In today’s highly regulated business landscape, compliance has become a critical aspect of product development and deployment. Adhering to various compliance standards not only helps a company avoid fines and penalties but also ensures trust and confidence among customers and stakeholders. To effectively plan for compliance, organizations must understand the what, why, and how of compliance, relevant frameworks and identify the ones that best align with their needs.
On a fundamental level, compliance can be considered as following a rulebook. Compliance means essentially adhering to a set of directives put in place by governing bodies or industry standards. Compliance isn’t just a bureaucratic hurdle; it’s the cornerstone of a robust and ethical business framework. It ensures your product operates legally, ethically, and securely, safeguarding your company and its users.
From the definition, compliance looks like a negative investment, and the C suite might wonder, why bother? While achieving and maintaining compliance can be resource-intensive, requiring dedicated efforts in terms of time, personnel, and financial investments, there are overarching benefits:
No matter which compliance framework an organization opts for, the fundamental components remain the same and must be integrated into the organization’s culture:
Leadership sets the tone for the entire organization. When top executives not only endorse but actively participate in compliance initiatives, it enforces the message throughout the company. Leadership buy-in ensures that compliance is not perceived as a mere checkbox exercise but as a fundamental aspect of the company’s values. It fosters a culture where adherence to standards becomes ingrained in everyday operations.
Open and effective communication channels are vital for the success of compliance initiatives. This includes mechanisms for reporting incidents, sharing updates on security measures, and creating an environment where employees feel comfortable expressing security concerns.
Transparent communication also ensures that everyone in the organization knows the importance of compliance. It facilitates the flow of information, allowing for quick responses to emerging threats and fostering a culture of collective responsibility.
Regular training and awareness programs are crucial for educating employees about compliance requirements, security best practices, and the latest threats. This component aims to empower the workforce with the knowledge to contribute actively to the organization’s security posture.
Knowledgeable employees are the first line of defense against potential security and regulatory risks. Training and awareness programs not only enhance individual capabilities but also contribute to building a proactive and vigilant workforce.
Compliance is not a static state; it’s a journey of continuous improvement. Regular assessments, feedback loops, and adaptability to changing threat landscapes ensure the compliance framework evolves alongside emerging risks.
Continuous improvement is key to staying ahead of evolving threats and maintaining a resilient security posture. It demonstrates a commitment to staying current with industry standards and best practices.
There are various categories of compliances, and few may fall under more than one category. Here are the common verticals:
They are established by national and regional governing bodies to ensure safety, security, risk management, and fair practices, but they carry unique sets of laws and regulations to address an industry’s particular challenges and concerns. For instance:
They focus on safeguarding personal and sensitive information, usually dictating how organizations collect, process, store, and share data, emphasizing the protection of individuals’ privacy. For Example:
These are voluntary but industry-recognized standards that organizations can implement to demonstrate their commitment to specific principles or practices like product quality, interoperability, and security. Examples include:
They focus on meeting regulations related to environmental protection and sustainable business practices. This includes measures to reduce carbon footprint, waste management, and energy conservation, like:
There are specific requirements outlined in contracts between organizations. They ensure adherence to agreed-upon terms and conditions. For instance:
This category involves the policies and procedures that are established within an organization to ensure adherence to company-specific ethical guidelines and best practices, like:
A misaligned compliance framework can cause issues because while on one side, there is a waste of resources, finances, and efforts, there is also a negative throughput or risk of lapse of the program due to mismatched requirements. Identifying the right compliance framework for a company involves systematically evaluating various factors, considering the industry, nature of operations, and applicable regulations. Some of the common factors are:
For instance, consider the Family Educational Rights and Privacy Act (FERPA) as a specific compliance framework if you deal with educational records. If your company processes credit card transactions, the Payment Card Industry Data Security Standard (PCI DSS) is crucial to ensure compliance.
If innovation and flexibility are key business goals, consider ISO 27001 for information security management, known for its adaptable approach.
Depending on your customer base, region-specific compliance may be necessary. For example, A European client may require adherence to the General Data Protection Regulation (GDPR), while a Texas-based client may need TX-RAMP.
If you’re a B2B organization with a cloud ecosystem, SOC 2 may help you gain customer confidence. InfraCloud security engineers help clients achieve SOC 2 certification.
If your company deals extensively with health data, consider HIPAA compliance for healthcare information protection.
If the company already adheres to, say, ISO 9001 for quality management, expanding to ISO 27001 for information security management may be a logical step.
For smaller companies with limited resources, adapting to the CIS benchmark or NIST CSF 2.0 framework can be a good starting point to lay down security best practices. When you wish to achieve multiple certifications, focus on the underlying framework it is based on. For example, NIST-SP 800-53 can be adopted by mature teams aiming for ISO, SOC 2, and StateRamp in the pipeline.
