Governance, Risk and Compliance (GRC) is an integrated approach to managing cybersecurity obligations. The order the acronym implies, however, is the wrong order to build the program.
Start with Compliance. Before you write a policy or build a risk register, identify what laws, regulations and contracts actually apply to your organization. This is a due diligence step: map your applicable statutory requirements (e.g., HIPAA, GLBA, FISMA, etc.), regulatory requirements (e.g., DFARS, FedRAMP, state privacy laws, etc.) and contractual requirements (e.g., DoD contracts, client agreements, flow-down clauses, etc.). That inventory determines your Minimum Compliance Requirements (MCR) that define the control set you must have, regardless of risk appetite.
Then build Governance. Once you know what you're required to do, governance creates the policy and standards infrastructure to do it consistently. It also assigns ownership: a clear RASCI that maps each control to a responsible party across the organization. Undefined ownership is one of the most consistent root causes of control failures found in assessments.
Risk Management comes last, but runs continuously. With policies published and ownership assigned, risk management identifies where controls are weak, absent, or newly threatened and drives prioritized remediation. It operates on a much shorter cycle than compliance and governance work: risk assessments may run monthly or quarterly, while policy reviews happen annually.
The practical consequence of getting the sequence wrong: organizations that build risk registers before they know their compliance requirements often treat mandatory controls as discretionary risks to be managed rather than as mandatory floors to be met. The result is a risk register that looks comprehensive but misses legally required controls entirely.
