Common Control Framework: The Complete Implementation Guide

If you handle sensitive data, you might find yourself in the alphabet soup of regulations – SOC 2, GDPR, HIPAA, NIST, CCPA, ISO, and more. Some mandatory and others voluntary, but complying with multiple frameworks is a lot of work and often spirals into chaos unless you have a methodical approach to systematically manage it all. This is where a common control framework comes into play.

This article explains what a common control framework is; the principles behind it and how to set it up.

What is a common control framework?

A Common Control Framework (CCF) is an approach that helps organizations tackle the requirements of multiple compliance and regulatory frameworks by collecting, consolidating, and correlating overlapping controls. Also known as the Unified Compliance Framework (UCF), it provides a structured set of controls derived by harmonizing control measures from standards and regulations. 

This approach is closely related to the concept of compliance mapping, a practice adopted by organizations to comply with multiple frameworks by gathering all common requirements and implementing them once. Doing so helps organizations use a single and centralized method to avoid duplication, reduce time to audit-readiness, and minimize cost to compliance.

Benefits of a common control framework

A common compliance control framework streamlines compliance by standardizing controls across multiple regulations and frameworks. It reduces duplication of efforts, saves time, improves efficiency, and ensures consistent risk management. Lets understand these in detail: 

Audit optimization

Ideal for businesses where at least two or more frameworks are mandatory, audit optimization is the practice of conducting an assessment for a regulation once and reusing the evidence to prepare for audits. Essentially, you reuse the security controls that are required for all the applicable regulations. 

Cost optimization

Audit prepwork is expensive. From buying new tools, hiring auditors, and partnering with external consultants—all of this burns a large hole in your wallet. If you do all of it from scratch multiple times, the cost also multiplies. Mapping the common controls, collecting the evidence at once, and sharing it whenever required reduces the overall cost by a significant margin. 

Develop baseline controls 

Assessment optimization helps to create baseline controls on which organizations can build more robust controls. Adding to baseline controls as you grow and scale enables you to strengthen your posture and build a stronger security architecture. Once you have a baseline of controls to work with, building from scratch is no longer necessary. 

Eliminate assessment fatigue

Audit preparation involves a lot of manual activities. Depending on the number of frameworks, existing setup, and complexity of the IT infrastructure, the timeline may stretch into years. 

Unless you automate the end-to-end processes, your engineering or infosec team will work on the same set of questionnaires, writing similar policies and collecting evidence previously collected. A common control framework eliminates the number of back and forths 

Monitor controls & capture audit-grade evidence. See Sprinto in action. 

How to implement a common control framework?

Setting up a common controls framework requires you know the following before setting up the project:

Understand your requirements

Before implementing the common control framework, you should do some groundwork to know the intricacies of the environment. It starts by prioritizing the mandatory controls over the optional or voluntary ones.

Next, gather the common and overlapping requirements of the applicable frameworks. For example, both CCPA (California Consumer Privacy Act) and GDPR have a requirement for data breach notification. You can meet the requirements of both frameworks using a process to consolidate both into a single control. 

Understand your risk environment 

Mandatory controls always come first. Risk-based controls come next. This is the ideal order of control prioritization. Conduct a risk assessment to understand which controls add resilience to the posture. This will help you identify the risk of non compliance if you choose to ignore it.

For example, if you have to comply with data privacy frameworks like HIPAA or GDPR, an encryption related control should be prioritized to protect sensitive data over a control related to patching a software for vulnerabilities. 

Sprinto enables precise risk interpretation and assessment by integrating seamlessly with your cloud stack to quickly identify misconfigurations and vulnerabilities. Its comprehensive risk library and customizable risk register ensures you manage risks with accuracy. Stay updated as you grow, with actionable, real-time risk data based on trusted industry benchmarks. See Sprinto in action.

Choose controls with better specificity

In some cases, consolidating multiple requirements into a single control may have more intricacies. For instance, the breach notification requirement of GDPR and CCPA have a minor difference in specification that you have to figure out.

While GDPR clearly states the deadline of no more than 72 hours, CCPA’s vague deadline states “without unreasonable delay”. You need to work your way around the difference to meet this control requirement. Since GDPR offers better clarity, it is recommended to go with it to meet this control, rather than CCPA. 

