Compliance Management is the set of practices that keeps your organization safe and in order. Implemented effectively, it can increase colleague and customer confidence, reduce the potential for legal exposure, and support governance.
The implementation process comes with its challenges, as you have to coordinate different teams and at the same time address a range of regulations and laws. Yet, with a strong strategy and an IT Asset Management (ITAM) tool that includes compliance features, the task will be much simpler.
Come along as we learn how to take on an IT Compliance Management process and how to streamline it with InvGate Insight.
Let's get started.
Why do you need an IT Compliance Management process?
So, let's kick things off by asking the question everyone wants the answer to. An IT Compliance Management process isn't the easiest of undertakings; it requires effort, time, money, people, tools, and processes – and it isn't a one-and-done exercise either – so why do we need it?
Well, the simple answer is that it keeps you out of trouble. It is the safety rail that allows the organization to go about its business in a way that ensures that it is legal, responsible, ethical, and protects its people and data.
The reality is that it's much more challenging and costly to deal with the outcome of not having the correct controls in place. Without Compliance Management, you can easily be involved in audits, fines, and reconciliation activities that will cause additional work for the organization.
It’s important to change the perspective; instead of looking at compliance as a drain on resources or an expense, we should consider it an investment in service quality.
By putting IT compliance in place, you will avoid panicked, last-minute preparation for audits, fines, and rework because not only will you reduce the risk of being non-compliant, but you will also strengthen your service stability as you will reduce the likelihood of service disruption due to compliance and nonconformance issues.
Elements of the Compliance Management process
Now that we’ve set clear its importance, let’s take a look at what it takes to implement a Compliance Management plan. The elements needed to establish a successful process include the following.
A solid set of objectives
Compliance Management is a big undertaking and it’s important to get right. Before creating policies, processes, and procedures, and before investing in tools, understand what you want to get out of your practice. What is your primary mission? Is it to be compliant with a particular regulatory requirement or standard? To save money? To reduce risk? To fix something that has happened previously. To get a better handle on audits?
If you're not sure about this, ask your stakeholders. So many compliance initiatives run into trouble because the scope isn't clear or people aren't sure what they need to be compliant or what to prioritize. We address this by talking to people. Lean into the business, Senior Management, governance, and risk teams. Agree on the objectives as a group so there is a common set of goals. Bonus points? Everyone agrees from the outset and knows what is expected from them.
Learn from past mistakes
Review past compliance activities or earlier issues flagged up to the compliance team to understand where to start or what to focus on. Things to look at include past audits, records, risk registers, and ongoing compliance projects.
By understanding what has caused pain in the past, extra preparation before external audits, overspending to make up for fines or additional work to reassure unhappy customers, you can create a roadmap and generate value where it's needed most.
Agree on your scope
Once you have set what you need to achieve and possible challenges to look out for, you have to define your sphere of action. Clearly outline the scope of your Compliance Management practice. Make sure it is easy to understand because if there is any room for confusion, your scope will creep, making your practice less efficient. Set out what is covered and what aspects of your IT ecosystem will be covered.
Build your team
Like the Avengers movies, you will need to assemble your team of subject matter experts to build your compliance practice. During the previous steps you should have started to outline who are the specialists regarding the different compliance fields. This team has to include IT professionals, legal experts, and compliance officers who can help create and implement the plan.
Understand your regulatory landscape
Before you start defining your documentation and compliance processes, you have to understand which requirements you have to address. Work with your governance, risk, and legal teams to identify the specific laws and regulations for your industry and organization. Common examples include GDPR, HIPAA, and SOX.
Create your supporting documentation
Now it’s time to put everything into action. Develop formal policies, processes, and standards. IT Compliance Management is a set of practices that needs to be underpinned with a clear policy so there's no room for any confusion.
Every organization will have different needs, but things that should always be covered include:
- Introduction and purpose - Why is compliance important, and how does it support the organization?
- Scope - What is covered?
- Legal or regulatory requirements that the process needs to be supported.
- Roles and responsibilities – for everyone to know what is expected of them.
- Where to go for help and further information
IT Compliance Management roles and responsibilities
IT Compliance Management is nothing without its people. Here is a chart of the key roles and responsibilities involved in the IT compliance plan:
|Compliance Manager||Responsible for the Compliance Management practice.|
|Board of directors||Responsible for business compliance and escalations.|
|CIO||Responsible for information security compliance and escalations.|
|Legal team||Provide subject matter expertise on compliance legal matters, provide updates on the changing compliance landscape, and review contracts with suppliers and partners to ensure all compliance requirements are met.|
|Risk Manager||Provides subject matter expertise on Risk Management, underpinning your compliance activities.|
|IT Security Manager||Provides subject matter expertise on information security and cyber resilience activities.|
|IT service desk||The service desk is the central point of contact for all colleagues when reporting IT issues – they will be able to identify any compliance issues and escalate them as and when needed.|
|IT Support teams||Provides subject matter expertise on IT aspects of compliance.|
|Change Management||Will ensure that all planned change is authorized and managed appropriately in line with current standards.|
|HR||Provides support for any HR, for example, compliance issues and dealing with disciplinary proceedings relating to non-compliance.|
|Internal Audit team||Conducts internal compliance audits and assessments to ensure everything is as it should be, and if exceptions are found, advise on the best way of dealing with them.|
|Business Function needs||Implement compliance activities in their own areas. Ensure areas comply with corporate standards.|
Eleven steps in the Compliance Management plan
Once you have made the decision to commit and are ready to put in the effort as an organization to implement Compliance Management it’s important to stick to a plan. Here are the eleven steps to follow when doing so.
1. Create a baseline
As we mentioned, you must have a solid understanding of your current state. This is a baselining process, taking a snapshot of our compliance landscape and understanding any key dependencies and risks to manage them.
