How You Can Build a Rock-Solid Compliance Program in 7 Easy Steps

Cyber attacks are up a staggering 221% across all industries compared to 2022. 

Given the average cost of a data breach in 2023 was $4.45 million, we owe it to our organizations to take these matters seriously.

The best way to strengthen your security posture is to implement a solid compliance program. By bundling security and compliance services, you can not only ensure you’re meeting regulatory requirements but also validate the security steps being taken to fulfill those controls.

This brief guide will cover everything you need to know about the basic components of a compliance program. It will be particularly helpful to anyone new to (or brushing up on) compliance, whether you’re part of an in-house IT team or a security provider managing compliance for your customers.

By the time you’re done reading this, you’ll understand what a compliance program is, the seven key components of a good program, and actionable steps to create your own plan.

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Key Takeaways

• A compliance program is a unified set of cybersecurity practices bundled as a single overarching system to simplify the process of meeting legal and regulatory requirements.
• Cyber compliance and an effective program can help prevent and mitigate the impact of cyberattacks.
• The seven elements of an effective compliance program are: 
  • Risk Assessment - Identify the risks that could potentially harm your organization, focusing on those specific to your business or industry.
  • Controls - Set up controls, based on the framework(s) you follow, to mitigate your identified risks. If using multiple frameworks, consider framework crosswalking to consolidate controls and avoid duplicate work.
  • Gap Assessments & Vendor Risk Management - Identify where your organization or third-party vendors fall short of security standards.
  • Policies & Procedures - Provide an overview of the expectations and standards to which your organization commits, with step-by-step instructions to guide implementation.
  • Communication & Reporting - Establish clear communication and reporting practices to build awareness, trust, and accountability.
  • Monitoring & Auditing - Continuously review and reassess your security posture, and perform regular audits. 
  • Response & Remediation - Implement an actionable incident response plan to contain, investigate, remediate, and continuously improve following an incident.
• Follow a policy template, plan template, or checklist to more easily build your compliance program.

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What Is a Compliance Program?

A cybersecurity compliance program is a single overarching system that covers a wide range of compliance areas under a unified program to ensure legal and regulatory requirements are met.

Establishing this singular system makes it easy to stay compliant consistently, especially across departments. While there are different compliance domains, such as data privacy and security, they all work together to drive a singular compliance program.

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Is a compliance program the same as a compliance framework?

Here’s an important distinction: compliance programs are different from compliance frameworks. 

A comprehensive and enterprise-wide compliance program covers the organization’s overall compliance plan.

Compliance frameworks, such as Health Insurance Portability and Accountability Act (HIPAA) or the European Union’s General Data Protection Regulation (GDPR), are a specific set of rules, controls, and policies for maintaining compliance with regulatory requirements. 

For example, ISO 27001 is the international standard for establishing, implementing, and sustaining an Information Security Management System (ISMS). ISO 27001 may be one aspect of your compliance program. But the framework alone isn’t a comprehensive system.

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Why Compliance Is So Important

92% of IT leaders agree that cyberattacks are on the rise. And an even higher percentage believe these attacks are growing in sophistication.

According to an aptly titled “35 Cybersecurity Statistics to Lose Sleep Over in 2024” article (we read it so you don’t have to), the annual cost of cyber attacks is predicted to reach $23 trillion by 2027.

These stats aren’t meant to scare you but to give you some perspective on why protecting against attacks is important. 

You can prevent breaches and set your organization up for success by getting and staying compliant. But compliance also has the added benefit of building trust with customers and investors by demonstrating a measured commitment to mitigating risk. 

The repercussions of an attack include:

• Cost of the breach
• Loss of customer and shareholder trust
• Customer identity theft
• Lawsuits, legal fees, settlements
• Hefty fees and penalties for lack of compliance
• Downtime and revenue loss
• Ongoing investigations
• Loss of customers

Cybersecurity compliance works to protect your organization from these attacks. It does this through specific standards, procedures, guidelines, and best practices for securing your systems and data. 

Compliance programs pull everything together so you can ensure continuous compliance with the most relevant industry standards. 

So, how do you create an effective compliance program tailored to your organization?

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The 7 Elements of an Effective Compliance Program

The following seven elements are the foundation for building a robust security compliance program for the clients or organization you serve, regardless of size or industry.

If you get each of these components right, you’ll have a solid system in place to meet regulatory requirements and protect against attacks.

Before building out your compliance program, it’s crucial to ensure you have buy-in from upper management. Without this buy-in, your program could fail, perhaps due to insufficient funding, poor prioritization, or an overall lack of commitment from higher-ups.  

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1. Risk Assessment

Before diving into what you can do to mitigate risks, you must clearly define those risks by conducting a risk assessment. 

Keep in mind that a risk is anything that could potentially harm the organization, such as a phishing attack or a data breach. 

