Corporate Compliance Program 101: How to Build One
Anwita
Nov 04, 2024If you’re considering building a corporate compliance program, it’s likely driven by a few key factors. Perhaps a prospect has requested proof of your company’s ethics and security standards. Maybe regulatory requirements apply based on the services you provide, or you simply want to elevate your organization’s culture, ethics, and security practices.
Whatever the motivation, building a compliance program is no easy task. But before you dive in, it’s essential to grasp the fundamentals: what it takes to create a robust, effective compliance program.
TLDR
A corporate compliance program ensures legal adherence and ethical conduct, reduces risks, protects the company’s reputation, and helps to minimize security breaches.
Some widely recognized and commonly adopted compliance frameworks include SOC 2, ISO 27001, GDPR, NIST CSF, and HIPAA.
An effective compliance program should include IT policies, risk assessment plans, employee training modules, the right controls, and a system to collect evidence.
What is a corporate compliance program?
A corporate compliance program is a plan composed of policies, processes, and individuals, that aims to meet regulatory and legal obligations. The purpose of corporate compliance programs is to minimize security breaches, avoid penalties due to noncompliance, ensure ethical behavior, and mitigate operational risks.
“Compliance can be fun. The biggest discussion always is that compliance is only a checklist. Yeah, if you make checklists out of it, sure. But if you understand how to analyze risks and what needs to be done from a security perspective, then it is fun because the expert tries to go deeper and understand which controls help mitigate the risk.”
Fabian Weber (vCISO and ISO 27001 auditor) in discussion with Sprinto
Why should you develop a corporate compliance program?
A corporate compliance program is important because it helps to adhere to legal standards, reduce risks, and prevent security mishaps. It fosters a culture of ethical conduct, protects the organization’s reputation, and helps you:
Minimize breaches
Security incidents result in financial loss, business downtimes, leakage of sensitive data, and loss of reputation.
When you adopt a regulatory framework designed to strengthen your security posture, it adds resilience to the defense capabilities. This approach ensures that systems not only minimize the likelihood of incidents but also mitigate the damage from any breaches that occur.
Avoid penalties
Noncompliance can result in two types of penalties.
The first includes legal penalties. If compulsory regulations like PCI DSS, HIPAA, or GDPR are applicable to your business, noncompliance or a breach incident can result in penalties – the range of which depends on the severity of the breach.
The second type is a consequence – when you don’t comply with industry standards and best practices, the resilience of the infrastructure takes a hit. Poor resilience opens up a pandora’s box of vulnerabilities, which is the ticking bomb for security breaches. According to a study conducted by Ponemon Institute, the cost of a data breach is increasing every year.
To earn trust
This is more of an indirect impact that can hit your goals in the long term. If you offer a service that processes sensitive customer data, prospects are likely to ask you to demonstrate proof that they are partnering with a business that is capable of handling their data without compromises.
When you comply with an industry-accepted standard that is globally recognized, it helps your sales team close deals faster and quickly onboard customers. Noncompliance gives your prospects the opportunity to partner with a competitor.
