2. There are 7
Steps to
ImprovingYour
Company’s
Compliance
Program.
Step 1: Engage in an Annual Risk Analysis
Step 2: Update Policies at Least Annually
Step 3: Continuously Monitor to MonitorAccountability
Step 4: Review Mitigating Controls
Step 5: Engage in Continuous Response and
Remediation
Step 6: Continuously Document Program Improvement
Step 7: Continuously UpdateYour Risk Profile
3. Why to
Improve your
Company’s
Compliance
Program?
Improving a company’s compliance, specifically for financial
institutions, means revisiting and refining the original compliance
program. Functionally, improving compliance program means
reiterating the process, drilling down into the original risk analysis,
and integrating more specific documentation.
For example:When attempting to mature cybersecurity program,
then need to start with the risk analysis first. Regulatory
requirements and industry standards focus on risk-based models
which means that if risk analysis lacks specificity then overall
program will lack maturity.
From there, we 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, need to create a cycle of continuous monitoring,
responding, remediating, mitigating, and documenting to provide
assurance of governance.
4. Step 1: Engage
in anAnnual
RiskAnalysis
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.
5. Step 2:Update
Policies at
LeastAnnually
To mature the compliance program need documentation of the
processes, procedures and policies.
Creating policies provides auditors the information that they need
for understanding the internal control processes and align them
with cybersecurity regulations.
As data needs change, you need to ensure that your policies
reflect those changes.
6. 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 that is set forth in policies
may no longer be adequate.
7. Step 4: Review
Mitigating
Controls
Mitigating controls protect you from cybercriminals while also
providing assurance over compliance program.
As threats evolve, mitigating controls may need to evolve.
Regular review helps ensure that they align with the internal
controls set forth in policies to maintain a robust compliance
program.
Updating controls, proves that organization following response
and remediation policy that strengthening the compliance
program.
8. Step 5: Engage
inContinuous
Response and
Remediation
Need to respond & remediate the new emerged threat.
Find new risks to data environment by continuous monitoring
Continuously respond & remediate the new risk that arises as a
result of monitoring program.
10. Step 7:
Continuously
UpdateYour
Risk Profile
Since cybercriminals continuously evolve their methodologies and
regulatory requirements cannot keep up with that, so need to
maintain a strong compliance posture by continuously reviewing
systems and updating risk profile as new threats emerge.
Whenever make a change to systems, software, and networks,
then need to review their potential impact and update risk profile.