A baseline aims to take a measurable part of the service so that it is documented and added to your Compliance Management system and risk register if appropriate. This ensures you have a solid foundation to build on and will ensure you have a reference point for future process iterations and improvement initiatives.
So, how do you carry out a baselining exercise in real life? Our advice? Start with your most critical compliance requirement. You know the one. That is, the one that is on almost every senior manager's radar. The one that is highlighted on the risk register at every meeting. That's the one.
Start by talking to everyone involved, from support teams to the business. As part of your baselining exercise, bring in your Risk Management team, if you have one, to assess and identify potential compliance risks and vulnerabilities within your IT infrastructure and processes.
2. Colleague training
Compliance is something that everyone is responsible for, so colleague training is crucial. Once you have defined your team and their roles and responsibilities, work with your HR and Learning and Development teams to create training programs. This should ensure all employees know the compliance duties and understand the appropriate policies, procedures, and standards.
3. Continue building your procedures and work instructions
We have also already talked about the importance of setting out clear policies and processes that must respond to your organization’s specific area of work and needs. Now is the time to expand on them with detailed guidelines and work instructions that align with the regulatory requirements you identified. These may include access controls, Data Management instructions, Incident Management procedures, etc.
4. Monitor compliance
Implement monitoring tools to ensure ongoing compliance. If your organization has an Event Management practice, ask them if they can manage compliance events and alerts so that you can automate routine compliance tasks such as monitoring, reviewing logs, conducting vulnerability assessments, and tracking access and data changes.
However, keep in mind that with so much information going around, it isn’t hard for things to get mixed up. For this step, InvGate Insight’s Software Compliance feature can help you ensure nothing falls through the cracks. It combines your contract’s data with reported software usage, enabling you to easily monitor any out of compliance systems and other important aspects such as costs or usage.
5. Data inventory and classification
Identify and classify all data within your organization based on its sensitivity, confidentiality, and regulatory requirements. Work with your Data Protection Officer or DPO to implement appropriate data protection measures for each category.
6. Access control
Work with your IT Security and Facilities Management teams to implement robust access controls. This ensures that only authorized personnel can access sensitive data. This includes physical access, user authentication, role-based access, and strong password policies.
7. Switch on MFA
This isn't a specific compliance requirement, but it's a good idea, so bear with us. If you haven't already implemented Multi-Factor Authentication or MFA in your organization, now is the time. Having MFA in place means that even if a password is guessed, it will be unusable without a second, one-time passcode issued by call, text, or app.
8. Data encryption
Use encryption technology to protect confidential data from unauthorized access. Engage your DPO and IT Security teams to ensure that any encryption used can be integrated into current infrastructure, is easy to use, and complies with relevant regulations.
9. Incident response plan
Have a plan in place for when things go wrong. I know that no one likes to think about being non-compliant, but with the best will in the world, people make mistakes, so have a plan that sets out the steps needed to be taken in case of a data breach or compliance failure. Ensure this plan is saved centrally and tested regularly, and talk to your IT team about having an incident category for compliance issues.
10. Vendor Management
Work with your third-party suppliers, vendors, and partners to ensure they comply with relevant regulations. Ensure compliance requirements are captured at a contractual level so there's no room for confusion and everybody knows what is expected from them.
11. Continuous improvement
Finally, it’s time for improvement. Compliance regulations change and you need to stay on top of your practice to make sure it doesn’t fall behind. Incorporate review and improve activity cycles into your process to adapt to changes in regulations, technology, potential threats, and business needs.
Best practices for IT Compliance Management
When following the implementation steps, keep in mind these IT Compliance Management best practices:
- Create a culture club - Build a culture where colleagues feel safe raising and discussing compliance issues and risks. If people feel comfortable talking about potential problems, they are more likely to engage with the process because they feel supported rather than under scrutiny.
- Embed it into day-to-day activities - Compliance is not a one-off exercise (if only!), so the easiest way to attack it is to embed it into your BAU activities. If it becomes part of the day job, everyone will get comfortable carrying out the tasks expected of them as it is part of their normal routine.
- Get proactive with patching - Patch regularly and test your Patch Management practice to prevent a Schrodinger's type situation. While we're on the subject of testing, test your backup and restore process as well. Nothing is more likely to raise red flags with an auditor than if they ask to see evidence of something being restored successfully from a backup and no one knows what to do.
- Use automation to lighten the load - Automation can make compliance easier and more efficient by automating routine tasks such as event monitoring and exception management.
- Keep in mind that relationships matter - Build strong relationships with your suppliers and partners. If you have regular service reviews, you will be less likely to be unknowingly non-compliant, for example, being under-licensed or not up to date with any mandatory patching or certificate renewals. Have a timetable of audit schedules and renewals so you know when to start planning for certificate renewals (and if you can automate them even better) and audit activities.
- Get proactive - When speaking with your stakeholders, ask them what compliance risks keep them up at night. Ask them if they have any concerns, and add any compliance issues to your risk register.
- Keep moving forward - We know we've said it previously, but it's important to say it as many times as needed. IT services, standards, rules, regulatory requirements, and business objectives are constantly evolving, so build continual improvement activities into your plan to stay in line with your organization's needs.
To sum up
Implementing an IT Compliance Management process will help you manage, control, and protect your organization from legal, regulatory, and reputational exposure. However, it’s no small undertaking. It requires careful planning, setting clear objectives, and incorporating different activities to implement, run, and improve compliance.
To support your strategy, a tool that incorporates compliance features will help you keep your data organized and monitor any installations that are out of compliance. Remember also that your process should contain continual improvement activities and be reviewed on a regular basis to ensure it remains fit for purpose.