This is a guest post by Cass Brewer, the founder of Truth to Power Association.
John Rostern recently blogged here about the dangers of checkbox compliance, noting that regulatory compliance doesn’t always bring information security.
I’ll take that argument a step further: Especially in terms of PCI DSS, most companies might get better ROI and comparable outcomes if they simply lied on their PCI DSS self assessments and returned to sprinkling salt around their servers, or whatever (apparently) prevented system breaches before PCI DSS came along. As John so aptly notes, siloed, point-in-time compliance is generally inadequate — in terms of both control and cost.
Unfortunately, external mandates tend to pervert otherwise healthy plan-do-check-act operational strategies. In the rush to comply with regulatory panaceas for perceived pervasive risks, managers too often deprecate their own informed risk judgments.
This is a backward response. Enterprise risk management should be both an input and output of any compliance program. As an input, it lets managers “just say no” to immaterial audit recommendations, defines implementation priorities and ensures that relevant controls aren’t displaced by compliance checkboxes.
Management can operationally parse broad compliance requirements by aligning control responses with actual material and significant risks. Or it can limit the in-scope environment of specific controls to particularly critical or sensitive information: cardholder data, customer PII, systems logs, etc. Either way, the bulk of risk management should occur on the front (planning) end of compliance. The risk management output of compliance programs is generally limited to risk mitigation.
Defining and measuring risks up front is also a cost-containment strategy. Under the Sarbanes-Oxley Act and other rules, organizations can exclude irrelevant “compliance” activities aimed at immaterial and insignificant threats. Of course, concrete documentation (and lots of it) is the key to defending such exclusions against auditor challenges.
Risks characteristics including existence, criticality, likelihood and period can further hone appropriate control responses. If a particular risk arises only once a year and potentially impacts just one disconnected system, a siloed, periodic response might be adequate. Of course, most risks are more constant and/or pervasive. Control efforts should respond to those characteristics, hitting compliance goals incidentally.
A risk management approach to compliance has opportunity benefits, too. It’s difficult to measure risk value (or risk abatement value) without understanding business-process value. In many cases, key risk indicators (KRIs) are complements to key performance indicators (KPIs). Defining one provides a base line for defining the other; and that base line is, in turn, a costing base line that supports more broadly strategic business decisions.
How does this work? Learn how to factor risk management into compliance assessments at SearchCompliance.com.
Cass Brewer is the founder of Truth to Power, a free and open research community for better information governance. At T2P and in her previous role as director of the IT Compliance Institute (ITCi), Cass has worked with thousands of compliance, audit, business, and IT leaders to develop practical guidance for corporate compliance and risk management. She can be reached at firstname.lastname@example.org.