Secure Controls Framework: Standardizing Security Controls for Global Governance

For complex global organizations, building an effective security and privacy program that spans multiple jurisdictions is a monumental challenge. The Secure Controls Framework approach to standardizing controls is instrumental when conflicting and overlapping compliance obligations from regulations like GDPR, CCPA, PCI DSS, SOC 2, and others create a tangled web of requirements that organizations must unravel. As a result, security and privacy teams often find themselves lost, siloed, and struggling to implement coherent global policies in the face of regulatory confusion.

This article provides guidance for multinational companies on how to take control of compliance complexity using Integrated Controls Management (ICM). ICM offers a methodology to streamline control definition, systematize procedures, and enable unified governance across diverse regulatory landscapes. By taking an ICM approach, security and privacy leaders can bring order to chaos when navigating the unique challenges of compliance in a complex global organization.

Secure Controls Framework for Standardizing Security Controls in a Complex Regulatory Environment

Multinational organizations face significant challenges in managing security and privacy programs that span multiple complex and conflicting regulatory landscapes across global jurisdictions. Large global enterprises must navigate an intricate web of broad privacy laws like GDPR and CCPA along with stringent industry-specific requirements such as PCI DSS in retail, SOX in financial services, SOC 2 in cloud services, and HIPAA in healthcare.

This complex labyrinth of overlapping and often contradictory compliance obligations creates major pain points:

• Regional and national teams end up managing compliance in silos, leading to fragmented efforts riddled with gaps as some requirements fall between the cracks. These disjointed efforts also result in redundant controls as different teams implement similar measures without coordination. These gaps and redundancies lead to unnecessary costs.
• Conflicting mandates across regimes make implementing cohesive global policies, security standards, and privacy controls a huge challenge. For instance, GDPR’s requirements for user consent and data portability differ drastically from CCPA’s approach. Organizations struggle to define consistent worldwide internal controls to meet contradictory dictates.
• The lack of centralized governance results in limited visibility and situational awareness of the overall compliance posture across the global organization. With regional silos, senior leadership lacks a consolidated view of whether critical compliance obligations are being met worldwide.
• Security and privacy teams get segmented into regional and national divisions, mapping localized controls in isolation based on specific local laws. This fragmentation dilutes expertise as staff lose sight of the bigger picture. It also hinders collaboration as coordination across borders becomes difficult.
• Finally, rationalizing and reconciling hundreds of pages of complex, contradictory requirements from various bodies of law and regulations becomes a monumental challenge. Specialists end up creating giant compliance matrices, trying to painstakingly map overlapping and conflicting dictates across regimes.

This amalgamation of challenges highlights why, without a rational methodology, compliance complexity breeds risk for global organizations. Taming this regulatory hydra becomes critical for security and privacy programs to succeed.

What is Integrated Control Management?

Integrated Controls Management (ICM) provides a methodology to unravel the tangled web of complex and conflicting compliance obligations. ICM enables organizations to consolidate, rationalize, and optimize controls across disparate regulatory regimes.

At its core, ICM creates a unified control framework by integrating requirements from major regulations like GDPR, CCPA, PCI DSS, SOC 2, etc. Duplicative controls are merged while gaps are filled to create a holistic control baseline tailored to the organization’s compliance landscape.

This centralized control set aligns with standardized global policies and procedures that balance consistency with regional nuances. Ongoing control metrics and audits based on the integrated framework provide visibility into compliance health across diverse regulatory environments.

The ICM methodology aims to bridge regional and functional silos by designating both centralized and localized owners for security controls. This unified approach replaces fragmented compliance efforts focused on isolated regimes.

For instance, Adobe uses an ICM approach to manage security and privacy compliance across its cloud services. By consolidating requirements from GDPR, CCPA, SOC 2, and ISO into a unified control framework, Adobe gained efficiency, consistency, and transparency across its global compliance program.

Digital Ventures Online consultants can assist organizations at every step of the ICM journey, from the initial assessment of compliance obligations and controls to planning and executing the integration process. Our experts help clients tailor and optimize a consolidated ICM framework aligned to their specific regulatory and business needs.

Bringing Order to Regulatory and Compliance Complexity

To unravel the tangled web of complex compliance obligations, global organizations need a rational methodology to bring order amidst regulatory chaos. Integrated Controls Management (ICM) provides such an approach with its emphasis on unified governance.

At its core, ICM establishes a centralized set of security and privacy controls that form the backbone of compliance across all jurisdictions. By consolidating requirements from various regulations like GDPR, CCPA, PCI DSS, SOC 2, and more into a unified control framework, ICM provides structure and consistency.

It provides a method to catalog and cross-reference all the various external compliance obligations globally. By collecting all regulatory requirements into one centralized taxonomy, ICM enables organizations to identify duplications and gaps.

For instance, mapping PCI DSS requirements against ISO 27001 controls would reveal areas of overlap and specific PCI DSS provisions not covered in ISO. ICM builds this consolidated superset of integrated controls tailored to the organization.

