As organizations go through digital transformations, managing compliance for the data that they process is becoming more difficult. Staying compliant with the multitude of regulations has always been a security concern and hard work for IT professionals, but rapid digital transformations are adding to this challenge and are making it more difficult for IT professionals to mitigate the security risk and associated compliance issues. There are practices that IT professionals can adopt to encourage a more effective compliance plan and better manage risk for this digital age in which we function.
Regulations keep changing, existing regulations are developed upon and brand-new ones evolve to address growing issues to specific problems. It is challenging for organizations to keep on top of this, to ensure that all compliance requirements are continuously and comprehensively met. Some industries must comply with an array of compliance practices. As compliance responsibilities change — and your compliance plan should, too — if an organization’s infrastructure, existing policies, and frameworks are not easily adaptable it makes it more challenging to put the processes in motion to comply with new requirements.
Staff often see compliance in a very different light, often more of a nuisance than a fundamental aspect of the organization’s success — which it ultimately is.
Consider the 2018 General Data Protection Regulation (GDPR). This is one of the biggest compliance changes to happen in many years. At first glance, it is an EU regulation, but it has a global reach and does impact the majority of organizations as long as they are processing data of EU citizens. This is a major change for most organizations and requires a lot of thought and strategy to implement the requirements to comply. Because it is a legal requirement, there is no way out of it and the penalties are significant for noncompliance. Compliance changes affect every aspect of a business including the staff. It is challenging to collaborate and align all processes and objectives to comply. It takes a considerable amount of time and effort to stay abreast of the changes and is difficult, for the most part, to get everyone motivated to jump on board and make it happen. Staff often see compliance in a very different light, often more of a nuisance than a fundamental aspect of the organization’s success — which it ultimately is.
Showing transparency and accountability is key for many compliance requirements including mandatory regulation compliance (like GDPR), industry standards (like PCI DSS) or to uphold certifications (like ISO27001). All of these require an organization to demonstrate their compliance which can be challenging without the correct foundations, processes, and controls. So, organizations need working systems in place to guarantee this. Methods for monitoring, reporting and managing employees’ behaviors to make sure that compliance is fulfilled as documented. IT resources must be managed to ensure accountability.
Advancements in technology, multifaceted environments, and functioning contribute to the compliance challenge and make drawing up an effective compliance plan that much harder. For example, areas like bring your own device (BYOD), Internet of Things (IoT), third-party applications, and shadow IT (to name a few), although all advantageous, create security vulnerabilities and impact compliance. This can be particularly tricky to manage; however, control is essential to ensure compliance is continuously met. All of these contribute to cyber-risk and need to be managed. The risk must be assessed so that any associated compliance risk can be effectively managed. Also, as technologies evolve, it means that many organizations have a mix of old and legacy systems. It’s important to know which systems are in use and for what purpose and to ensure the software is kept up to date and patched.
Adding shadow IT to the mix and BYOD (with unauthorized applications and devices) increases the compliance plan challenge as these may circumvent corporate IT systems. If not properly managed, the organization is unaware of the software or applications that staff is using and the data that they are processing. IoT, interconnected devices, and the merging of the digital and physical are expanding the potential threat landscape too. All these systems need to be compliant, so practices must be in place to ensure their continued compliance for not only data protection but physical safety too.
Effective Compliance is only achievable if everyone is on board. This is often challenging for some organizations as it involves getting everyone to realize the importance from the top down. Everyone, no matter their job function in the business, has a role to play and it’s important that this message gets across and that the correct compliance and security culture is encouraged. Entire organization responsibility for compliance is necessary so that wider concern for policies, processes, and controls is encouraged to create an organization that’s compliance and cybersecurity aware. So, all staff, all teams, all departments are ready to accept changes and adapt continuously for the organization to continuously comply. This requires continuous training and education for all personal.
Managing how external parties comply so that the supply chain is consistently compliant too, is a challenge. The organization is only as compliant and secure as its weakest link. The cause of many vulnerabilities is often directly or indirectly a result of a third-party participant. It’s challenging to manage a third party or vendor’s information security and compliance with regulations, but it is fundamental to your organization’s continuous compliance to get this right.
In this highly interconnected digital world, organizations are processing increasingly large amounts of highly sensitive data. Cyberattacks are on the rise because of this. So are internal accidental errors (and intentional ones). Organizations have a responsibility to protect the data that they process, not only for compliance reasons but to protect their customers, their brand, and reputation and ultimately the success of their business. Identity theft, financial fraud, and loss of data or privacy of data are primary concerns for many businesses. As organizations’ environments become increasingly complex and multifaceted, it is more challenging to ensure data protection and access control to maintain compliance and mitigate the risk. Compliance regulations like the GDPR (legal compliance), PCI DSS (industry regulated compliance for credit card processing) and HIPAA (health industry compliance for sensitive patient information) all, if observed, aim to mitigate many of these risks.
We know that regulations adapt and change, so be prepared for this to happen. Get the groundwork right. Try to implement the best possible frameworks and standards for data management and protection. Frameworks are quite flexible so when changes need to be made new ones can be mapped to them more efficiently and compliance disruption is kept to a minimum. Try to standardize processes across compliance regulations. Compliance strategies need to evolve to meet regulatory change. It’s helpful if changes can be anticipated and plans made ahead of any significant changes. A lot of the time changes are not instantaneous and there is a considerable lead up to them, organizations should take advantage of this to continuously comply.