Below is a brief flowchart to help you navigate these steps.
Once a compliance framework is identified and finalized, the next step is to plan the implementation, which typically involves several stages, from listing the necessary controls to defining roles and responsibilities and creating an improvement and monitoring plan. Each stage is critical for establishing and maintaining a robust compliance program. Regardless of which framework you opt for, below is the key, high-level structure.
The first step would be scoping the specific control requirements for the chosen framework. Each compliance framework has a set of controls and best practices that must be implemented to achieve compliance. Review the latest revision of the framework and identify the controls that apply to the product.
Objective: Define the specific control requirements and measures required to achieve compliance with the selected framework.
Activities:
Suggested platforms: CIS Critical Security Controls® v8, NIST SP 800- 53, NIST CSF 2.0
To ensure the successful implementation of compliance controls, it’s essential to define clear roles and responsibilities within your organization. Identify the individuals or teams responsible for implementing and maintaining each control. This ensures accountability and facilitates effective coordination during the compliance implementation process.
Objective: Clarify and allocate roles and responsibilities for compliance management throughout the organization.
Activities:
After listing the compliance control requirements, conduct a gap analysis to identify any missed controls or areas where your organization currently falls short. This analysis helps you understand the gaps between your existing practices and the required controls. It enables you to prioritize and plan for the implementation of missed controls. Gap analysis can be a manual process by conducting interviews with all relevant teams, or it can be partly automated using compliance management platforms available in the market.
Objective 2: Identify the gaps between current practices and the required controls outlined in the chosen compliance framework.
Activity: Conduct a thorough gap analysis in three verticals:
Suggested tools:
Develop a comprehensive implementation plan that outlines the specific tasks, timelines, and milestones for each control. A well-defined plan helps track progress and ensures that compliance activities are executed in a systematic and organized manner.
Objective: Develop a detailed plan outlining the steps and timeline for implementing the identified compliance controls. The plan should include resource allocation and training requirements and address any dependencies for successful implementation.
Activities:
Suggested tools: Asana, Jira, Azure Boards, Linear, Trello
Regularly monitor the effectiveness of your compliance controls through metrics and audits. Establish key performance indicators (KPIs) to measure the performance and impact of your compliance efforts. Conduct periodic internal audits to assess the effectiveness of controls, identify areas for improvement, and ensure ongoing compliance.
Objective: Implement ongoing monitoring processes to ensure that compliance controls are consistently maintained.
Activities:
Establish Key Performance Indicators (KPIs) for compliance.
Suggested tools: OpenSCAP, Drata, Vanta, Sprinto, Wiz, Secureframe, Cavirin
Once you are satisfied with the results of internal audits of the controls, you can opt for external audits for the compliance frameworks you’ve implemented. Always double-check that the auditor you choose is accredited by the certification body. Additionally, while you may have reached 100% compliance against controls on your internal scale, there is a fair chance of deviations in what you have implemented versus what the auditor expects, sometimes in the terms of extent to which a control should be adhered, or just the way the control was inferred. Such variations are normal and to be expected in external assessments. You can work with the auditor to patch the remaining gaps and go for a second round of verification. Post the assessment is completed by the corresponding third party, you can expect the certification depending on the timeline shared.
Objective: Engage with the selected external auditor to assess and certify the organization’s compliance.
Activities:
These stages are cyclical in nature because every compliance framework requires a periodic evaluation. This structure can be used as a baseline and customized variations of the stages can be prepared with automation wherever feasible.
Irrespective of the framework chosen or the target compliance there are some best practices to adhere to make compliance certificates easier with time.
Governance Risk and Compliance (GRC)
Identity and Access Management:
Data security:
Automate, shift left, and collaborate cross-functionally to have a joint, dedicated team for:
Role-based training:
Understanding the relevant compliance frameworks, identifying the ones that align with your product needs, and following a systematic implementation approach, you can ensure regulatory adherence and build trust among customers and stakeholders.
However, this is not a one-time solution. Remember to continuously monitor and evaluate your compliance efforts, seek certifications when appropriate, and adapt to evolving regulatory requirements. By prioritizing compliance and embedding it into your product development lifecycle, you can achieve a strong compliance strategy that promotes security, privacy, and trust.
Thank you for reading this blog post, and hope it will help you wear your compliance hat and plan your company compliance program. I would love to hear your thoughts on this post, so start a conversation on LinkedIn. Looking for help with securing your infrastructure or want to outsource DevSecOps to the experts? Learn why so many startups & enterprises consider us as one of the best DevSecOps consulting & services companies.