Compliance program to look into: common frameworks explained
Compliance programs are unique to each organization and depend on factors like risk profile, primary location of operation, type of service, data processes, and more. Here are some common compliance frameworks that offer best practices and guidance to build a program:
Compliance framework | Who is it for | Framework structure | Certification/compliance process |
SOC 2 | Service providers, especially SaaS companies handling sensitive customer data who want to demonstrate strong security practices to new prospects. | Secures data based on five Trust Service Criteria (TSC) or principles; security, availability, processing integrity, confidentiality, and privacy. These five principles are further divided into 64 requirements. Businesses have to implement security measures to meet these requirements. | Define scope by identifying the applicable TSCs Identify the scope of the report (Type 1 or 2) Conduct an internal assessment Conduct a gap analysis and remediate based on the results Implement controls and evaluate their effectiveness Undergo readiness assessment Get a certified auditor to assess your posture and generate a report |
ISO 27001 | Businesses of all sizes that want to establish or improve their ISMS (information security management system). | Comprises two parts – clauses and controls. The scope includes Scope Normative references Definitions Context of the Organisation Leadership Planning Support Operation Performance evaluation Improvement The controls are mentioned in Annex A. There are 114 controls under 14 domains. | Plan your certification process Define ISMS scope Conduct a risk assessment Build a security framework for implementation Implement the plan Evaluate performanceInternal audit Get your systems audited Implement a continual improvement process |
GDPR | Businesses processing personally identifiable data (PII) of EU residents. This applies irrespective of where the business is located. | 99 articles under 11 chapters. The chapters are: General provisions Principles Rights of the data subject Controller and processor Transfers of personal data to third countries or international organizations Independent supervisory authorities Cooperation and consistency Remedies, liability and penalties Provisions relating to specific processing situations Delegated acts and implementing acts Final Provisions | GDPR certification is issued by The EUGDPR Institute and The Information Security Institute by Copenhagen Compliance and their approved partners. The process involves: Create a readiness plan of action Understand how data flows in your business Develop policies and training based on your data flow Hire or assign a DPO and give them ownership |
HIPAA | Covered entities in the healthcare sector include healthcare providers, insurers, and business associates who process, store, or handle protected health information (PHI). | The act consists of five titles, out of which the second title (Administrative Simplification) details the compliance requirements for BAs and CEs. It has five rules: Privacy ruleSecurity ruleTransactions and Code Sets ruleUnique Identifiers ruleEnforcement rule | There is no such thing as a HIPAA certification recognized by the enforcing body (HHS). However, businesses can get their systems and practices audited by third-party services. The process involves: Select and security and privacy officer Establish privacy policies and security procedures to protect PHI Create a Business Associate Agreement with vendors Train your employees Conduct risk assessment Develop a breach notification protocol |
Key elements of a corporate compliance program
To create a robust compliance program, the following elements are a must have:
- Standards, policies, and procedures outlining the legal and ethical obligations.
- Oversight and responsibility to oversee the project from start to finish.
- Training and education to ensure that employees and stakeholders are aware of their roles to maintain compliance.
- Monitoring and auditing to identify, detect, and remediate non compliance issues on time.
- Continuous improvement to learn from previous incidents, adapt to changing regulations, and add resilience to the program.
How to develop and monitor the compliance program
A robust compliance program should have custom policies, be audited internally, have an employee training program, and have the right controls in place. Let’s understand them in detail:
Policies
To implement an effective compliance program, you must develop guardrails around the operations. Compliance policies are documents detailing how individuals interact with systems and assets. It is a high-level reflection of your company’s values, and ethics, and aligned with the goals. Policies should have a buy-in from all internal and external stakeholders.
Internal audits
The goal of developing a compliance program is to meet the legal requirements and practices mandated by the framework. Given the scope and complexity of such a project, understanding if all the moving parts are progressing in a manner that meets these mandates.
An internal audit helps infosec teams understand the current posture, how far it falls behind, and identify gaps. Include monitoring logs, timestamps, system screenshots, and other critical records in your audit trail.
Risk assessment
As businesses incorporate more systems, adopt new technologies, and hire more people, they add unforeseen risks to the infrastructure. Knowing and understanding the nature of the risks added is critical to building a resilient corporate compliance program.
Risk assessments can be qualitative or quantitative. Irrespective of how you approach it, the end goal is to identify gaps in your program’s practices that can lead to non-compliance. An end-to-end risk assessment process includes four options – accept, avoid, transfer, and mitigate. It helps infosec teams assess risks for their impact to prioritize the next steps – accept, transfer, avoid, or mitigate.
Employee training
Humans are the touchpoints that connect risk-inducing action and the technology used to introduce it. This is why it is critical for employees to familiarize themselves with the best practices and work efficiently without breaking down the security guardrails.
Develop your training program based on your security goals, history of breaches, and compliance requirements. All new employees and vendors who have access to critical assets should undergo the training as part of their onboarding process. For existing employees, the frequency should be at least once every six months.
Continuous monitoring
While audits are a critical process that provides visibility into the posture at a point in time, continuous compliance monitoring tells the status in real time. This helps to increase visibility into risks as soon as they are introduced to your system.
