Compliance Management in IT Services

𝐈𝐓 𝐆𝐞𝐧𝐞𝐫𝐚𝐥 𝐂𝐨𝐧𝐭𝐫𝐨𝐥𝐬 (𝐈𝐓𝐆𝐂) 𝐂𝐡𝐞𝐜𝐤𝐥𝐢𝐬𝐭 𝐀𝐜𝐜𝐞𝐬𝐬 𝐂𝐨𝐧𝐭𝐫𝐨𝐥𝐬 -User access provisioning and de-provisioning processes are established. -Access rights are assigned based on job responsibilities. -Segregation of duties (SoD) controls are in place. -Regular access reviews are conducted. -Strong password policies are enforced. 𝐂𝐡𝐚𝐧𝐠𝐞 𝐌𝐚𝐧𝐚𝐠𝐞𝐦𝐞𝐧𝐭 -Formal change management processes exist for all system changes. -Changes are documented, approved, and tested before implementation. -Segregation of duties between development, testing, and production environments. -Regular reviews of change management are conducted. 𝐁𝐚𝐜𝐤𝐮𝐩 & 𝐑𝐞𝐜𝐨𝐯𝐞𝐫𝐲 -Regular backups of critical systems and data are performed. -Backup integrity checks are regularly conducted. -Backup and recovery procedures are documented and tested. -Off-site storage of backups is maintained for disaster mitigation. 𝐈𝐧𝐜𝐢𝐝𝐞𝐧𝐭 𝐌𝐚𝐧𝐚𝐠𝐞𝐦𝐞𝐧𝐭 -Formal incident response plans are in place. -Procedures for reporting and documenting incidents are established. -Incident response teams are trained and ready. -Post-incident reviews are conducted for improvement. 𝐍𝐞𝐭𝐰𝐨𝐫𝐤 𝐒𝐞𝐜𝐮𝐫𝐢𝐭𝐲 -Intrusion detection/prevention and antivirus are deployed. -Network segmentation minimizes breaches. -Regular vulnerability assessments and penetration testing are conducted. -Wireless network security controls prevent unauthorized access. 𝐃𝐚𝐭𝐚 𝐏𝐫𝐢𝐯𝐚𝐜𝐲 -Policies protect sensitive data. -Data encryption is used in transit and at rest. -Data classification policies categorize data by sensitivity. -Regular data privacy training for employees. 𝐌𝐨𝐧𝐢𝐭𝐨𝐫𝐢𝐧𝐠 & 𝐋𝐨𝐠𝐠𝐢𝐧𝐠 -Logging mechanisms record security-related events. -Regular review and analysis of logs for security incidents. -Monitoring of system performance and availability. -Intrusion detection systems monitor suspicious activity. 𝐕𝐞𝐧𝐝𝐨𝐫 𝐌𝐚𝐧𝐚𝐠𝐞𝐦𝐞𝐧𝐭 -Vendor risk assessments before engaging third parties. -Vendor contracts include security and compliance provisions. -Ongoing monitoring and oversight of vendor activities. -Procedures for terminating vendor access. 𝐂𝐨𝐦𝐩𝐥𝐢𝐚𝐧𝐜𝐞 & 𝐀𝐮𝐝𝐢𝐭 -Regular compliance assessments and audits. -Documentation of IT policies, procedures, and controls is maintained. -Remediation of control deficiencies or non-compliance issues. #kpmg #periodicreviews #cybersecurity #itgc #technology #learning

The Three Lines of Defense in IT Audit Think of your company’s IT security like a fortress. To protect it from cyber threats, compliance risks, and operational failures, you need three layers of defense working together. This structured approach ensures effective risk management while maintaining strong governance and compliance. 1st Line – The Warriors (Business & IT Teams) The first line of defense consists of IT administrators, business process owners, and security teams responsible for implementing controls and managing daily IT risks. Key Responsibilities ✔ Managing access controls and system security ✔ Implementing ITGCs and ITACs to maintain compliance ✔ Monitoring cyber risks, security logs, and incident response ✔ Ensuring data protection and regulatory compliance Example: A DBA ensures only authorized employees access financial data, monitoring logs for suspicious activity. 2nd Line – The Strategists (Risk & Compliance Teams) The second line of defense consists of risk management and compliance teams that enforce policies and monitor risks. Key Responsibilities ✔ Defining IT security policies and frameworks ✔ Monitoring compliance with SOX, GDPR, ISO 27001, PCI DSS ✔ Conducting risk assessments and security monitoring ✔ Ensuring proper reporting and mitigation of security incidents Example: An IT risk team enforces MFA after identifying weak login security. 3rd Line – The Watchmen (Internal & External Auditors) The third line of defense provides independent assurance through IT audits, ensuring the first two lines function effectively. Key Responsibilities ✔ Auditing IT System and cybersecurity controls ✔ Evaluating compliance with SOX, SOC 1, and data privacy laws ✔ Identifying security weaknesses and recommending improvements Example: An IT auditor finds that former employees still have ERP system access, highlighting a security gap. How the Three Lines of Defense Work Together During a ransomware attack: 1st Line (IT Teams) isolates infected systems and restores data. 2nd Line (Risk Teams) updates policies and strengthens security. 3rd Line (Auditors) assesses control failures and recommends fixes. Case Study: ITGC Failure and the Three Lines of Defense in Action Background During a SOX compliance audit, an internal auditor at a financial services company found that terminated employees still had access to critical financial systems, posing a security risk. What Went Wrong? 1st Line (IT Teams): Failed to revoke access promptly. 2nd Line (Risk Teams): Had policies but lacked monitoring. 3rd Line (Auditors): Discovered the issue and reported it. How They Fixed It ✔ IT Teams: Disabled old accounts and strengthened role-based access controls (RBAC). ✔ Risk Teams: Implemented automated alerts for access anomalies. ✔ Auditors: Recommended quarterly access reviews to prevent recurrence. Outcome The company avoided regulatory penalties, improved ITGC controls, and enhanced security monitoring.

Compliance officers and IT professionals understand the challenge: 🛡️ the 110 controls in NIST SP 800-171 require more than documentation. They demand a System Security Plan (SSP) supported by policies and procedures that are consistently followed in daily operations. The real test in a CMMC Level 2 assessment is not what’s written down, but what’s actually practiced. Organizations that succeed make three key shifts: ❇️ From reactive to proactive: Anticipating risks and regulatory changes, not just responding to them. ✳️ From “what” to “how”: Translating high-level policy into practical, repeatable procedures. ✴️ From checklist to culture: Embedding risk management into everyday work to protect Controlled Unclassified Information (CUI). Compliance isn’t just a requirement for DoD contracts. It’s an opportunity to strengthen resilience, improve security, and build trust

This Compliance Management Framework is designed to establish a unified, strategic, and consistent approach to managing compliance obligations. It outlines the process for identifying, documenting, evaluating, prioritizing, and monitoring organization’s compliance requirements. The Framework also defines the roles, responsibilities, and accountabilities within the compliance structure and specifies the organization’s overarching approach to compliance management. To ensure a cohesive approach, the Risk and Compliance collaborates extensively with key representatives from various functions, leveraging their specialized knowledge in their respective fields.