Regulatory Compliance, Governance and Security

May 31 2009   3:33PM GMT

Policies and Procedures | SAS 70 | PCI DSS | An Auditor’s Viewpoint



Policies and Procedures-it’s such a common theme and phrase in today’s regulatory compliance and governance arena, so much so, i think it should have it’s own Wikipedia page. It can be an arduous undertaking in developing these documents. Furthermore, policies and procedures are becoming increasingly larger and larger in scope for compliance initiatives.

Take a look at Requirement 12 for PCI DSS compliance; Maintain an Information Security Policy. It’s quite detailed, to say the least. Furthermore, there are numerous other P&P requirements sprinkled throughout the other 11 PCI DSS requirements.

As for SAS 70, the audit’s success also depends on policies and procedures for a large range of items. A few examples of common P&P documents that may fall under the scope of a SAS 70 Type I or SAS 70 Type II audit are as follows:

Change Management P&P
An organizational wide security policy handbook with documented P&P
Backup P&P
SDLC documentation

To be blunt, most organization despise authoring these documents for a number of reasons: time, cost, or the simple inability to write effective P&P documents.

Even with that said, organizations need to be aware of the growing requirements for P&P for SAS 70, PCI DSS, and a whole host of other regulatory compliance mandates.

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