How to Design Effective Security Compliance Programs
Security compliance is a primary concern for data-driven, technology-empowered businesses. On the one hand, they face internal and external security threats ranging from ransomware and phishing attacks to malicious insiders and human error. On the other hand, regulatory frameworks such as HIPAA and the GDPR impose stringent security and privacy standards with legal and financial penalties for non-compliance.
A security compliance program helps a business to own its compliance risks. However, there are numerous challenges along the path to a security compliance program that supports long-term compliance goals. This article explores security compliance programs and suggests strategies to help businesses manage security compliance risks.
What Is a Security Compliance Management Program?
A security compliance program is the policies, procedures, and processes an organization creates to maintain security standards, typically based on regulatory frameworks such as HIPAA or recognized industry standards such as SOC 2.
Security compliance programs also encompass the mechanisms by which the organization reviews and assesses information management practices. Without ongoing monitoring and auditing, it’s impossible to verify the organization is complying with its own policies.
Perhaps most important, security compliance programs are people-focused; they aim to create a management framework with resources and incentives that encourage employees to follow security best practices.
An organization without a security compliance program may follow security best practices in an ad-hoc manner, but then again, they may not. Information security and privacy concerns are often deprioritized relative to other business goals. A security management program supported by an organization’s leadership helps align business practices with security compliance objectives.
A security compliance management program enables organizations to:
- Comply with regulations such as Sarbanes-Oxley, the Health Insurance Portability and Accountability Act (HIPAA), and the Payment Card Industry Data Security Standards (PCI DSS), among many others.
- Protect data assets and reduce the legal, financial, and reputational risk of regulatory compliance failures.
- Design policies and implement processes that allow executives to exercise control over the organization’s security posture.
- Monitor and verify security compliance
Those interested in building a security compliance program may find it instructive to read the U.S. Department of Justice Criminal Division’s Evaluation of Corporate Compliance Programs. Although broader in scope than information security, it explains the factors that prosecutors look for when evaluating compliance. These include the presence of risk assessments and risk management processes, well-designed and comprehensive policies, risk-based training, properly scoped investigations by qualified personnel, internal and external audits, and more.
The Components of Effective Security Compliance Management
A security compliance management plan is tailored to the business’s needs and the environment in which it operates, but effective security compliance programs are built on the following components.
Security Compliance Policies
Policies are the key documents in a security compliance management program. Security compliance policies describe the minimum security standards with which the organization intends to comply. Policies should be informed by a variety of factors, including:
- The organization’s business objectives,
- The regulatory environment in which the business operates, and
- The specific risks the organization faces.
Policies are long-lasting, high-level documents, but they are not permanent. A company must be prepared to evolve policies in response to changes in the organization, its operating environment, and the technology on which it relies.
Structures to Implement Security Compliance Policies
Policies are only useful insofar as they are implemented, but this is often the biggest challenge. Security compliance impacts almost all aspects of modern business: data is a key asset, and information technology is ubiquitous.
There are two possible approaches. The first is to “bolt” security compliance onto existing business processes. However, as Gartner’s research makes clear, this is unsustainable and unscalable. It makes security a potential hindrance to normal operations, creating the risk that compliance processes are bypassed as managers and employees prioritize efficiency.
The second approach is to make security compliance an integral part of business processes. As workflows are designed, compliance is “baked in,” informing organizational structures, processes, relationships with business partners, and technology choices.
Learn more about building compliant business processes in Auditor Insights: Compliance from the Start.
Whichever approach is chosen, security compliance management requires leadership and clear communication with stakeholders throughout the organization. A typical security compliance management structure includes:
- A leader with authority to sponsor security compliance projects. This may be an executive or a security compliance steering team with executive support.
- Participation from relevant stakeholders within the organization. This might include stakeholders from IT, information security, sales, finance, and other business units. The IT department plays a critical role in security compliance. Still, other stakeholders should also be involved to reduce the risk of security compliance procedures failing to align with broader business objectives.
- A compliance manager or managers with information security expertise. The compliance manager is responsible for overseeing compliance projects that integrate security compliance throughout the business. For example, the compliance manager may work with IT to implement encryption policies for sensitive data. The compliance manager also gathers evidence to assess compliance efforts’ effectiveness and inform future policy and process changes.
Additionally, it is usually necessary to offer information security training. Any employee who has access to potentially sensitive data should receive security awareness training that prepares them to comply with information security policies.
Security Compliance Evaluation and Auditing
Compliance monitoring and internal audits are essential. Security compliance is a continuous process of implementation and evaluation. Policies evolve as regulatory standards change, and procedures and outcomes must be re-evaluated to ensure they meet security compliance objectives. Internal monitoring and evaluation should be augmented by external audits conducted by experienced auditors with information security expertise.
Implementing a Security Compliance Management Program for Your Business
There is no universally applicable template for building a compliance management program. Every company is different, and so are its compliance requirements. However, most businesses benefit from a plan which follows these steps.
- Conduct a risk assessment to establish which risks the company faces, including compliance risks.
- Develop policies and standards to mitigate those risks.
- Appoint a compliance leader to oversee implementation and communication with stakeholders.
- Implement processes, procedures, and tools that support compliance policies.
- Train and educate employees to understand your compliance objectives and the role they play in achieving them.
- Monitor compliance and conduct internal and external audits to measure how effective your compliance efforts are.
- Act to correct risks and compliance failings identified by monitoring and audits.
As we mentioned earlier, security compliance management is an ongoing process. The steps outlined above should be thought of as a cycle rather than a linear process that will be complete at a point in the future.