Focus on risks that are specific to the organization and industry. For example, healthcare companies store sensitive patient information, so they need to guard against patient data breaches, medical device hacking, and healthcare compliance failures.

IT companies have to guard their software, firmware, and hardware, as well as protect their valuable intellectual property. Their risks include cloud security breaches, IP theft, and zero-day exploits. 

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Actionable steps for conducting risk assessments:

First, don’t worry — this isn’t a task you have to tackle alone. You can leverage both internal and external resources to build a comprehensive risk assessment plan. This is a common practice since many companies don’t have the internal resources or expertise for this kind of project. 

In fact, many organizations will partner closely with Managed Security Service Providers (MSSPs) that can provide support, expertise, manpower, and essentially work as an extension of the team to help manage compliance.

Another way to streamline this process is to work with compliance tools and technology to:

• Automate your assessments.
• Integrate with your existing systems.
• Get real-time visibility into risks and controls.
• Create a single source of truth for compliance information.
• Increase transparency and visibility.
• Reduce tedious, manual work.

After you conduct an initial risk assessment, you can set up a quarterly and yearly occurrence, with the latter being a more comprehensive assessment. 

However, compliance should not be seen as something to be achieved through occasional assessments but rather as an ongoing process. With continuous compliance, you can transform check-the-box exercises into a constant state of improvement and scoring.. This way, you can track compliance around the clock, with real-time visibility if using a compliance platform.

For security providers, continuous compliance can also turn one-off projects into long-term client relationships, increasing recurring revenue, margins, and customer retention.

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2. Creating Controls

So, you’ve performed a risk assessment and identified potential threats. To mitigate these risks, you’ll set up controls. Controls are the action plans you put in place to safeguard the organization from risks. For example, if the risk is that someone might break into your home, the corresponding controls would be locks, alarms, and security cameras.

Selecting a compliance framework can give structure to your risks and controls. For example, the ISO 27001 framework’s Annex A has a list of 93 controls across four categories. Each control corresponds to a specific risk, and the list format makes it easy to reference when building out your program. 

So, for the listed risk of data loss or interruption (Information Backup, Annex A 1.83),  the control is as follows: “Backup copies of information, software and systems shall be maintained and regularly tested in accordance with the agreed topic-specific policy on backup.”

Or you could pursue ISO 27001 certification, which is a clear-cut way to solidify your overall program.

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Actionable steps for creating controls:

Use a framework either as a reference or to pursue certification. Just note that certification could be a long, entailed process. However, it does provide a highly structured approach that you can validate through an external body.

Also, keep in mind that your risks and controls should be linked to business goals. This crucial step ensures that your compliance efforts are designed to support your organization’s strategic objectives, such as protecting intellectual property or building customer trust.

If you’re managing multiple frameworks, consider consolidating them into a unified set mapped to relevant frameworks. This framework crosswalking approach will help you avoid unnecessary steps and duplicate work.

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3. Gap Assessment and Vendor Risk Management

Once you’ve conducted a risk assessment and set up controls, you can look at the security program holistically. 

The idea of a gap assessment is to compare your existing program against best practices or a specific compliance framework to identify gaps. In other words, you’re examining your program to see where it falls short of security standards. By understanding the deficiencies in your program, you can adjust your compliance practices to bridge those gaps and strengthen your overall program. 

Alongside this gap assessment, you can create a vendor risk management process, which is the protocol for vetting third parties that do business with the organization. Your process should include a vendor risk analysis in which you thoroughly examine every relevant risk. Unlike the risk assessment you run for your own organization or the client you manage, the controls are a little different in that, with vendor risk assessment, you’re communicating security expectations for the vendor. 

You can set these expectations by creating contractual requirements such as specific frameworks, a regular audit process, and controls that need to be in place based on their risks. After all, if an incident occurs in your organization because of a third-party breach, you’ll still be held accountable. 

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Actionable steps for conducting gap and vendor risk assessments:

When conducting your gap assessment, start with the scope and objectives, then decide which frameworks or standards to evaluate your program against. As always, be sure to document every potential gap or discrepancy where the program does not align with standards.

You can then create your action plan with a clear remediation process to address and correct gaps, starting with those with the biggest potential impact. 

For example, maybe you’ve found outdated security policies and decided they are high-priority items. One recommended action might be to review and update every security policy. Using a compliance platform can simplify the process by bringing everything together in one place and making it easy to assign tasks and set priorities. In fact, some platforms will handle the heavy lifting of gap assessments for you by automating the process. 

Likewise, you could use a compliance platform to streamline the vendor assessment process by creating vendor questionnaires in minutes, getting faster responses, and keeping track of everything in a centralized system.

