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100% compliance is not an outcome that gets achieved by accident. It takes a great deal of strategy and planning to get to the point where you can reliably maintain complete alignment with regulatory rules. And complete alignment is what you need in today’s world of rising threats and steep consequences for noncompliance. Every compliance violation invites a consequence, whether that’s an SEC fine; reputational damage from an unintentional leak of sensitive data; or ransomware and other attacks from malicious actors exploiting underprotected systems.
The stakes are such that 100% compliance needs to be ensured through a rigorous, programmatic strategy. At ECI, we call this a Governance, Risk and Compliance (GRC) Program. This holistic and coordinated approach to enterprise security and operations is essential to achieving 100% compliance.
100% Compliance Requires Rigorous Planning and Strong Execution
Earlier in this series, we drew the analogy of 100% compliance as being similar to a perfect score at the Olympics, or acing the SAT. Those analogies are useful not just because they demonstrate how 100% compliance is 100% achievable, but also to illustrate how the key to a perfect score is to first plan strategize your approach, and then pull it off flawlessly.
Athletes competing at the top of their sport take a rigorous and broad-based approach to planning that involves diet, strength training, mental toughness, technique and more. Scholars looking to ace the SAT study the entire range of topics they’ll be assessed on, while also familiarizing themselves thoroughly with the format and standards of the test itself. Each of these scenarios requires a comprehensive approach to planning and execution to get the Olympic gymnast atop of the podium, or the test taker that perfect SAT score.
The same is true for achieving 100% compliance. Organizations can’t afford to narrowly look at risk management, vulnerability mapping, threat mitigation, IT governance and other tasks in isolation. There are complex and highly-interrelated factors that form the basis of a company’s overall compliance posture – and so an overall program for governance, risk and compliance is therefore needed to orchestrate these factors together to achieve 100% compliance.
Building the GRC Program for 100% Compliance
Organizations that put a GRC program in place soon find they’re able to achieve stronger compliance as the program is iteratively developed and implemented in enterprise systems. The plan rollout typically begins with initial deployment of vulnerability scanners and security assessment controls mapping to establish baseline conditions. These foundational steps then form the basis for business impact analyses and information security policy frameworks.
From there, the GRC plan grows to include development of a full Business Continuity and Incident Response plan, and even a Vendor Management platform to guard against third party compliance risk. All these activities create a whole level of insight and control that is more than the sum of their parts. And the plan remains a living-breathing document, allowing new functionality and technology tools to be layered in as needed with the help of continuous feedback loops that constantly adjust to changing threats and business conditions.
To ensure 100% compliance, the GRC must be attuned to the unique domains and business activities of the organization. That means financial sector organizations should ensure their GRC program closely aligns with SEC Division of Examination (formerly OCIE) controls and requirements, CIS controls and the NIST Cybersecurity framework in the United States – as well as with similar compliance frameworks internationally.
If building a GRC plan sounds complex, that’s because it is. And that’s why, just as top athletes and academics team up with experienced coaches or tutors to help them excel, organizations can partner with an MSP to help master the design and implementation of a GRC program. The right partner can help C-suite executives and IT leaders leverage the GRC plan for holistic control of all factors impacting compliance – with real-time visibility into where and how threats or changes in operational conditions are affecting the compliance picture. This is the level of coordinated planning and control that it takes for an organization to achieve 100% compliance – and it’s 100% achievable with the right MSP partner on your team.
