In today’s business landscape, organizations are realizing the importance of adopting a proactive and strategic approach to compliance. As highlighted by A-LIGN’s 2023 Compliance Benchmark Report, the demand for compliance is evident, with a significant number of organizations (72%) conducting audits or assessments to win new business.
The need for strategic compliance is further underscored by the frequency of audits, the time spent preparing for them, and the benefits of consolidating audits. In this blog, we delve into the concept of strategic compliance and explore how organizations can develop a master audit plan to streamline their compliance program. We also discuss the value of consolidating audits and auditors, leveraging technology, and the journey toward compliance maturity.
Embrace strategic compliance with a master audit plan (MAP)
Strategic compliance requires a fundamental shift in the way that organizations approach their compliance program away from tactical and reactive audits to a more strategic and proactive compliance program. Strategic compliance elevates singular audits into an ongoing process of risk assessments, monitoring and reporting, and continuous improvement. Planning, testing and assessing, and optimization are cornerstones of strategic compliance.
A master audit plan (MAP) is at the heart of strategic compliance. Developing a MAP includes reviewing current processes, establishing a schedule of upcoming audits, consolidating audits and auditors as needed, and delivering an efficient and scalable audit program.
Consolidate audits and auditors
Consolidating audits and auditors is one of the most effective approaches to enhancing the efficiency of a compliance program. Conducting multiple audits as a coordinated effort can reduce duplication of work and ensure consistency across the audit process.
The first step toward consolidating audits and auditors is to review which audits and auditors can be consolidated. Most audits can be consolidated under a single auditor, but certain compliance frameworks may have specific requirements to be conducted independently. Once you have determined which audits you want to consolidate, seek an audit firm that provides the widest breadth of coverage for those audits.
The process of consolidating audits and auditors should be outlined within the MAP. For example, a MAP could define the objectives and expected outcomes of the audits. Organizations should also include key activities, timelines, resources, roles, and responsibilities when they develop their MAP schedule. Likewise, this process should be continuously monitored and assessed.
Leverage technology with auditor expertise
In the process of consolidating audits and auditors, organizations should also consider how audit software solutions can further increase the efficiency of their compliance program — particularly if an audit service provider can provide a compliance management solution as part of their service.
Start by reviewing the audit requirements and determining which features of compliance management software are important to you. Then, talk to your audit service provider about their software solutions or research other options to find the right solution for you needs. Commonly requested features include the ability to automate audit workflows, integrate with other systems, generate reports and analytics, provide continuous compliance monitoring, and deliver the final compliance report.
Compliance is a journey toward maturity
Ultimately, fostering a culture of strategic compliance takes time. This transformation requires investing resources into assessing audit requirements and researching the capabilities of service providers. Consolidation does not happen overnight — some compliance frameworks may take a year or more to fully transition from one audit service provider to another.
Even as an organization begins their journey toward compliance maturity, their audit processes may still seem tactical and ad hoc. Over time, as technology is introduced and compliance becomes a proactive, strategic function, these processes tend to become more well-managed and consolidated. Eventually, with the right compliance framework and process, it can be optimized as a competitive advantage across departments.
Learn more about strategic compliance in A-LIGN’s 2023 Compliance Benchmark Report.
Leveraging HITRUST Gap & Diagnostic Assessments to Identify Gaps between CSF Versions
On January 18, 2023, HITRUST launched the latest version of its framework, HITRUST CSF v11, which brings significant changes compared to the previous version, HITRUST CSF v9.6.
HITRUST understands the importance of keeping organizations up to date with the evolving threat landscape and ensuring compliance. With the release of HITRUST CSF v11, they have redesigned the framework to enhance the efficiency of the assessment portfolio and its relevance to cyber threats. The primary goal of this new framework is to enable organizations to stay prepared for current threats and identify appropriate measures to protect their data.
