction efforts and build trust in the governance team. Moving forward, all new assets should be confirmed to conform to internal baselines during the acquisition process.

Next, companies must conduct a comprehensive data mapping exercise to identify all data flows and data storage locations, including all third-party providers. This helps the organization’s security team understand the types of information collected, transmitted, and/or retained, and allows them to begin identifying the relevant standards and technical safeguards that require implementation and applicability. Build these additional requirements into the spirit of the overall controls or as enhancements for business units to apply during situations where marketing has new additional considerations, such as GDPR or CCPA.

Additionally, evaluating governance, risk, and compliance (GRC) platforms that can integrate with different systems and technologies can provide unified oversight of compliance in real-time across the organization and afford customized adaptability to multiple frameworks and organizational units. It is important to ensure that these solutions are integrated with each other and with other key systems, such as security information and event management (SIEM) and identity and access management (IAM). KPI tracking, dashboarding, and the ability to easily report or provide executive-management-level views of governance efforts are critical.

Developing a team of cybersecurity and governance professionals with technical and business skills is not guaranteed to be a long-term recipe for success. Regularly evaluate where the team could benefit from external service providers or consultants to augment existing capabilities as the function matures or individual initiatives arise.

Many GRC software platforms are not capable of managing complex organizational structures without overwhelming implementation processes and configuration efforts, leading to unfriendly, incomplete and non-functional solutions.

Planning for how to continually evolve and adapt is critical to keeping pace with today’s regulatory, risk, and threat landscape. GRC sits at the perfect intersection between enabling enterprise agility and balancing operational risk and resiliency. A proactive approach can break down barriers to implementing one or many compliance frameworks across the most complex organization.

SDG is a leading provider of technology, consulting, and managed services that enable organizations to confidently execute cybersecurity, identity, and risk management solutions to mitigate risk, protect assets, and grow securely.

Our 30 years of experience have transformed compliance integration and management, enabling hundreds of organizations to take control of their complete compliance lifecycle and enhance governance of all compliance-related activities – even in the most diverse and heavily regulated environments.

SDG is a leading provider of cloud services and solutions, with expertise in cloud cost optimization. We have helped numerous organizations across various industries achieve significant cost savings and improve their cloud efficiency. Our team of certified professionals possesses extensive knowledge of cloud platforms, pricing models, and optimization techniques, enabling us to deliver effective and tailored solutions to our clients.