Highly regulated financial institutions often struggle with compliance management. As a financial institution matures its cybersecurity compliance program, the document management requirements often mean they need to find automated solutions that can create a single source of truth to ease audit stress. Financial institutions store, transmit, and process large amounts of nonpublic personally identifiable information, meaning cyber criminals more heavily target the industry. As such, while all companies need to create mature cybersecurity compliance programs, the higher standard to regulators hold financial institutions means they need to improve their programs continuously.
7 Steps to Improving Your Company’s Compliance Program
How to Improve Compliance in a Company
Improving a company’s compliance, specifically for financial institutions, means revisiting and refining the original compliance program. Functionally, improving your compliance program means reiterating the process, drilling down into the original risk analysis, and integrating more specific documentation.
When attempting to mature your cybersecurity program, you need to start with the risk analysis first. Regulatory requirements and industry standards focus on risk-based models which means that if your risk analysis lacks specificity, your overall program will lack maturity.
From there, you need to continue the original process by focusing on details that may have been overlooked when you established your program. Unfortunately, given the dynamic nature of cybersecurity, you need to create a cycle of continuous monitoring, responding, remediating, mitigating, and documenting to provide assurance of governance.
Step 1: Engage in an Annual Risk Analysis
A risk analysis incorporates the risk identification, assessment, and analysis steps. Before you begin to improve your compliance program, you need to ensure that you know all the threats facing your financial institution. To do this effectively, you need to review all the locations where you store, transmit, and process data. This includes systems, networks, and devices. Then you need to review all the types of data you collect and store.
After this, you need to assess the risks to the different types of information and locations. Nonpublic, personally identifiable information is more attractive to cybercriminals so is a higher risk. The same true of things like software or networks that have commonly known vulnerabilities.
Finally, you need to analyze the risk a potential data breach by multiplying the likelihood of a data breach by the potential financial impact on the organization. This allows you to set the risk tolerances necessary for creating policies and mitigating risks.
Step 2: Update Policies at Least Annually
To mature the compliance program, you need documentation of the processes and procedures. Creating policies provides auditors the information they need to understand your internal control processes and align them with cybersecurity regulations. As your data needs change, you need to ensure that your policies reflect those changes.
Step 3: Continuously Monitor to Monitor Accountability
All industry standards and regulatory requirements focus on the importance of continuously monitoring your networks, systems, and software. Since cybercriminals continuously update their threat methodologies, the mitigating controls you set forth in your policies may no longer be adequate.
Step 5: Engage in Continuous Response and Remediation
As new threats emerge, you need to respond and remediate them. As part of your continuous monitoring, you need to will find new risks to your data environment. However, detection is the first step. You need to make sure that you are continuously responding to and remediating any new risks that arise as part of your monitoring program.
Step 4: Review Mitigating Controls
Mitigating controls protect you from cybercriminals while also providing assurance over your compliance program. As threats evolve, mitigating controls may need to evolve. As such, a regular review helps ensure that they align with the internal controls set forth in your policies to maintain a robust compliance program. By updating controls, you prove that you are following your response and remediation policy while also strengthening your compliance program.
Step 6: Continuously Document Program Improvement
Documentation provides assurance over your compliance with internal controls and external regulatory requirements. Documenting the risk process proves your program governance.
Step 7: Continuously Update Your Risk Profile
Since cybercriminals continuously evolve their methodologies and regulatory requirements cannot keep up with that, you need to maintain a strong compliance posture by continuously reviewing your systems and updating your risk profile as new threats emerge. Any time that you make a change to your systems, software, and networks, you need to review their potential impact and update your risk profile.
How ZenGRC Enables Companies to Improve Their Compliance Programs
ZenGRC provides a tracking system where organizations can log their compliance activities so that everyone knows what to do and when to do it so that you can more rapidly review the “to do” lists and “completed tasks” lists.
With our workflow tagging, you can monitor accountability and evaluate productivity over compliance program improvement by assigning tasks to the individuals in your organization responsible for the activities involved.
Finally, with our audit trail capabilities, you can establish a document management program that provides assurance over remediation activities to prove that you maintained data confidentiality, integrity, and availability as required by law.
For more information about how ZenGRC can streamline your GRC process, contact us for a demo today.