Industry-specific regulations like PCI DSS for retail and e-commerce, SOC 2 for cloud services, and SOX for financial services present additional challenges layered on top of broader requirements. ICM provides the methodology to reconcile and rationalize these diverse dictates into a unified control framework.

This consolidated set of standardized controls enables the global implementation of coherent policies, procedures, and practices. ICM takes a “unify then customize” approach, establishing a common global baseline for security and privacy while allowing for regional nuances.

With centralized control definition and policy setting, ICM also enables unified situational awareness and compliance posture worldwide. Global compliance metrics and audits against standardized controls provide visibility even within diverse regulatory environments.

For organizations struggling to reconcile conflicting requirements from GDPR, CCPA, PCI DSS, SOC 2, SOX, and more, ICM brings order from chaos. ICM provides a clear methodology to rationalize complex regulatory obligations and implement harmonized governance.

Right-Sizing Documentation

With varied and complex compliance landscapes spanning different regulations in multiple jurisdictions, organizations often end up with highly fragmented and disjointed regional policies and procedures.

For instance, the European division maintains localized ISO 27001 and GDPR focused policies, while the North American team has separate documentation tailored only to CCPA. The retail business has PCI DSS specific standards, while financial services drafts SOX-centric procedures. Cloud services maintain specialized SOC 2 controls apart from the rest.

This proliferation of localized, regulation-specific documentation results in highly duplicative, disconnected policies globally that hinder unified governance. Creating cohesive global standards becomes nearly impossible.

A major benefit provided by ICM is that it enables standardized global documentation consolidated across regulatory regimes. Rather than maintaining localized PCI DSS policies in North America and separate ISO 27001 and GDPR policies in Europe, ICM allows for a single, unified set of global policies, standards, and procedures.

These global documents are crafted based on the integrated control framework that rationalizes requirements from various bodies of regulation like PCI DSS, SOC 2, ISO 27001, and more.

While accommodating for important regional nuances, ICM’s centralized documentation approach ensures the foundational information security and privacy practices are instituted consistently on a worldwide basis per the global standards.

ICM also provides additional documentation efficiency through tools like control inheritance hierarchies and cross-references between policies. For instance, the global access control policy can reference subsidiary PCI DSS standards that drill down into cardholder data roles and access while also linking to SOC 2 controls on cloud access.

This methodology of consolidating documentation based on integrated controls enables right-sized policies, standards, and procedures that balance consistency with regionalization. The outcome is centralized, scalable documentation that brings order and cohesion amidst complex regulatory requirements.

Rationalizing Controls

With the complex compliance landscape spanning PCI DSS, SOX, ISO 27001, CCPA, GDPR, SOC 2, and more, global organizations struggle to make sense of the hundreds of pages of security and privacy controls dictated by each framework.

Requirements within each regime are written from different perspectives and with different industry focuses. For instance, PCI DSS provides prescriptive technical controls to protect cardholder data for retailers, while SOC 2 takes a cloud-centric approach for service organizations.

This results in vastly disparate, disconnected control frameworks that organizations attempt to map into silos. But this mapping exercise quickly turns into an intractable mess trying to track overlapping, conflicting, and duplicative controls across disparate frameworks.

ICM provides a much needed rational methodology to integrate related controls from diverse sources into a unified control set tailored for the organization’s specific compliance obligations.

For example, identity and access management controls scattered piecemeal across PCI DSS, ISO 27001, SOX, SOC 2, and CCPA can be consolidated into a comprehensive identity and access control framework. Duplicative controls get merged, while gaps are identified and filled.

In particular, ICM can integrate more granular technical controls from PCI DSS with higher-level policy and process controls from ISO 27001, SOC 2, and SOX to create a holistic control structure.

ICM creates a standard baseline for compliance that meets requirements and reduces complexity by building a superset of controls from all relevant regulations that don’t duplicate each other but do work well together.

This consolidated control set provides the foundation for consistent and unified global policies and procedures that bridge varied compliance frameworks.

A key benefit of ICM’s control integration process is that it reveals where substantive conflicts or inconsistencies exist between frameworks. For instance, while PCI DSS focuses prescriptively on specific technology safeguards around card data security, SOC 2 principles are centered on organizational process integrity for service organizations.

Making these distinctions explicit prevents misapplication of controls and streamlines reconciliation across frameworks. By surfacing divergences, ICM helps craft integrated controls that holistically address needs across compliance regimes.

Through this rationalization and reconciliation approach, ICM enables organizations to craft a unified control set that fulfills requirements from various bodies of regulations in a consistent, standardized way. This unified control baseline provides the foundation for effective global compliance governance.

Scaling Accountability

Effective compliance requires clearly defining ownership and accountability for implementing controls consistently across the global organization. These include cyber security, information security, data protection and other privacy controls.

However, assigning centralized and local control owners becomes extremely challenging in complex multinational environments with diverse regulations like PCI DSS, SOC 2, and SOX.

