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At the heart of it, procedures represent an established way of doing something, such as a series of actions conducted in a specified order or manner. Some organizations refer to procedures as “control activities” and the terms are essentially synonymous. Documented procedures are one of the most overlooked requirements in cybersecurity compliance, but procedures are also a minimum expectation that an auditor is going to look for. Organizations that undergo annual audits tend to do better with procedures, since they learned early on that lacking procedures would earn a control deficiency and possibly fail the audit (e.g., SOX). Companies tend to learn quickly about the ramification that lacking procedures is a demonstrated failure of internal controls in the auditor's eyes. In general terms, internal controls are the policies, standards and procedures that an organization implements to govern its cybersecurity and privacy program. |
For anyone who has written procedures, the answer for why companies routinely fail to maintain procedures is clear - it can take considerable time and effort to properly document processes. Part of that is tied to a lack of best practices around what good procedures look like - every organization tends to do something different, based on internal staff preferences or auditor pressure. This leads to a lack of standardization across departments and business functions, which can be an issue when trying to maintain "what right looks like" if a benchmark does not exist.
The good news is that ComplianceForge developed a standardized template for procedures and control activity statements, the Cybersecurity Standardized Operating Procedures (CSOP).
Given the difficult nature of writing templated procedure statements, we aimed for approximately a "80% solution" since it is impossible to write a 100% complete cookie cutter procedure statement that can be equally applied across multiple organizations. What this means is ComplianceForge did the heavy lifting and you just need to fine-tune the procedure with the specifics that only you would know to make it applicable to your organization. It is pretty much filling in the blanks and following the helpful guidance that we provide to identify the who / what / when / where / why / how to make it complete.
There are four (4) versions of the CSOP:
Procedures should be both clearly-written and concise, where procedure documentation is meant to provide evidence of due diligence that standards are complied with. Well-managed procedures are critical to a security program, since procedures represents the specific activities that are performed to protect systems and data. The diagram shown below helps visualize the linkages in documentation that involve written procedures:
What can possibly go wrong with non-compliance with a law, regulation or contract?
Below is a short list of statutory and regulatory requirements, as well as leading cybersecurity frameworks, that EXPECT every organization documents and maintains cybersecurity-related procedures. If you need to address one or more of those frameworks, then you need to maintain documented procedures.
Procedures are not meant to be documented for the sake of generating paperwork - procedures are meant to satisfy a specific operational need that are complied with:
The Cybersecurity Standardized Operating Procedures (CSOP) leverages the NIST NICE Cybersecurity Workforce Framework. The purpose of this framework is that work roles have an impact on an organization’s ability to protect its data, systems and operations. By assigning work roles, it helps direct the work of employees and contractors to minimize assumptions about who is responsible for certain cybersecurity and privacy tasks.
The CSOP uses the work roles identified in the NIST NICE Cybersecurity Workforce Framework to help make assigning the tasks associated with procedures/control activities more efficient and manageable. Keep in mind these are merely recommendations and are fully editable for every organization – this is just a helpful point in the right direction!
We sell cybersecurity documentation - policies, standards, procedures and more! Our documentation is meant to help companies become audit-ready!
We take a holistic approach to creating comprehensive cybersecurity documentation that is both scalable and affordable. This is beyond just generic policies and allows you to build out an audit-ready cybersecurity program for your organization!
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