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4. Policies and Procedures

The next step is implementing policies and procedures for the organization. You should make these accessible and as clear, concise, and comprehensive as possible. 

Policies provide an overview of the expectations and standards to which the organization commits. Procedures are step-by-step instructions to guide implementation.

You’ll want to cover the expected conduct of staff, mechanisms for reporting, and the consequences of lack of compliance. Yes, there must be disciplinary action for lack of employee compliance. Your organization’s compliance success hinges on their conduct.

A compliance program only works if staff can understand and implement it. That’s why regular education on the program is typically suggested to help everyone (senior leadership included) grasp their role in maintaining compliance.  

You should develop a variety of detailed yet accessible training materials. For example, you can put together online courses, manuals, workbooks, workshops, and more.

Actionable steps for policy and procedure implementation:

If it helps, break down your policies into key areas. You’ll have sections for data protection, employee conduct, and incident response, for example. 

Don’t forget that this isn’t set in stone. As you observe the implementation phase, you can continue to tweak your procedures to reflect changes in regulations or business practices.

As for employee discipline, keep in mind that you can work with managers in their departments to determine fair and reasonable consequences for non-compliance. Just make sure the consequences are clearly communicated, documented, and accessible. 

In addition to initial training for new employees, make sure you also schedule ongoing education for current staff. Try to keep the materials varied for improved engagement. 

Unsure if your training materials are working? Implement a feedback system or include quizzes to ensure everyone understands the material. 

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5. Communication & Reporting

Transparency is the key to compliance success, and good communication — along with the right reporting system — make that possible. 

Compliance management can only be successful if everybody is kept in the loop, including staff, senior leadership, and stakeholders. Again, compliance is not something you set up once and forget. Regulations change, and so do security threats, policies, and procedures. If any updates are made to your security program, they need to be clearly communicated to promote awareness and build internal trust.

Of equal importance is the ability for any employee to anonymously report potential compliance issues. This is a huge deal and one of the few ways to detect issues early and ensure accountability. 

This process must be anonymous to protect the reporter and reduce fear of retaliation. Plus, by keeping it anonymous, you’ll see increased reporting rates and find out about issues you would never hear about via regular channels.

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Actionable steps for effective communication:

Again, reminding employees to report potential issues should be consistent and encouraging. This should come from both the organization and managers. 

A technology platform could simplify reporting. It would not only be user-friendly (and available through multiple channels such as web or mobile app) but also protect the user’s identity, promptly submit the report to management, and create an action item for management to address. 

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6. Monitoring and Auditing

Maintaining your compliance program requires a strong system of monitoring and reassessing the organization’s security posture. There is always room to review the compliance program and make potential improvements as you go. 

You may find that some policies or procedures need major or minor adjustments, and you should  document the process for updating them. 

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Actionable steps for monitoring:

Schedule ongoing internal audits of the compliance program. This is a great stage to leverage automated compliance monitoring and auditing tools to simplify the process. 

And with real-time insights, tools and technology might catch things that staff won’t. As always, be sure to document every finding.

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7. Response and Remediation

Finally, make sure you have procedures in place to respond to compliance issues. In case of a breach or other incident, you need to ensure the response is swift and effective. This procedure might look like this:

• Containment - This is the first step in responding to an incident. Your goal here is to limit the impact of the breach and reduce damage as much as possible. Three things you might do here are isolate the affected systems, suspend related operations, and notify stakeholders as soon as possible.
• Investigation - Knowing what caused the incident is critical for learning from it and identifying how you can correct it. You can put together a team to investigate (legal, compliance, IT, third-parties, etc.), and they can work with you to analyze the evidence, conduct interviews, and report findings.
• Remediation - Building off the above two steps, you can create a remediation plan with actionable steps to correct the compliance issue and prevent it from happening in the future. This plan will combine corrective and preventative measures as well as how you plan to communicate with and update stakeholders on the situation.
• Continuous improvement - As is a common theme, you need to ensure continuous compliance. To do this, part of your response plan should include regular reviews and updates built on regular audits and feedback (including the ability for staff to report possible compliance issues).

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Actionable steps for incident response:

Your incident response plan should be clear and actionable. Everybody should know their role ahead of time so they can act fast if an incident occurs. Consider running regular drills so everybody is prepared. It’s important to treat each incident (or drill) as a learning opportunity for the future.

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Building Your Compliance Program and Next Steps

Yes, it sounds like a lot. But if you tackle each piece one by one, following the action steps we’ve provided, you can build an effective compliance program tailored to your client or organization. 

Before you know it, you’ll be able to get and stay compliant and even prevent future security incidents. 

For additional guidance building a compliance program, check out our templates page for policy and plan templates as well as useful checklists. 

Interested in exploring a compliance platform to simplify the process of building and running a compliance program? Learn how Apptega can help with a program tailored to your needs.