Comprehensive GRC: Unifying Governance Beyond Frameworks

When it comes to Governance, Risk, and Compliance (GRC), there’s no one-size-fits-all solution. Governance must permeate every part of your organization—from HR to legal to finance. Without collaboration across all departments, even the most robust framework will fail.

Consider an employee on leave of absence (LOA) who still accesses their email regularly. The employer suspends payroll since the employee is on disability insurance, but the salaried employee claims they were working daily checking email. This situation underscores the need for comprehensive governance policies that define and manage such processes. HR, IT, and other departments must be in sync to handle these nuances effectively.

Every framework has its pros and cons. ISO 27001 is internationally recognized and has recognized certifiers that confirm your adherence to the requirements. SOC2s require hiring an auditor to assess operations based on COSO principles. Both SOC2 and ISO 27001 have generalized recommendations for vendor management, also known as third party risk management. As with all other frameworks, the controls are vague and nebulous which means that the company readying for a ISO 27001 or SOC2 must firm up their own auditable controls. 

Most SOC2s specifically exclude subservice organizations, and although the vendor management policy may get reviewed as part of that SOC2, specific details within that vendor management competency may be missing. Critical details such as data handling transparency to include your vendor forwarding your data to their vendor, breach notification commitments, and cyber insurance minimum qualifiers. 

Downstream data transfers, where your vendor passess your data to their vendor, is one of the largest risks in our industry. It doesn’t matter what framework or regulation dominates the operations at your company because none of them will prescribe how to stand up a vendor management program that addresses all of the risks we have today given the excessive data hoarding and how it is passed, transferred, and stored. If a vendor is required for your operations, your organization’s critical data must be safeguarded diligently, even if managed by downstream vendors.

Implementing ISO 27001 can bring tangible benefits. For example, the company that invested into an ISO 27001 certification will likely be able to satisfy requirements for the larger clients that they want. Start with robust policies for information security and mechanisms to track policy execution. The organization of information security is paramount. Responsibilities should be mapped out, particularly in HR, and access should be role-based with strict approval processes.

Publicly traded companies must disclose material breaches within four days, per the SEC. This necessitates a robust communication plan involving all relevant departments—HR, legal, IT, and more. Practicing these workflows during normal operations is critical, don’t wait until an event occurs to understand that your silo’d departments aren’t communicating effectively in a short timeline. Initiating drills which originate in incident management, move to HR, potentially legal and finance, loop in the communications team -  is something that should be practiced as part of normal operations.

Governance doesn’t end with risk logging; it requires immediate action to rectify failed controls. Leverage the Project Management practices at your company to remediate identified risks as well as satisfying information security requirement controls into all projects. This ensures continuous improvement and adherence to security standards.

Effective governance requires a comprehensive approach that integrates all departments. By adopting and rigorously implementing suitable frameworks like ISO 27001 or SOC2, and fostering collaboration across all departments, your organization can navigate the complexities of GRC successfully.

At Klever Compliance, we transform GRC from a daunting challenge into a valuable asset for your business. Partner with us to achieve seamless governance, risk management, and compliance that makes sense for you. Transform the overwhelming to the empowering.

… article collaboratively written by Katherine Burke & Karina Klever