Integrated Controls Management (ICM)

The Integrated Controls Management (ICM) is a joint project between ComplianceForge and the Secure Controls Framework (SCF) and the premise is that controls are central to cybersecurity and privacy operations, as well as the overall business rhythm of an organization. This is supported by the Cybersecurity & Data Privacy Risk Management Model (C|P-RMM), that describes the central nature of controls, where not just policies and standards map to controls, but procedures, metrics, threats and risks, as well.

ICM takes a different approach from the traditional definition of Governance, Risk Management and Compliance (GRC) and/or Integrated Risk Management (IRM), since ICM is controls-centric, where controls are viewed as the nexus, or central pivoting point, for an organization’s cybersecurity and privacy operations.

Integrated Controls Management - cover

OCEG defines GRC as,GRC is the integrated collection of capabilities that enable an organization to reliably achieve objectives, address uncertainty and act with integrity,” while Gartner jointly defines GRC/IRM as, "a set of practices and processes supported by a risk-aware culture and enabling technologies, that improves decision making and performance through an integrated view of how well an organization manages its unique set of risks."

ComplianceForge and Secure Controls Framework (SCF), the developers of the ICM model, define ICM as, a holistic, technology-agnostic approach to cybersecurity and data protection controls to identify, implement and manage secure and compliant practices, covering an organization’s people, processes, technology and data, regardless of how or where data is stored, processed and/or transmitted.

ICM is designed to proactively address the strategic, operational and tactical nature of operating an organization’s cybersecurity and privacy program at the control level. ICM is designed to address both internal controls, as well as the broader concept of Supply Chain Risk Management (SCRM).

Integrated Controls Management (ICM) GRC focus

Defining What It Means To Be “Secure & Compliant”

Unlike GRC/IRM, ICM specifically focuses on the need to understand and clarify the difference between "compliant" versus "secure" since that is necessary to have coherent risk management discussions. To assist in this process, ICM helps an organization categorize its applicable controls according to “must have” vs “nice to have” requirements:

cybersecurity compliant vs secure | compliance vs security

Secure and compliant operations exist when both MCR and DSR are implemented and properly governed:

ICM Principles

There are eight (8) principles associated with ICM:

    1. Establish Context
    2. Define Applicable Controls
    3. Assign Maturity-Based Criteria
    4. Publish Policies, Standards & Procedures
    5. Assign Stakeholder Accountability
    6. Maintain Situational Awareness
    7. Manage Risk
    8. Evolve Processes

ComplianceForge has simplified the concept of "how to GRC" in the following downloadable diagram to demonstrate the unique nature of these components, as well as the dependencies that exist:

Integrated Controls Management (ICM) – Overlaid On Integrated Cybersecurity Governance Model (ICGM) 

Integrated Controls Management (ICM)

[graphic can also be downloaded from

Principle 1: Establish Context

To build and maintain efficient and effective operations, a cybersecurity & privacy program must have a hierarchical vision, mission and strategy that directly supports the organization’s broader strategic objectives and business processes. This process of establishing context involves identifying all applicable external compliance requirements (e.g., laws, regulations and contractual obligations), as well as internal directives (e.g., Board of Directors, corporate policies, etc.). This is a due diligence element of the cybersecurity and privacy program.

Principle 2: Define Applicable Controls

A tailored control set cybersecurity and data protection controls must exist. This control set needs to be made of Minimum Compliance Requirements (MCR) and Discretionary Security Requirements (DSR). This blend of “must have” and “nice to have” requirements establish an organization’s tailored control set to ensure both secure practices and compliance.

Principle 3: Assign Maturity-Based Criteria

The cybersecurity & privacy program must assign maturity targets to define organization-specific “what right looks like” for controls. This establishes attainable criteria for people, processes and technology requirements. Tailored maturity level criteria can be used to plan for, budget for and assess against. Maturity targets should support the organization’s need for operational resiliency.

Principle 4: Publish Policies, Standards & Procedures

Documentation must exist, otherwise an organization’s cybersecurity and data protection practices are unenforceable. Formalizing organization-specific requirements via policies and standards are necessary to operationalize controls. Stakeholders utilize those prescriptive requirements to develop Standardized Operating Procedures (SOP) that enable Individual Contributors (IC) to execute those controls. Policies, standards and procedures provides evidence of due diligence that the organization identified and implemented reasonable steps to address its applicable requirements.

Principle 5: Assign Stakeholder Accountability

Controls must be assigned to stakeholders to ensure accountability (e.g., business units, teams and/or individuals). These “control owners” may assign the task of executing controls to “control operators” at the IC-level. The documented execution of procedures provides evidence of due care that reasonable practices are being performed.

Principle 6: Maintain Situational Awareness

Situational awareness must involve more than merely “monitoring controls” (e.g., metrics). While metrics are a point-in-time snapshot into discrete controls’ performance, the broader view of metrics leads to a longer-term trend analysis. When properly tied in with current risk, threat and vulnerability information, this insight provides “situational awareness” that is necessary for organizational leadership to adjust plans to operate within the organization’s risk threshold.

Principle 7: Manage Risk

Proactive risk management processes must exist across all phases of development/information/system life cycles to address confidentiality, integrity, availability and safety aspects. Risk management must address internal and external factors, including privacy and Supply Chain Risk Management (SCRM) considerations. To manage risk, it requires the organization to clearly define its risk threshold and risk management expectations.

