Host Geoff Hancock, Access Point Consulting CEO; was joined by Rick Leib, Senior Director and CISO Advisor at Access Point Consulting; and Susan Woyton, a cyber risk and security expert with extensive industry experience. They talked about building a GRC (Governance, Regulatory, and Compliance) program that is resilient -- able to meet the rapidly changing needs of a company in 2024 and beyond.
The conversation began with Woyton pointing out how important it is for GRC managers to understand the specific requirements for their industry and their business. That done, they must then communicate those requirements up the management ladder to executives; a robust and resilient GRC program is necessary but not necessarily inexpensive, and executive buy-in will be required for any real chance at success.
GRC requirements will also have to be reflected in contracts with suppliers and service providers, Woyton said, because relying on audit failure to bring those third parties into compliance is expensive and disruptive. Hancock said that he has seen a wide variety of contract language, ranging from requiring full GRC compliance before projects can move forward to those that simply stipulate audit acceptance.
Woyton noted that the variation in contract language is often associated with differences in industry regulation: Companies in heavily regulated industries like banking and healthcare tend to have more stringent contract requirements from the beginning.
Hancock noted that contract language, while necessary, is no longer enough. The SEC is making companies show that they have a cybersecurity program they adhere to, and provide the evidence that the program is fully in place. The challenge, he said, is that some companies are just showing the results from a year-old audit and assuming it's sufficient.
Leib agreed, saying that he has gone into organizations to discover that they're failing GRC because managers have simply assumed that everything documented was in place and working. When organizations don't have good, resilient GRC, he noted, it can create a huge problem. This can be especially troublesome, Hancock said, because companies must show that they're maintaining the elements of their GRC program at all times -- not just when the auditor is in the building.
While constant GRC attention has costs, it can bring significant benefits, too. Hancock pointed out that GRC programs can improve operational efficiency, a point Woyton agreed with because GRC is intertwined with everything. Good vulnerability management, she said, is important and can bring with it automated tools that alert on any changes made to the system This automates documenting the system configuration, making change management and systems operations more efficient.
Leib continued the theme, saying that having GRC understood on the executive level is important. The executive team should understand that GRC can help improve the bottom line by methods that include improving operating efficiency or avoiding HIPAA violations, ransomware or phishing attacks. He noted that in many companies 80% of breaches go away when a solid GRC program is in place -- something that can't happen without executive support.
Of course, artificial intelligence entered the conversation. Woyton argued that humans must remain part of the process in GRC because of the rapid, complex changes to the regulatory and legal landscape for most businesses. Leib agreed, noting that AI can help a GRC program but there are caveats. AI lies, he said, because it's based on human-provided data and it can hallucinate. Organizations must have a human look at any results to make sure the answers make sense and apply to the specific organization. "As someone who uses AI every day," he said, "I don't trust it. It's useful but you have to check every word."
Even beyond that, Hancock warned, if a small business owner, see a product, and AI is doing part of it, that owner needs to understand the portions involving AI so it can be handles if there's an audit. Which data is being touched, by which processes, and where? All of this is especially true if customer data is involved.
The ultimate take-away is, as Woyton said, "Make sure that the way you're doing things align with the documentation. If your policy says you have to use MFA, you'd better be using MFA. You have to continuously work on it."
Hancock agreed, and added, "GRC is not a silo, not a person in a corner who comes out once a year. Organizations have to understand how to integrate GRC into the rest of their operations and their cybersecurity. Without good GRC," he warned, "lawsuits will happen."