The update includes the introduction of new controls and requirements, modifications to existing ones, and updates to risk factors and scoring methodology. Additionally, HITRUST CSF v11 offers enhanced security and risk management capabilities, increased flexibility for organizations, and improved alignment with other frameworks and regulations.
Here are some of the key benefits that organizations can expect from the new HITRUST CSF v11 framework:
- Cyber Threat-Adaptive Assessments: The new framework and controls leverage threat intelligence information to proactively defend against the latest cyber threats, such as phishing and ransomware.
- Expanded and Aligned Assessment Portfolio: This updated framework provides a comprehensive approach that addresses diverse assurance needs for different risk levels and compliance requirements. It offers greater assurance reliability compared to other assessments.
- Traversable Assessment Journey: A new feature introduced in HITRUST CSF v11, traversable assessments allow organizations to reuse lower-level HITRUST assessments, progressively achieving higher levels of assurance by sharing common control environments and inheritance.
- Reduced Level of Effort: The selection and specification of controls ensure that the most relevant ones are in place, eliminating redundancy. This streamlines the HITRUST certification process, reducing the time and effort required and helping organizations obtain credentials in a timely manner.
- Expanded Authoritative Sources: AI-powered improvements increase speed, efficiency, and automation for organizations. The update includes additional sources like NIST SP 800-53, Rev. 5, and HICP, along with refreshed mappings for HIPAA, NIST CSF, and NIST 800-171.
Tips for Businesses Transitioning from HITRUST CSF v9.6 to v11
Considering the significant changes in the new HITRUST CSF v11 framework, organizations should keep the following points in mind during their transition from v9.6 to v11:
- Communication and Training: It is essential to communicate the changes to all employees and provide necessary training to ensure awareness of the new requirements and individual responsibilities in compliance.
- Update Risk Management Program: Align the risk management program with the newly outlined risk factors and scoring methodology in HITRUST CSF v11.
- Review Controls and Requirements: Evaluate the new controls and requirements in v11 and identify any gaps in the current compliance posture of the organization.
To facilitate a smooth transition and address any critical control gaps, it is recommended to collaborate with a trusted cybersecurity and compliance partner. A detailed HITRUST gap assessment or diagnostic assessment conducted by such a partner, like A-LIGN, can help organizations:
- Align with industry standards and the new framework
- Mitigate risks and vulnerabilities
- Improve operational efficiency
- Enhance trust and reputation with customers, stakeholders, and partners
To ensure that your business effectively addresses any critical gaps in controls, A-LIGN offers a comprehensive HITRUST gap assessment. The HITRUST gap assessment is designed for organizations that have previously undergone the HITRUST certification process. The gap assessment involves a focused evaluation of the controls that have changed between frameworks, identifying any gaps, and providing recommendations.
This gap assessment becomes crucial when there are changes in the HITRUST standard, such as transitioning from v8 to v9 or from v9 to v11. Additionally, changes to scoring rubrics used to determine how controls are evaluated can also lead to the requirement of a HITRUST gap assessment. For example, if an organization previously scored 100% on their controls based on a less rigorous rubric, the updated rubric may yield a lower score, indicating the need for additional work.
This process allows for targeted testing and ensures businesses remain aligned with the updated standards. The gap assessment by A-LIGN provides valuable insights, helps customers maintain compliance with the latest HITRUST standards, and offers a tailored approach based on their specific needs and resources.
A-LIGN also offers a diagnostic assessment for organizations transitioning from HITRUST v9.6 to v11. This assessment generally compares previous version controls like v9.6 to an updated version like v11 framework. The diagnostic report provides best practice recommendations on how to address changes between versions based on the CSF general control library. It does not consider the specific requirement statements of an organization like the gap assessment described above does.
Organizations with a mature control environment and a compliance team could leverage the general comparison and recommendations offered in a diagnostic assessment to make the necessary changes needed to complete a validated assessment against the new CSF version. Following the diagnostic assessment, your business will receive a general comparison report outlining the identified gaps and providing recommendations on how to close them. This will enable your organization to maintain compliance and stay up to date with the latest framework.
