Some businesses must comply with regulatory frameworks for legality. Your current and potential clients may also expect it. One of the most effective approaches companies take to fulfill their compliance obligations is integrating governance, risk, and compliance into a unified “GRC platform.
Read on to learn about how a GRC platform is one of the best compliance management software solutions available and how to adopt one.
What Compliance Aspects Does a GRC Platform Address?
GRC is helpful in combining three disparate areas of cybersecurity into one simplified platform. This blog will touch on three aspects of compliance that GRC platforms most aptly address, including:
- Initial and ongoing implementation of all required regulatory framework controls
- Mapping controls and practices between and across multiple regulatory frameworks
- Monitoring for, avoiding, and navigating potential consequences of non-compliance
That’s not all. We’ll also provide a case study example for each aspect, utilizing a particular framework to illustrate how the GRC platform facilitates it in practice.
Implementation of Required Compliance Framework Controls
There is no shortage of compliance management system software available. Companies that implement a given framework can gain certification from their presiding government or other organizations. However, unlike other compliance advisory suites and software packages, a GRC approach is uniquely apt for implementing architecture or the practices and controls needed from the top down.
Considering a GRC approach, consider that a byproduct of its unification of governance and compliance (along with risk management) is swift approval and administration. Internal and external staff tasked with risk management and compliance responsibilities will work to integrate themselves (and these responsibilities) into the highest levels of management, facilitating near-instantaneous adoption of required practices. Put simply, less red tape means faster, more comprehensive compliance.
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Example #1: Starting from Scratch with PCI-DSS Compliance
One widely-applicable regulatory framework is the Data Security Standard (DSS), a publication of the Security Standards Council (SSC) of the Payment Card Industry (PCI). If your company processes payments via credit card, debit card, or online payment platforms, you may need to be PCI compliant to protect cardholder data and other relevant data.
A GRC can help you implement the 12 core PCI requirements, spread out across six categories:
- Secure network systems – This includes requirements for (1) installation and configuration of firewalls and (2) removing and replacing all settings installed by default by vendors.
- Protecting cardholders’ data – This includes requirements for (3) protecting stored data and (4) encrypting cardholder data before transmission and de-encrypting or re-encrypting afterward.
- Vulnerability management includes requirements for (5) regularly updating antivirus software and (6) installing and maintaining antiviral safeguards across all resources.
- Access control measures – This includes requirements for (7) limiting access based on a need to know, (8) authenticating identity for access, and (9) restricting physical access.
- Monitoring and Testing – This includes requirements for (10) closely monitoring access to cardholder data and (11) regularly testing, auditing, and analyzing all security measures.
- Information security policy – This includes one requirement (12) for maintaining security policies across all personnel, such as through regular training and assessment modules.
PCI-DSS compliance poses many challenges to companies of all shapes and sizes, significantly smaller businesses with more modest IT resources. GRC platforms are especially useful in these cases.
Mapping Controls Between Different Compliance Frameworks
The second aspect GRC compliance software addresses involve shifting between the controls required by various frameworks you may need to follow. This includes both moving from one framework to another or adapting controls for reporting across two or more frameworks you need to comply with simultaneously. Some frameworks themselves are designed for this very aim, such as the HITRUST CSF, which combines other frameworks into one omnibus set of controls.
However, even compliance with HITRUST, or other similar omnibus frameworks, may not cover the reporting and certification protocols for individual systems that it comprises. Some industries and business situations will require you to comply with various frameworks irrespective of each other, duplicating controls and navigating several overlap layers. A GRC approach facilitates mapping in even the most difficult situations, minimizing overlap and reducing resources spent.
Example #2: From NIST SP 800-171 to CMMC for DoD Compliance
Companies seeking contracts with the US Department of Defense (DoD) must navigate several frameworks to meet the Defense Federal Acquisition Regulation Supplement (DFARS) standards. One of these is the National Institute of Standards and Technology’s (NIST) Special Publication 800-171, comprising 14 Requirements spread out across 14 Requirement Families.
Moving forward, these DoD contractors will need to migrate NIST and other controls over to the Cybersecurity Model Maturity Certification (CMMC) framework. Highlights of the model include:
- A total of 171 Practices, comprising all Requirements of NIST SP 800-171 and several others from the NIST Cybersecurity Framework (CSF) and other regulatory guides
- Implementation of all 14 Requirement Families (called “Domains” in CMMC), along with three additional Domains (“Asset Management,” “Recovery,” “Situational Awareness”)
While this comprehensive scope constitutes a major mapping challenge, one built-in element of CMMC compliance that facilitates implementation and mapping is the innovation of “Maturity Levels.” Unlike NIST SP 800-171 and other frameworks, CMMC allows for stepwise adoption of its Practices to particular “Process Maturity” thresholds. These thresholds span five Maturity Levels. A GRC partner can help companies move from one level to the next with ease, then fully certify them.
Monitoring for and Navigating Penalties for Non-Compliance
Finally, GRC-focused compliance management software solutions address the consequences of non-compliance. To avoid non-compliance, GRC platforms implement, map, report on, and test all controls needed, as noted above. But even the most well-protected companies need to prepare for possible breaches, despite their best cybersecurity efforts. In some breach cases, these will trigger consequences.
A well-constructed GRC, comprising a combination of internal and external resources, will do everything in its power to stave off non-compliance penalties. But it will also make the payment of any requisite fines and the navigation of criminal and other penalties as smooth as possible. Critically, it will also seek out root causes for non-compliance to alleviate them and ensure that similar and other non-compliance penalties are avoided in the future.
Example #3: How to Steer Clear of the HIPAA Enforcement Rule
Within the Health Insurance Portability and Accountability Act of 1996 (HIPAA), “covered entities” are companies in and adjacent to the healthcare industry. Covered entities must comply with HIPAA compliance regulations enforced by the US Department of Health and Human Services (HHS). Per the HIPAA Enforcement Rule, failure to follow its provisions can result in civil money penalties of up to $50 dollars per incident and criminal penalties of up to 10 years’ imprisonment.
To avoid these penalties, companies need to prevent breaches based on the three other prescriptive HIPAA rules:
- Avoid all uses or disclosures of protected health information (PHI) not marked as permitted, authorized, or required, as defined in the HIPAA Privacy Rule summary.
- Ensure the confidentiality, integrity, and availability of PHI and electronic PHI through administrative, physical, and technical safeguards defined in the HIPAA Security Rule.
- Notify all stakeholders impacted by breaches of Privacy/Security Rules and send notice to the HHS and local media within thresholds defined in the HIPAA Breach Notification Rule.
As noted above, a GRC can help implement these practices to avoid violations, then work with the HHS and DOJ throughout the enforcement process to ensure a fair assessment is made.
Stay Compliant with a Compliance Management Software Platform
GRC platforms are some of the best compliance management software solutions available. To see just how much a GRC can help your company with compliance and more — especially from a quality managed IT service provider — contact RSI Security today!