Continuous monitoring

Risks and vulnerabilities don’t take a break and are continuously added into your infrastructure. The continuous exchange of information, adding new technologies, process changes, human errors, and poorly configured systems – all are risk factors. 

Continuous monitoring helps to identify gaps in real time and patch them before it becomes an incident. Moreover, it is a compulsory requirement for a number of regulations like PCI DSS, NIST, and ISO 27001. 

Avoid mapping uncertain controls 

An error of judgment infosec teams using the CCF make is working with the mindset of consolidating every control. While most controls can be grouped with other sets, some must be implemented independently. Forced control mapping in uncertain cases can cause a misalignment between the framework’s requirement and your control implementation. 

When you are unable to group certain controls, categorize them independently to ensure that each requirement is addressed sufficiently. This will help you prevent audit remarks due to possible misalignment and avoid incidents due to control failure. 

How Recruit CRM embraced compliance automation for seamless, multi-framework security audits

Evidence collection

Implementing the controls, policies, and is only half the work done. Regulations require you to ensure that these controls are functioning sufficiently enough to prevent incidents and auditors would cross check if it meets the regulatory expectations. 

Once you have identified the common controls across all frameworks, document the evidence from these sources and save it in one location to get a single source of truth. 

Sprinto connects control evidence across frameworks, eliminating the need for duplicate tests. Implement and test controls once to meet requirements for multiple frameworks like SOC 2 and ISO 27001. Boost capacity, handle more evidence requests, and save time effortlessly. Get a demo now. 

What is Secure Controls Framework? Is CCF based on SCF?

The Secure Controls Framework (SCF) is a meta framework that aims to help organizations operationalize cybersecurity and data privacy management by simplifying their controls. It is a straightforward, scalable, and holistic framework that offers a control set to address governance, risk, and compliance issues. 

The SCF control catalog consists of more than 100 data privacy and security laws, regulations, and frameworks. It normalizes and standardizes disparate control language and legal speech into a common and easy to understand language that can be used across frameworks and regulations. 

Download our control mapping sheet.

How Sprinto streamlines common control frameworks?

Preparing for an audit is a burdensome process, especially for you are doing everything from scratch, manually, and for the first time. Chances are, you are breaking processes and leaving a lot of room for error, ultimately leading to audit failure. 

Sprinto is an end-to -end compliance and audit management solution that integrates with your cloud setup to smartly assess the environment, gather all data for control requirements. It helps you: 

• Automatically map policies and controls to multiple compliance criteria based on your security frameworks
• Automates tests and validates security controls to track its effectiveness using intelligent automation 
• Implements controls and tests it to satisfy evidence requirements for multiple frameworks to save time and effort

Sprinto can do much more. Talk to our experts to learn how we help businesses like you. 

FAQs

What is the difference between UCF and SCF?

The Unified Compliance Framework (UCF) and the Secure Controls Framework (SCF) both streamline compliance, but differ in focus. UCF integrates over 1,000 global regulations and offers a compliance-centric approach to help organizations align with legal and regulatory requirements. SCF is security-focused, providing a comprehensive set of cybersecurity and privacy controls that map across multiple frameworks. While UCF emphasizes regulatory alignment, SCF concentrates on implementing robust security and privacy measures.

What is the common control concept?

The common control concept refers to the practice of using a single security or compliance control to meet the requirements of multiple regulatory frameworks or standards. Instead of implementing separate controls for each framework, organizations design and apply a control that satisfies the overlapping requirements of various frameworks, such as SOC 2, ISO 27001, or HIPAA. 

What are the four components of the compliance framework? 

The four key components of a compliance framework are policies, which set clear rules and expectations; procedures, outlining the steps to meet those rules; controls, which enforce and monitor compliance; and audits, which assess effectiveness and ensure continuous improvement.

What is an example of a common control framework?

An example of a common controls framework is the NIST Cybersecurity Framework (CSF). It provides a set of best practices and guidelines to help organizations manage and reduce cybersecurity risks. NIST CSF is widely adopted because it aligns with various regulations and industry standards, making it adaptable across sectors.