How Effective Policies and Procedures Can Keep Your Organization Secure
Hunter Barrat, Strategy & Risk Project Manager and Technical Writer
We also undergo the annual continuous monitoring process, so we understand these challenges and can help you work through them.
Many organizations lack effective security-related policies and procedures (P&Ps). But if your organization creates, stores, or transmits sensitive or regulated data, you don’t have a choice, especially if you need to show compliance for your industry-specific audits. Assessors won’t be satisfied with informal processes or institutional knowledge; as the saying goes, “If it is not on paper, it never happened.” A.I. can be a useful tool to draft or refine what you have in place, but don’t rely on artificial intelligence to substitute for real intelligence. Auditors will require proof your P&Ps reflect your real practices.
First, some definitions.
Policies are specific statements that should reflect your organization’s business priorities. They also describe the standards or the rules your organization and/or designated staff must follow to be compliant with a requirement and align with regulatory standards. .0.0
Procedures describe the steps your organization and/or designated staff will take to be compliant with the policy. In general, they should follow the “hit by a bus” standard: if the key person responsible for a task isn’t available, the procedure should be detailed enough that someone else can assume those responsibilities without any business disruption.
Developing P&Ps can be time consuming, and A.I. can help polish language, search your documentation for evidence, and remind you of areas that need annual updates. But you still need to verify what A.I. creates. And this gives you the chance to address possible weaknesses in your organization’s strategic security-related planning, prompting corporate leaders to consider how best to remediate these shortcomings—both to pass the audit, and more importantly, to protect your organization and the data you hold from a wide range of threats, both internal and external.
Five Steps to Strong P&Ps
- Tailor policy statements to your organization. Restating the control won’t be enough to pass. It’s a good place to start, but you will need to include specifics about how each P&P is implemented and by whom, and translate the policy into actionable steps that your organization follows and will continue to follow.
- Define the scope, purpose, and objectives. Clarify what the policy is designed to protect, and align objectives both with your business goals and your industry’s regulatory requirements.
- Select a relevant framework to guide your efforts. Frameworks such as NIST SP 800-53 Rev. 5 provide best practices across 20 security and privacy control families. Policies built on these standards often map well to other industry requirements.
- Train staff so they understand and acknowledge the P&Ps. Auditors will ask your staff to demonstrate familiarity with P&Ps. Several, including those related to security training, incidents, compliance testing, and response, require annual staff training with documented attendance.
- This is not a one-and-done task. You must update P&Ps annually or after incidents, technology changes, or evolving threats. Auditors look for review tables and evidence of continuous improvement.
We Can Help!
If you don’t have the staff to create or formalize your P&Ps, consider hiring a third-party advisor. CISO Global is a compliance risk management firm and a third-party assessment organization. And as a cloud service provider, we also undergo the annual continuous monitoring process, so we understand these challenges and can help you work through them. Our security experts have decades of experience in helping our clients prepare P&Ps. This includes:
- Interviewing staff to formalize institutional knowledge and define roles and responsibilities
- Reviewing your asset inventories to identify end-of-life software, gaps in patching schedules, and other vulnerabilities
- Conducting table top exercises to help with incident response and contingency planning.
We use TiGRIS, our FedRAMP-authorized GRC tool, as a centralized evidence library to organize all the documentation that supports your P&P development and maintenance. This simplifies, updates, and ensures you are prepared to satisfy your audit and compliance requirements.
Effective P&Ps are essential both for passing audits and ensuring you protect your organization’s and clients’ data.
Ready to get started? Let’s talk.