Principle 8: Evolve Processes

Cybersecurity and data protection measures must adapt and evolve to address business operations and the evolving threat landscape. This requires the adoption of a Plan, Do, Check & Act (PDCA) approach (Deming Cycle) to ensure the organization proactively identifies its requirements, implements appropriate protections, maintains situational awareness to detect incidents, operates a viable capability to respond to incidents and can sustain key business operations, if an incident occurs.

Plan-Do-Check-Act (PDCA) Approach To GRC

The ICM takes a comprehensive view towards governing a cybersecurity and privacy program. Without an overarching concept of operations for the broader GRC/IRM function, organizations will often find that their governance, risk, compliance and privacy teams are siloed in how they think and operate. These siloed functions and unclear roles often stem from a lack of a strategic understanding of how these specific functions come together to build a symbiotic working relationship between the individual teams that enables quality control over people, processes and technology. The ICM utilizes a Plan, Do, Check & Act (PDCA) approach that is a logical way to design a governance structure:

  • Plan. The overall GRC process beings with planning. This planning will define the policies, standards and controls for the organization. It will also directly influence the tools and services that an organization purchases, since technology purchases should address needs that are defined by policies and standards.
  • Do. Arguably, this is the most important section for cybersecurity and privacy practitioners. Controls are the “security glue” that make processes, applications, systems and services secure. Procedures (also referred to as control activities) are the processes how the controls are actually implemented and performed. The Secure Controls Framework (SCF) can be an excellent starting point for a control set if your organization lacks a comprehensive set of cybersecurity and privacy controls.
  • Check. In simple terms, this is situational awareness. Situational awareness is only achieved through reporting through metrics and reviewing the results of audits/assessments.
  • Act. This is essentially risk management, which is an encompassing area that deals with addressing two main concepts (1) real deficiencies that currently exist and (2) possible threats to the organization.

Browse Our Products

  • Digital Security Program (DSP)

    Digital Security Program (DSP) - SCF Policy Template

    Secure Controls Framework (SCF)

    Secure Controls Framework (SCF) "Premium Content" - Expertise-Class Policies, Control Objectives, Standards, Guidelines, Controls & Metrics. Product Walkthrough Video This short product walkthrough video is designed to give a brief overview about...

    Choose Options
  • Cybersecurity Standardized Operating Procedures (CSOP) Template - Digital Security Program (DSP) Version

    DSP & SCF Procedures Template

    Secure Controls Framework (SCF)

    Cybersecurity Standardized Operating Procedures (CSOP)  DSP | SCF Version Product Walkthrough Video This short product walkthrough video is designed to give a brief overview about what the CSOP is to help answer common questions we receive...

    Choose Options
  • C-SCRM Compliance Bundle 2 - NIST SP 800-161 R1-based C-SCRM Program

    C-SCRM Bundle 2: DSP version (SCF alignment)


    Cybersecurity Supply Chain Risk Management (C-SCRM) Bundle #2 - DSP Version (45% discount) This is a bundle that includes the following thirteen (13) ComplianceForge products that are focused on operationalizing Cybersecurity Supply Chain Risk...

    Choose Options
  • DSP Bundle 1: DSP-CSOP

    DSP Bundle 1: Policies, Standards, Procedures & Controls

    Secure Controls Framework (SCF)

    Digital Security Plan (DSP) Bundle #1 - SCF-Aligned Policies, Standards & Procedures (25% Discount) This is a bundle that includes the following two (2) ComplianceForge products that are focused on operationalizing the Secure Controls Framework...

    Choose Options
  • DSP Bundle 2

    DSP Bundle 2: Enhanced Digital Security Documentation

    Secure Controls Framework (SCF)

    Digital Security Plan (DSP) Bundle #2 - ENHANCED DIGITAL SECURITY (35% Discount) This is a bundle that includes the following seven (7) ComplianceForge products that are focused on operationalizing the Secure Controls Framework (SCF): Digital...

    Choose Options
  • DSP Bundle 3: Whole Enchilada

    DSP Bundle 3: Robust Digital Security Documentation

    Secure Controls Framework (SCF)

    Digital Security Plan (DSP) Bundle #3 - ROBUST DIGITAL SECURITY (45% Discount) This is a bundle that includes the following thirteen (13) ComplianceForge products that are focused on operationalizing the Secure Controls Framework (SCF): Digital...

    Choose Options
  • NIST 800-171 Compliance Bundle 4: Secure Controls Framework (SCF) / Digital Security Program (DSP) Documentation. CMMC policies & standards. NIST 800-171 policies & standards.

    CMMC Bundle 4: Levels 1-3 (DSP & SCF)

    Secure Controls Framework (SCF)

    NIST 800-171 & CMMC 2.0 Compliance Bundle #4 - EXPERT  CMMC 2.0 Levels 1-3  (45% discount) This is a bundle that includes the following thirteen (13) ComplianceForge products that are focused on operationalizing NIST SP 800-171...

    Choose Options
  • Privacy Bundle 2: DSP-based

    Privacy Bundle 2: DSP version (SCF alignment)


    Privacy Bundle #2 - DSP Version (45% discount) This is a bundle that includes the following twelve (12) ComplianceForge products that are focused on operationalizing the cybersecurity and privacy principles: Digital Security Program (DSP) Cybersecurity...

    Choose Options

Learn More About Cybersecurity & Data Privacy