What Are the Elements of an Effective GRC Program?

The landscape of risks and threats your business now faces is more complex than it’s ever been. In such a climate, governance, risk, and compliance (GRC) can no longer be an afterthought. 

To reduce risk, ensure regulatory compliance, and implement effective security controls, you need a GRC program.

The process involved in establishing a GRC program can seem overwhelming at first, particularly if it’s something with which your organization has never needed to contend. The trick is to take things slow. To gradually develop GRC capabilities and incorporate them into an overarching program and strategy. 

Let’s go over the practical steps involved in this process.

Step One: The Initial Audit

Before you can plan your program, you need to understand the foundation on which it will be built. That starts with understanding the processes, people, policies, hardware, software, data architecture regulatory requirements, and vendor ecosystem of your business. The checklist below will give you steps and points to consider to help you evaluate each specific category and determine whether you’re GRC-ready, and what you must do to get there. 

People

• An effective cybersecurity awareness training program. 
• Processes for regular training review and optimization. 
• A culture of accountability in which executives lead by example.  
• Scheduled compliance, security, and privacy reminders. 
• Clearly-established roles and responsibilities from a security and risk management perspective. 

Processes and Policies

• An acceptable use policy for business and personal devices. 
• A zero-trust approach to identity management and access control. 
• Clearly-delineated roles and a clear idea of the data each role must access.
• An internal risk management program. 
• Policies for change management and lifecycle management. 
• Enforcement guidelines for applying security and compliance controls. 
• Guidance on how policies are to be evaluated and updated, including frequency.
• A comprehensive remote work policy. 
• Requirements for the adoption and integration of new technology. 
• A crisis management policy, including communication and remediation. 
• Disaster recovery and business continuity

Vendor/Partner Ecosystem (Third-Parties)

• The capacity to assess risk for both current and prospective vendors.
• The capacity to assess risk for downstream vendors. 
• Application of your internal risk management program to vendors and business partners. 
• Policies for regular training and contract updates.

Assets

• Data orchestration to eliminate silos and consolidate business-critical data. 
• A complete map of your business’s hardware and software ecosystem.
• Identification of which assets are likeliest to be targeted in an attack, and why. 
• Assessment of the security controls and tools that currently protect these assets. 

Legal/Compliance

• Compliance requirements that are clearly and regularly communicated. 
• Determine responsibilities under regulations, such as the GDPR. 
• Regular, scheduled review and updates of compliance data. 

Technology

• Identify potential gaps in your current toolkit.
• Create a shortlist of vendors that may offer the needed GRC functionality. 

Don’t worry if you’re having a bit of trouble figuring out processes, policies, and controls. There exists a vast array of security and compliance frameworks online that can provide you with guidance in that regard. We discuss them later in the piece. 

Step Two: Engaging Stakeholders

Once you’ve mapped out your assets and infrastructure, the next step is to get everyone on-board with your pending program. GRC is no longer the sole domain of a compliance officer or the IT department. In a modern context, it’s everyone’s responsibility — and everybody has their part to play. 

GRC, compliance especially, is typically mandated from the top-down by the board. With a command-like approach, employees are likely to pay lip service to your GRC program until the moment it inconveniences them or interrupts their work. For a more effective implementation, meet with the leader of each business unit separately, tailoring your approach to their expertise and highlighting the benefits and importance of their participation. 

Don’t simply talk about the update to your GRC program, however. Listen to each leader’s GRC requirements, and ensure that your final policy accounts for them. As you’ll see momentarily, the most effective GRC programs are those that align with the business’s goals. 

Step Three: Establishing Objectives

GRC does not exist in a vacuum. For yours to succeed, you cannot simply jot down a few vaguely-defined goals. Instead, you need to align the objectives of your GRC program with the overall strategic objectives of your organization and understand how they work together. This is part of the reason why stakeholder buy-in is such a critical step. 