Generally, it is better to move with the times with regards to technology. The security attributed to legacy technologies was designed for a different time, different functioning, and different threat landscape. Newer technologies are likely to be better suited to current environments and security challenges. They also tend to increase efficiency and agility. If not properly managed, legacy tech (or a mix of new and old) can introduce security gaps. Compliance and data-focused technologies are beneficial and if chosen and used correctly can better support highly regulated environments. So, maximize investments in IT compliance services.
The security attributed to legacy technologies was designed for a different time, different functioning, and different threat landscape. Newer technologies are likely to be better suited to current environments and security challenges.
Ensure that your organization’s security and compliance culture carry through to your supply chain and third-party providers so that you can mitigate potential vulnerability and risk from them. If a third party does not instill the same level or higher security and compliance as your organization — don’t deal with them. Work with organizations and people that demand the same security culture as you do. Make sure you manage the potential risk and always conduct due diligence, on all partners, to ensure that their level of security and compliance is continuously maintained at levels that are acceptable to your organizations. Evaluate their history and reputation, make sure they understand your compliance requirements and assess them on specific organization governance, risk and compliance requirements. Make sure they tick all the boxes before involving them.
First, get top-level stakeholders involved and onboard so that compliance oversight comes from the top. This means that it’s more likely to be taken seriously and increases accountability. If this is a struggle, it may help to articulate the cost of noncompliance which not only relates to monetary penalties but will impact the business on other levels including customer relationships and trust, loss of competitive advantage and impact on brand and reputation. If management weren’t listening before, these will get them listening! Get everyone involved. Make compliance an entire organization responsibility so that everyone knows their role and encourage a culture of cybersecurity and compliance awareness by emphasizing the importance of security and compliance always (not only when a change is needed).
Educate employees on all aspects of data protection and provide them with the resources to uphold data privacy. Keep educating and training everyone so that it becomes habitual and the entire organization is continuously ready. By doing this, security and compliance become a priority and not a nuisance. Everyone must understand the compliance plan, the procedures and what is expected of them. So, be sure to provide the information needed, make training fun and memorable, and put it into practice.
As technologies and initiatives change, so do the skills needed to support them. This means that you need to ensure you have the right skill sets available to support these changes to maintain compliance. This may require employing or contracting individuals with specific talents that your resources lack. People with compliance and technology skill sets are beneficial as well as data analytics, cybersecurity, cyber-risk, and AI skills (especially as people and automation begin to work side by side). You must have the skills available or a plan in place to obtain them when required. Whenever possible work with industry experts.
Cyberattacks are a concern and the best chance to mitigate this risk is to focus efforts on properly securing the organization and its data. Data-driven protection is encouraged with a layered security approach to address as many potential concerns as possible. Know your environment and data assets to gain a consolidated view of the risks so that you can plan an effective strategy to minimize the cyberthreat risk. Access control is fundamental to data protection. Have procedures in place to manage who accesses what, how, and when — not only for compliance reasons but to mitigate cyber-risk and to protect customer relations. Enforce encryption and inhibit access by devices without secure access.
Additionally, have a disaster recovery plan in place and coordinate effective recovery tasks by delegating duties and responsibilities to trained teams to minimize the potential disruption if an incident were to occur. Test and practice your plan! By doing this you can identify any areas where issues may occur, where your plan is perhaps not working as intended and these problems can be rectified before any actual incident or disaster. Have practical controls in place including management protocols to control data access and manage and protect data. Ultimately, if you can effectively and continuously manage and protect the data that you process you will tick many of the compliance boxes.
Have procedures in place to manage who accesses what, how, and when — not only for compliance reasons but to mitigate cyber-risk and to protect customer relations.
Access control and data protection must be a priority. However, if it is not enforced it is as good as not having it. Enforce the data protection and compliance policies and controls that you put in place. Make sure they are being implemented! By communicating with your staff and making the software and applications that are in demand available to them, shadow IT can be better managed. Have strong BYOD policies and police and enforce them. Limit access to downloadable applications and only allow approved software and applications to be downloaded.
Manage, monitor, and report so that you can control the behaviors within your organization. Consistency is important and any diversions or violations should be effectively addressed to discourage any future transgressions. Monitoring and reporting are fundamental to the compliance plan to determine if what you are doing is effective and can establish where improvements are needed to maintain compliance. Consider investing in technologies and services that enable your organization to identify issues and act on them in real-time to mitigate the risk and encourage continuous compliance.
Improve effectiveness with automated processes and controls. Implement procedures that enable you to audit your infrastructure for compliance, scan for vulnerabilities, and continuously monitor to protect against internal and external threats to identify, assess, and remediate existing threats and monitor for new ones. Maintain accurate records for audits.
The public, customers, and clients are more security-aware than ever. Moreover, organizations are dealing with more scrutiny than ever before as a result of the various compliance regulations they must meet, both mandated and non-mandated. A compliance plan will help you get this part of your business right and will not only remove any legal concerns but improve business operations and security and will enhance public relations and trust. Achieving compliance in any area is beneficial and as long as data protection is integral to your cultural makeup, you’ll always be progressing in the right direction. Yes, there will be times when gaps emerge, but being alert and by incorporating suitable compliance best practices into processes and workflow can help you to identify these, efficiently resolve them and move on and upwards.
Security and compliance require resilience — as does your compliance plan — so just keep at it!
Featured image: Shutterstock
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