Without centralized accountability, localized regional teams end up bearing responsibility only for compliance in their geography based on local laws. For instance, the retail division owns only PCI DSS controls, while the cloud services team handles SOC 2 controls independently.

This fragmentation causes control gaps and duplications. But the alternative of solely centralized accountability also has drawbacks. Centralized teams lack regional expertise and visibility to manage localized compliance nuances worldwide.

ICM provides optimal flexibility in designating control owners and distributing accountability between corporate and regional stakeholders.

While ICM enables centralized owners to ensure consistency for core control categories like identity management, it also allows localization for targeted controls.

For instance, the Global CISO may own the identity and access management control framework. But regional CISOs would own implementation for systems and data specific to PCI DSS, SOC 2, or SOX based on their localized regulatory expertise.

The ICM methodology enables the parsing of control ownership between central and local parties. For example, central GRC teams may own policies while regional IT and security own system provisioning based on localized needs.

By mapping controls to appropriate accountable stakeholders, whether at corporate or regional divisions, ICM drives effective compliance accountability across the global organization.

This matrixed allocation of centralized and local ownership allows optimization for consistency, coordination, and regionalization simultaneously.

Maintaining Assurance

Within complex global organizations spanning multiple regulatory regimes, maintaining clear visibility into overall compliance health and posture becomes extremely challenging.

With disjointed regional teams implementing fragmented, localized controls based on specific regulations like PCI DSS, SOC 2, or SOX, senior leadership lacks a consolidated view of whether critical compliance obligations are being met worldwide.

This also hampers risk assessment and auditing, which are conducted in silos tied to particular frameworks, creating blind spots and inefficiencies.

ICM enables centralized visibility and assurance across diverse compliance frameworks by instituting standardized control assessment, audits, and reporting applied consistently across the global organization.

Instead of relying on regional audits and metrics that are just for PCI DSS or SOC 2, ICM uses integrated assessments and reporting that are tied to the unified controls framework.

For instance, global audits assess identity and access management controls across systems and data subject to GDPR in Europe, CCPA in California, PCI DSS for card data, SOC 2 for cloud services, and SOX for financial reporting. This provides a consolidated view of maturity and risks.

Ongoing control testing and metrics are also conducted centrally against the integrated framework. This enables continuous monitoring and benchmarking regardless of differences in regional regulations.

Consolidated control dashboards and risk reporting provide senior leadership and board oversight with efficient visibility into critical security and privacy compliance positions globally across all major industry and jurisdictional regulations, like SOC 2.

For example, unified dashboards surface reports on identity and access controls across assets in scope for GDPR, CCPA, PCI, SOC 2, and SOX simultaneously based on a shared set of ICM controls.

By aligning assessments, audits, and metrics to centralized ICM controls rather than fragmented regional documentation, organizations can maintain clarity and effectively govern compliance across complex global regulatory obligations.

Final Thoughts

In the face of conflicting and overlapping compliance obligations, complex global organizations often find themselves navigating a turbulent sea of regulatory complexity. With the reach of multinational companies spanning diverse jurisdictions and industries, they grapple with a hydra of requirements from privacy laws such as GDPR and CCPA to rigorous frameworks like PCI DSS, SOC 2, and SOX.

This chaotic amalgamation of fragmented and contradictory regulations wreaks havoc within security programs, making the task of implementing coherent policies and controls an arduous endeavor. The clashing requirements, regional silos, and disjointed efforts further complicate governance. Duplicative controls inflate costs, while gaps in compliance pose risks.

To instill order amid this regulatory turmoil, global enterprises must look towards Integrated Controls Management (ICM) as a beacon to guide effective compliance. ICM serves as a unifying methodology, standardizing controls and rationalizing diverse requirements into a consolidated framework.

At the heart of ICM lies a tailored set of standardized controls that serves as the backbone for fulfilling compliance obligations across various frameworks, including SOC 2. Centralized policies are tailored for consistency and scalability across different regions, while shared metrics and audits enhance visibility into the global compliance health.

For multinational firms caught in the storm of complex regulatory seas, ICM offers a means to chart a clear course. Acting as a compass, it enables organizations to standardize controls, rationalize conflicting obligations, and streamline governance.

ICM transforms compliance from a source of conflict into a cornerstone of stability by emphasizing unification, integration, and consolidation. Rather than succumbing to chaos, ICM provides a pathway to consistency and cohesion even in the most intricate compliance landscapes.

As data security and privacy regulations continue to grow across jurisdictions, standardizing controls through ICM is emerging as an essential methodology for multinational organizations aiming for effective global governance.

Should you have any inquiries about implementing an ICM approach or wish to engage Digital Ventures Online for planning and execution, please don’t hesitate to reach out for a consultation. Our experts are ready to provide guidance on rolling out ICM, aligning it with your specific compliance landscape and requirements, and thereby standardizing controls to navigate the complex world of regulations.