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Lockdown Chaos and Compliance: Better and Faster with CISO On Demand

J.S. Held Releases Insights on Risks & Opportunities Expected to Impact Organizations in 2025

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Anyone who is working toward or has already achieved some kind of certification will know that getting there is difficult, time- and resource-consuming, and requires buy-in and input at all levels, especially from those at the top.

It might be a legal requirement for an industry, such as HIPAA or PCI/DSS, or it might provide assurances to current and prospective clients, like many companies aiming for SOC 2 or ISO 27001.

Whether it's for the first time or in preparation for a future audit, it’s likely that in recent weeks, various control requirements that were thought to have been locked down would have been stretched to a breaking point.

Even the best-laid "stay at home" disaster recovery scenario may not have anticipated all the effects caused by so many partner businesses, third-party suppliers, and so on having to make similar drastic changes.

Let's consider a couple of common requirements where compliance might have gone slightly awry:

  • A company followed the "stay at home" scenario in its business continuity plan. How do the results compare with expectations following findings from the most recent business continuity contingency experiment? Many companies did not bother to test the plans appropriately before signing off and may now find themselves in difficult positions.
  • A company is required to ensure its firewall is correctly configured and updated. How does this apply now to remote working employees’ computers, which find themselves behind a variety of consumer-grade firewalls, all individually configured?
  • A company signed up for a new cloud backup provider so users wouldn’t make insecure backups at home. Did the company ensure that its vendor selection processes were followed? For example, do these backup actions fit into the outlined requirements for security controls and compliance?

Additionally, and crucially, if these points have been covered, is it possible to produce evidence of how they were implemented and how they are configured and used to protect the environment and the data?

To be sure, nothing has stopped in the world of compliance. Controls must still be adhered to. Audits must still take place. In fact, because of the likelihood of compliance controls not being adhered to, organizations such as AICPA are pumping out information on how auditors can conduct effective remote audit.

As long as virtual meetings can still happen, it will still be necessary to gather the information and evidence needed according to the schedule.

There are many actions that need to be taken right now, especially if an audit is just around the corner:

  • Carry out a risk assessment to establish how the changes implemented affect the normal control objectives. Gather evidence and establish whether policies and procedures were fit for purpose.
  • Contact the certification partner to understand both the company's situation and theirs and create a new action plan and schedule.
  • Coordinate with internal stakeholders. Many people in IT and in high-level management are doing little else but firefighting at the moment, but the auditing schedule will have to be viewed as a priority. Continued certification is of fundamental importance to any business that hopes to thrive in the "new normal" economy.
  • Communicate with external stakeholders. If clients or the law require companies to continue to be certified then the results of audits will be looked for. If there is a legitimate delay then this must be transparently communicated.

This would be a challenging task at the best of times. Simply arranging a meeting of internal stakeholders who work in the same building can be quite difficult. When so many actions and people need to be coordinated in a short time, it may be necessary to have an additional level head to help coordinate the strategy, prepare the evidence and documentation, and bring the various stakeholders together. For a good resource to help better understand what might be involved, see the NIST cybersecurity requirements.

We are all in uncharted territory, but businesses must ensure that compliance is maintained. With a CISO on demand, it is possible to get the specialized talent and experience needed right now to navigate this most difficult of times. The regulatory process can be completed quickly and, of course, this means not having to employ a new member of staff with all the time and cost that entails.

Acknowledgments

We would like to thank Kevin Gorsline for providing insight and expertise that greatly assisted this research.

Kevin Gorsline is a Managing Director in J.S. Held's Global Investigations Practice who joined following J.S. Held's acquisition of TBG Security. For several years, Kevin served as the Chief Operating Officer and head of the Risk and Compliance practice at TBG Security, where he was responsible for providing the leadership, management, and vision necessary to ensure that the company had the proper operational controls, administrative and reporting procedures, and people systems in place to effectively grow the organization and to ensure financial strength and operating efficiency. His experience and leadership throughout his career have been focused on developing and delivering information security services and solutions, providing outstanding client service, and driving profitable revenue growth. Kevin brings established proficiency as an IT leader with extensive experience in risk and compliance services, applications development, and implementation projects both in the United States and abroad.

Kevin can be reached at [email protected] or +1 843 890 8596.

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This publication is for educational and general information purposes only. It may contain errors and is provided as is. It is not intended as specific advice, legal, or otherwise. Opinions and views are not necessarily those of J.S. Held or its affiliates and it should not be presumed that J.S. Held subscribes to any particular method, interpretation, or analysis merely because it appears in this publication. We disclaim any representation and/or warranty regarding the accuracy, timeliness, quality, or applicability of any of the contents. You should not act, or fail to act, in reliance on this publication and we disclaim all liability in respect to such actions or failure to act. We assume no responsibility for information contained in this publication and disclaim all liability and damages in respect to such information. This publication is not a substitute for competent legal advice. The content herein may be updated or otherwise modified without notice.

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