A GRC program needs to be implemented through a collaborative, multidisciplinary process in order to be effective. Starting with your business’s most important objectives as a foundation, define the following :

• A GRC vision and mission statement. 
• Objectives and goals of your program, both short-term and long-term.
• With regards to the above, critical milestones in your program’s development and deployment.  
• The criteria by which you’ll measure your program’s success. 
• Roles and responsibilities of each major stakeholder in the GRC process. 
• What you’ll need in terms of technology. 

Step Four: Choosing Your Frameworks

By now, you’ve likely figured out that you aren’t building a monolith. Instead, there exists a multitude of smaller processes, policies, and programs that comprise GRC; regulatory compliance, privacy, risk management, and legal, to name just a few. Frameworks and standards exist for each of these, and it’s advisable to find and follow a well-established set of guidelines. 

Our personal recommendation is ISACA’s COBIT, a comprehensive set of standards that blends governance, risk management, and business objectives into a single, unified strategy. It should go without saying, too, that you’ll want to follow whatever regulations, guidelines, and frameworks are the standard for your own industry. 

Why are these frameworks so important? Simply put, standardization. By ensuring everyone within the organization follows the same processes where GRC is concerned, you both streamline your program and avoid mistakes like data silos or blind spots.  

Step Five: Assessing GRC Management Software

As part of your initial groundwork, put together a shortlist of GRC vendors. Now, it’s time to assess each vendor on that list to determine which one best suits your needs. We recommend that you keep an eye out for programs that offer the following features: 

• Real-time threat intelligence and visibility. 
• Automated logging, tracking, and reporting. 
• Analytics functionality. 
• Integrated risk management. 
• Remediation tools. 
• Simple application of security controls. 
• Intuitive functionality. 
• Stakeholder-focused report generation. 
• Easy integration. 
• Data management. 

Step Six: Integration and Orchestration

Now for the fun part.

First, you need to integrate your GRC solution with the rest of your infrastructure, ensuring that there’s a seamless, uninterrupted flow of data between them. This is crucial for the next, most important step..

Data orchestration. If you haven’t already done so, you need to break down the data silos within your organization, and ensure that all GRC data is stored in a centralized repository, accessible to anyone who needs it. How challenging this is depends on two factors. 

• Your data hygiene and security practices prior to your decision to deploy a GRC program. 
• Whether or not you’ve selected a GRC platform that can automatically aggregate data. 

Step Seven: Reporting

We’ve come to the last step in the cycle. Even once your GRC program is fully planned, deployed, and integrated, you need to consider how to keep it running and up to date. It’s an ongoing process, one which requires constant monitoring, assessment, and evaluation. 

The good news is that by following the steps outlined above, you will have implemented an effective GRC program. With continued monitoring, sound policies that keep your systems up to date and regularly generated situation reports, you will have built a GRC program that is fit for the long haul.

Key GRC Program Management Best Practices

We’ll wrap things up with a few general best practices to consider when you start planning a GRC strategy. 

• A well-defined roadmap for your program is a must, with accurate estimates for time, funding, and other resource requirements. 
• Always remember that GRC is a collaborative process that involves processes, people, and technology across your entire organization. You need to work with stakeholders at every stage. 
• Determine an order of priority for your GRC use cases. 
• Establish a team solely responsible for managing the GRC program, led by a compliance manager. You may need to hire outside talent for this. 
• Use GRC technology to enable your program, not as a band-aid for bad practices. 
• Again, take it slow. Plan, integrate, and scale your GRC program with patience. You won’t do anyone any favors by rushing things, least of all yourself. 
• Always refer to established frameworks and guidelines for planning, implementation, and process management. 

Build a Next-Gen GRC Program With Centraleyes

Every company today needs a GRC program in place to stay ahead of developing industry trends, regulations, and evolving compliance requirements.

You now know what is needed to develop a GRC program that follows best practices. The next step is to find the right platform to collect, quantify, and analyze performance.

Centraleyes is a next-generation, cloud-native integrated risk management platform that your organization can use to actively monitor, measure, and improve your GRC program’s performance. With Centraleyes, you can achieve real-time visibility into your GRC program.

Are you interested in seeing how you can build a successful GRC program within your organization? Book a meeting today to see how easy Centraleyes makes it to manage GRC.