9 Essential Elements of a Compliance Program

November 26, 2024

After a Change Healthcare data breach exposed the private information of at least 100 million Americans, investigators tied the hack to a basic cybersecurity failure: stolen credentials and servers with no multifactor authentication. In 2018, Uber had to pay nearly $150 million for trying to cover up a major data breach in 2016. An effective compliance program could have prevented both of these situations. Help your organization avoid similar problems by following the essential elements of any compliance program.

How Do You Determine the Most Important Elements of Your Compliance Program?

What are the most important elements of a compliance program?

The purpose of a compliance program is to meet regulatory requirements and industry standards. It’s not just your organization as a whole that needs to meet these obligations, but also individual employees.

Your objectives determine the best type of compliance framework and your priorities:

  • Client requirements: Many customers expect ISO 27001 compliance, SOC 2 certification, or third-party audits.
  • Finance: Lenders and investment firms need a compliance program that follows SEC, FINRA, SOX, and Federal Reserve Board rules.
  • Software and cloud platforms:SaaS and PaaS developers often need to follow PCI DSS regulations for storing and encrypting cardholder data.
  • Defense contractors: Businesses in the DoD supply chain need to comply with NIST 800-171 and CMMC.

Compliance programs can also include internal standards. Many manufacturers have higher standards than the minimum required by law.

What Are the Essential Elements of a Compliance Program?

The following principles are vital for virtually every industry and enterprise.

1. Clear Policies and Standards of Conduct

Ensure workers are consistently informed of organizational rules to encourage compliance. Put your compliance program in writing and make it readily available to your team. Add any modifications or updates to your compliance guide immediately.

Make sure your guidelines are easy to understand and specific. For example, look at the way the PCI DSS framework outlines requirements:

  • 2.0: Do not use vendor-supplied defaults for system passwords and other security parameters.”
  • 4.1:Use strong cryptography and security protocols to safeguard sensitive cardholder data during transmission over open, public networks (e.g. Internet, wireless technologies, cellular technologies, satellite communications)
  • 10.0:Track and monitor all access to network resources and cardholder data.”

Even though each item is brief, it’s clear exactly what compliance involves.

2. Assigned Officer or Oversight Committee

Having an oversight committee is an important element of a compliance program.

An effective compliance program needs someone to make decisions and accept responsibility for implementation. This individual or group should have significant expertise in the assigned area of compliance.

A committee is ideal because you can draw from a pool of InfoSec, legal, and management experience. This committee should review your compliance policies at least once a year, keeping up with industry and regulatory changes.

3. Detailed Analysis of Risk and Scope

You can make compliance more efficient and less complex by understanding exactly what type of sensitive data your organization handles and what regulations come into play. This requires a thorough risk analysis.

In addition to identifying current compliance obligations, your compliance committee should stay up to date with emerging cybersecurity threats and regulatory changes, such as the California Consumer Privacy Act.

4. Compliance Training and Ongoing Education

Include compliance orientation as part of the onboarding process for new employees. Periodically refresh your staff on regulations and company policies. Considering that nearly 75% of data breaches happen because of human error, and the average cost of a single breach is almost $10 million, investing time in compliance training is money well spent.

Cybersecurity education should include helping employees recognize and avoid phishing attempts. For healthcare businesses, HIPAA training should include mobile device best practices, like never leaving devices unlocked or signed in when unattended.

5. Avenues for Employee Communication

Forced compliance is less effective than building good habits, such as regular training, open communication, and encouraging employee participation in compliance processes. In other words, instead of fighting your employees, encourage compliance by putting them on your side.

Compliance officers should be approachable and ready to answer questions, allay concerns, and explain the reasons for policies. Sometimes, you may discover better ways to reach the same objective but with less effort required.

Case in point? NIST recently changed password complexity requirements, recognizing that they caused more trouble than solutions. Instead, longer but easier-to-remember passwords and multifactor authentication are the new normal.

Good employee communications for compliance programs also require anonymous channels for reports and ethical violations. It’s in the organization’s best interests to detect issues and breaches quickly. Still, employees may hesitate to report superiors because of fear of retaliation. Anonymous channels get around the problem.

6. Continuous Monitoring and Auditing

Continuous monitoring and auditing is an important element of a compliance program.

Even well-oiled machines need periodic maintenance. Similarly, passing a compliance check years ago isn’t good enough. Enterprises should schedule external audits at least once a year.

These audits are mandatory for SOC 2 compliance and many other cybersecurity frameworks. To have the best chance of passing regulatory or client-required audits, conduct internal audits at more frequent intervals.

7. Compliance Reports and Records

It’s like the old “if a tree falls in the woods” adage. Compliance counts most when you have the evidence to back it up. Compliance programs should have policies for document retention, especially where certification is concerned. Compliance software with automated workflows can streamline report generation and storage significantly.

8. Enforcement

Unfortunately, enforcing compliance sometimes requires disciplinary actions. These shouldn’t be random or subjective. Your compliance program needs to clearly spell out appropriate penalties for violations, from verbal warnings to termination.

In addition to non-compliance, reasons for discipline include failure to report and gross negligence, blatant errors that reveal poor job quality. Of course, there are times when extenuating circumstances come into play, such as miscommunication between departments.

9. Prompt Corrective Actions

Your compliance committee needs teeth. It should have the authority to order decisive action when necessary. If you have a data breach, acting quickly can minimize the extent of damage significantly. Ideally, the compliance committee should answer only to a vice president or CEO.

How To Streamline Important Parts of a Compliance Program

Compliance is worth the cost, but there are ways to make it more cost-effective, too. One of the best ways to simplify the elements of a compliance program is by using SaaS solutions. A unified platform helps you monitor compliance, create reports, track progress, view user activities, and create roadmaps for rigorous regulatory frameworks. See how Compyl can save you time and money right away.

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