This article provides 10 steps for IT policy compliance who work hard to find things their organisation forgot to do. IT policy compliance is the implementation and management of information technology in accordance with accepted standards. Using the right approach can help a company manage its IT policy compliance in order to reduce operational risks and protect valuable data.
1. Remember that IT compliance is about people, processes and technology. Many companies put too much emphasis on the technology and end up failing audits due to their lack of attention on people and processes. While IT makes this compliance ecosystem more complicated, using the right approach can help a company to automate its controls and controls monitoring.
2. Understand the Importance of IT in policy compliance. Compliance is about conformity with accepted standards. Usually, this means obeying laws and regulations that apply to your business. IT is so important in policy compliance because of the crucial part it plays in the operation of modern businesses, and compliance often relates to the way your organisation uses IT. IT compliance is the implementation and management of IT in accordance with accepted standards. This includes technical standards, and how people use that technology in the course of business operations.
3. Determine the Relevant Laws and Regulations. Laws and regulations articulate the ‘policies’ governing their requirements. You can’t begin the process of policy compliance without knowing which laws and regulations apply to your company.
4. Ascertain What Controls Apply to the Laws and Regulations. Controls are the technical and process-oriented means to comply with policy. Controls are specified by various government and industry standards, such as Control Objectives for Information and Related IT (COBIT), National Institute of Standards and Technology (NIST), International Standards Organisation (ISO), and the Payment Card Industry Data Security Standard (PCI DSS). As with laws and regulations, compliance requires that you determine which controls apply to your organisation.
5. Align IT policy compliance and Security with the Business. Aligning compliance with business entails understanding your organisation’s culture. Is it highly process-driven, or does it have more of an ad-hoc, chaotic way of doing things? If it’s the former, issuing detailed policies may be adequate for ensuring compliance. But if it’s the latter case (a common situation!), you need controls that are preventative and detective in nature. Your controls should address the specific business risks related to policy. Executives buy in more when you can speak their language of business. Doing this also helps auditors to understand the reasons why your organisation deployed particular controls, or perhaps decided to accept certain levels of risk.
6. Understand Your IT Environment. Your IT environment directly affects the design of your policy compliance program.
7. Establish Accountability. IT policy compliance programs don’t work without accountability. Accountability involves the definition of organisational roles and responsibilities — which set out what assets an individual is responsible for protecting and who has authority to make decisions.
Accountability starts at the top with executives; you stand a better chance of their active involvement by casting IT policy compliance in terms of business risks rather than technology.
Prioritize Remediation of Vulnerabilities and Audit Issues. Remediation is a critical activity that must be planned and executed in a manner that is logical, repeatable, and defendable to auditors. Start with the business-critical risks and exposures; address all previous audit findings; look for any instance where one fix can address multiple control weaknesses or findings; and go after the low-hanging fruit first!
9. Use Automation for IT Policy Compliance. Your IT assets are continuously evolving and growing in number. For internal auditors to review more than a small sampling of user accounts or system configuration settings on a periodic basis is practically impossible. Automation is the only reasonable way to assure that you evaluate an adequate number of systems on a regular basis.
10. Monitor your IT policy compliance program Regularly. Re-stating the Big Picture: Regularly check the “sanity” of your IT policy compliance program to make sure that controls are appropriate and risk based. They must make financial sense to the business. Establish your justifications before auditors arrive, and don’t be afraid to share the business context with them should questions arise about a particular control. The presence of your automated IT policy compliance controls with well reasoned business context for each one will help ensure that your company passes the audit — and viably enforce IT policy compliance throughout the organisation.
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