Moving Beyond Compliance & Paper Tigers into Cybersecurity

Cybersecurity experts have said it for years: "Compliance does NOT equal security." To the uninformed buyer, it's easy to read mass marketing hype machines talking about buying an automation platform that is built for compliance to make you "secure in weeks." This is a falsehood, and the reckoning comes after the purchase is made, only to realize all those empty promises about that point solution materialize into actual work where hover text and comments in templates are useless! Worse, marketing claims are made equating "security" and "compliance," and there's probably no worse example of false advertising in the marketplace.

While SOC2 compliance is a valuable achievement, and at least sets in motion the idea of a security program, it's essential to recognize it doesn't establish a secure operating environment. It establishes "the basics," and is a solid starting point for the Supply Chain, so I actually like SOC2 for that reason! But the chief problem is the marketing mindset around this for uninformed buyers. The reality is that "compliance" vanishes the day the auditor leaves, and the controls that were effective get ignored and fall "out-of-compliance" for many months until the next scramble mode to "get ready for the audit." Hence, that's not security.

In this post, l hope to help educate buyers with "eyes wide open," and explore the limitations of relying solely on compliance to define and drive the security program. Further, the goal is to cut the wheat from the chaff and help buyers understand that a real security program is built with a continuous improvement mindset, and is entirely reliant upon People, Processes, and Technology - in that order - for it's maximum effectiveness.

Compliance Breeds a Checklist Mentality

SOC2 compliance specifically (point-in-time assessments) follows a checklist mentality, where organizations focus on meeting specific requirements without fully understanding the context and purpose behind each control. Sometimes the control should be removed, or customized, or greatly enhanced based on the business context. Compliance is a checklist, security is a program.

Static Nature of Compliance

Cyber threats are dynamic and constantly evolving, hourly, daily. SOC2, however, is a snapshot in time, focusing on the effectiveness of controls at a particular moment. This static nature makes it challenging to understand emerging threats that aren't measured by compliance, leaving organizations vulnerable when they rely solely on compliance-driven security measures.

Inadequate Scope

SOC 2 compliance primarily addresses the security of customer data, and specifically, an application. While this is crucial, it might not encompass all the potential risks an organization faces. ISO27001(+27002) is much better, as it formally establishes a comprehensive security program for the entire organization. A narrow focus on compliance leaves other critical assets and systems unprotected, making the overall environment less secure.

So what is the best approach to establishing a security program, if compliance isn't the only answer? First, recognize that compliance is a great starting point, but don't be misled (or fool yourself into thinking) that this means you have a secure posture. It helps identify areas that "are working OK" and also areas that need great improvement.

But fundamentally, It's all about a laser-focus on the basics, building that muscle memory across the organization by leveraging existing tools, brains, and capabilities that can

Always start with a Risk-Based Approach

Rather than adopting a compliance-centric mindset, organizations should embrace a risk-based approach to security. This involves identifying and prioritizing risks based on their potential impact on business objectives. This means having the tough, laborious, yet tremendously vital discussion with business leaders about Risk. Define your risk appetite, create a Risk Register, and assign owners to the Risk Treatment plans. By aligning security measures with specific risks, organizations can create a more tailored and effective security program, and possibly identify areas that are more urgent than achieving compliance.

Continuous Monitoring and Adaptation

Cybersecurity is an ongoing process that requires continuous monitoring and adaptation. Instead of relying solely on periodic compliance assessments, organizations should implement real-time monitoring tools and practices to detect and respond to threats promptly. On this point, it's vital to thoroughly evaluate the tools that "scrape" info about your environment for "continuous compliance." Understanding that compliance is only looking at a subset of security items as defined by X GRC vendor is a limited lens is crucial to understanding where you need to adapt and improve, assuming you actually care about improving!

Cultural Integration

This is probably the most important point for an effective, resilient, scalable security program. Building a secure environment is not just about implementing technical controls; it's also about fostering a security-aware culture within the organization, and creating a continuous improvement mindset. Aligning business priorities with security context includes educating employees about the importance of security, their role in the security of the organization, and integrating security practices into daily operations.

Incident Response & Disaster Recovery Planning

No security program is foolproof, and incidents can still occur. Developing robust Incident Response and Disaster Recovery capabilities is crucial for minimizing the impact of a security breach, and in fact should be a top priority. This involves regular testing, updating, and refining the response plan based on lessons learned and changes in the threat landscape.

Conclusion

Gone are the days where an organization can rely on cyberinsurance to make all their troubles go away, and compliance is truly a paper tiger that lulls organizations of all sizes into a very false sense of security. While SOC 2 compliance is a significant step towards demonstrating a commitment to security, organizations must recognize its limitations. It's a great starting point, but don't be fooled by Vendors telling you it means you're secure.

To truly create a secure environment, it is imperative to align business priorities with security context, adopting a risk-based approach, embracing continuous monitoring, integrating a security-aware culture, and implementing a robust incident response plan. By doing so, organizations can move beyond compliance-driven security programs and build a resilient defense against the ever-evolving landscape of cyber threats.