Patching issues as they pop up is key to ensure continuous compliance, which prevents your systems and people from falling into a state of risk, possible penalties, and breaches. A continuous monitoring system should have:
- Real time scanning to track and analyze security events
- Real time alerting and notification to the right individual responsible for a task
- Automated compliance checks to enforce correct policies and corrective actions
Implement controls
These are the strategies, systems, measures, and mechanisms. These work together to minimize the impact of breaches or prevent them from occurring in the first place by acting as a guardrail that adds a layer of protection against risky or fraudulent activities.
Controls fall within either one of the three categories-
- Preventive (designed to avert risky issues)
- Detective (identifies issues after they have already entered the system
- Corrective (rectify and control the damages).
Compliance controls should be selected and designed based on three objectives –
- Results of a risk assessment
- Requirements of the applicable framework
- Your organization’s unique security goals.
Assign roles and responsibilities
Taking a corporate compliance program to the finish line involves a multitude of activities. Unless you are using a compliance automation system or plan on hiring a third-party service, your compliance program can easily go off track and spiral into chaos.
To avoid a messy situation midway through your compliance journey, plan out the whos, whats, and whens before the starting line. Develop a clear roadmap on which individual should handle a specific task and within which timeframe. Chalking out this plan beforehand helps to ensure accountability and maintain transparency throughout.
Collect evidence
Evidence is proof that you are doing what you claim to and is pretty much a nonnegotiable requirement to pass external audit checks. If you want to implement a certifiable compliance framework like SOC 2 or ISO 27001, it boils down to the quality evidence.
Your evidence should comprise of system screenshots, proof of incident response plans, proof of the effectiveness of controls, results of risk assessments, implementation of policies, and other security measures.
There are two ways to approach this – the traditional or semi-manual way using multiple tools like spreadsheets or a fully automated method using a tool like Sprinto that automates the end-to-end process. The latter is recommended since it is more cost-effective, reduces the chances of errors to zero, and takes only a fraction of the time.
How Sprinto helps you establish and maintain a continuous corporate compliance program
IT compliance goes beyond being a one-time requirement; it’s crucial for fostering a security-first culture and maintaining continuous readiness against evolving threats. Yet, many organizations struggle with compliance due to manual processes that slow down progress and take a hit on productivity.
To overcome these challenges, businesses can use compliance automation tools like Sprinto to streamline the process, minimize human error, maintain compliance year-round, and align the company with best practices for regulatory requirements.
Sprinto drives compliance management forward with a platform designed for speed and efficiency. It is equipped with automated security programs, policies, controls, and task workflows, making compliance and audits faster and easier. The real-time compliance dashboard allows you to monitor assets, controls, and tasks centrally and continuously.
With extensive flexibility and customization options, Sprinto helps you scale compliance effortlessly, adapting to your business needs. It keeps compliance aligned with your growth, ensuring it supports your progress rather than slowing it down..
Want to learn more? Talk to a compliance expert now
FAQs
What are the elements of a corporate compliance plan?
A corporate compliance plan has the following elements: clear policies, a compliance officer, an employee training program, effective communication, monitoring activities, prompt resolution of issues, and continuous tracking and improvement.
How to choose an IT corporate compliance tool?
To choose an IT compliance tool, start by identifying the compliance frameworks relevant to your organization, ensuring the tool supports them, testing the platform’s usability through demos, looking for automated workflows, integration with existing systems, reporting capabilities, and scalability to grow with your needs.
What is an example of a compliance program in healthcare?
An example of a compliance program in healthcare is the Health Insurance Portability and Accountability Act (HIPAA). It requires healthcare workers and service providers to protect personal health information of patients from being leaked or disclosed to unauthorized individuals.
Who is responsible for overseeing a compliance program?
In large organizations, The Chief Compliance Officer (CCO) oversees the compliance program, ensuring adherence to legal and ethical standards. The CCO coordinates with the compliance committee and other leaders to manage risks. In smaller companies, compliance activities are distributed among employees.