High-profile data breaches stemming from inadequacies in compliance programs demonstrate the importance of continuous vigilance. Simply checking the box on required controls is not enough. This article examines key areas compliance teams need to evaluate and strengthen to effectively safeguard sensitive data.
Evaluate Technical Safeguards
Robust technical protections are the foundation of any secure infrastructure. Assess and upgrade:
- Encryption to scramble data at rest and in transit. Use industry standard protocols with proper key management.
- Access controls like multi-factor authentication and role-based access to limit system and data access.
- Network protections including firewalls, intrusion detection/prevention systems (IDS/IPS), and frequent vulnerability scanning and penetration testing to identify and resolve security gaps.
- Disaster recovery and backup systems to enable quick restoration of data and operations in case of outages or data corruption.
Review and Update Policies and Procedures
The most secure technology still requires proper implementation and oversight. Key policy areas to review include:
- Mandatory training to ensure all employees understand privacy policies, data handling restrictions, phishing risks and incident reporting duties. Update training at least annually.
- Incident response plans that provide step-by-step guidance across detection, containment, eradication and recovery of breaches. Conduct exercises to verify efficacy.
- Access review and revocation procedures to validate that users still require data access. Promptly revoke when no longer needed.
- Data disposal guidelines mandating secure destruction of hardware, paper records and electronic media containing sensitive data.
Prioritize Third Party Risk Management
With supply chains growing increasingly complex, third parties have become a major data breach liability. Enforce:
- Risk assessments and audits for all vendors and business partners handling sensitive data, both during onboarding and periodically after.
- Contracts that hold suppliers accountable for data protection via access restrictions, encryption, training, audit rights and breach responsibility.
- Multi-factor authentication and controls on remote access to your systems originating from third parties. Limit access to least privilege only.
- Restrictions on subcontracting and data sharing to prevent access from expanding beyond vetted partners.
Cultivate a Security and Privacy-Focused Culture
Technical controls and policies only work when people uphold them. Foster an environment where privacy and ethics are valued through:
- Tone at the top – Executives and leadership must model the attitude and behaviors expected from all employees.
- Incentives for raising issues – Encourage speaking up about potential vulnerabilities without fear of retaliation.
- Personal accountability – Make sure identification with data policies begins on day one. Hold everyone responsible for understanding and adhering to them.
- Zero tolerance enforcement – Violations of data handling rules must have consequences to reinforce compliance.
Test and Audit Proactively
The best laid plans still need regular testing. Routinely verify program effectiveness through:
- Simulations – Conduct mock data breaches and incident response exercises. Learn from mistakes to fill any preparedness gaps.
- Internal and external audits – Partner with auditors to objectively assess compliance with security standards and data privacy regulations.
- Remediation tracking – Quickly establish timelines for fixing control deficiencies. Follow up to verify resolution.
Recent breaches show privacy and security require more than just point-in-time compliance. Companies must vigilantly monitor their people, processes and technology controls to identify and address gaps before incidents occur. Updating technical safeguards, strengthening policies, vetting third parties, fostering an ethical culture of security, and verifying program effectiveness through testing and audits are crucial to making compliance programs complete. While data threats will continue evolving, proactive defense-in-depth strategies provide the best assurance against future data breaches.
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Third-Party Risk Management: Why it Matters Now More than Ever. (2020). Retrieved from https://www.ibm.com/security/data-security/third-party-risk-management
Building an Effective Information Security Policy Architecture. (2017). Retrieved from https://www.sans.org/information-security-policy/
Security Culture – SANS Institute. (n.d.). Retrieved from https://www.sans.org/information-security-policy/awareness-and-training/security-culture
Whiteman, C. (2022, September 30). Top Tips for Testing Your Incident Response Plan. Retrieved from https://digitalguardian.com/blog/top-tips-for-testing-your-incident-response-plan