If your organization has never done a HITRUST Assessment before, a full readiness assessment is recommended. In contrast to the gap assessment or diagnostic assessment that only provides gaps and recommendations for controls that changed between two CSF versions, the full readiness assessment reviews the scope of every single control requirement.
If your business is currently navigating the changes brought about by HITRUST CSF v11 and would like to undergo a diagnostic assessment or gap assessment to identify any gaps, we encourage you to reach out to the A-LIGN team. Our experienced professionals are available to provide further information and guidance on which assessment will be most beneficial to your organization.
Contact us today to learn more about our services and how we can support you during this transition period.
Download our HITRUST checklist now!
As the focus on cybersecurity continues to rise, many organizations are realizing that maintaining compliance and keeping their systems safe can come with many challenges. While consolidating audits and auditors is one way to streamline the process, compliance management software is another.
More than nine out of ten organizations are now using audit software solutions, up from 71% in 2022, according to A-LIGN’s 2023 Compliance Benchmark Report.
In this blog, we will discuss the benefits of compliance management software and highlight some of the most popular and in-demand features and capabilities that organizations should consider when evaluating compliance management software.
What are the benefits of compliance management software?
Once an organization realizes the business value of compliance, they may want to implement more efficient compliance processes. Compliance management and audit software is one way that organizations can consolidate their audit process. The benefits of compliance management software include:
- Efficiency: Using compliance management and audit software has the obvious benefit of saving organizations time and improving their efficiency by streamlining the audit process. Organizations can reduce the internal resources required by automating tasks such as evidence collection and project management. This can help organizations to reduce costs, save time, and focus their resources on other important business activities.
- Consistency: Organizations can ensure that their audits are conducted consistently across different business units and locations by using a standardized audit software solution. Consistency can help to reduce the risk of errors in the audit process.
- Visibility: Compliance management and audit software can provide organizations with improved visibility into the audit process, such as progress tracking, status updates, and compliance assessments. By continuously monitoring compliance state, organizations can identify issues or gaps more quickly, and work to remediate these risks before they disrupt their business.
Overall, the use of compliance management and audit software solutions can provide organizations a competitive advantage by improving their efficiency, accuracy and decision-making.
How to evaluate compliance management software
When it comes to compliance management and audit software, there are a lot of options. A-LIGN’s 2023 Compliance Benchmark Report provides benchmarking data to help organizations determine the most popular and in-demand features for these solutions.
A-LIGN’s survey found commonly mentioned features, including:
- Evidence Collection: More than half of respondents reported that their compliance management software collects evidence required for their audit. A centralized approach to evidence collection can streamline what can otherwise be a time-consuming and complex process. Organizations can achieve even greater efficiency with automated evidence collection.
- Task Management: More than half of respondents reported that their audit software helps manage the process with features like task assignment, tracking, and reporting, which can help ensure audits are completed on time and with accountability.
- Gap Assessment: Almost half of respondents reported that their audit solution helps to assess gaps before the audit, which can identify potential compliance issues in advance, enabling organizations to address them proactively.
- Compliance Reporting & Analytics: Almost half of respondents reported that their audit software solution helps to prove compliance, which could include features such as automated reporting and analytics. Reports generated by the software can help demonstrate compliance and identify areas for improvement.
- Policy Implementation: Less than half of respondents reported that their audit software solution helps to implement policies needed for the audit, which could include features such as policy templates and workflows for policy review and approval. This also includes ensuring that policies and procedures are in place and up-to-date.
- Continuous Monitoring: Only about a quarter of respondents reported that their audit software offers continuous compliance monitoring, which can help identify issues in real-time and enable organizations to take corrective action more quickly. It is worth noting that continuous monitoring is now the most in-demand feature for organizations evaluating audit software solutions.
Ultimately, compliance management and audit software solutions can simplify, centralize, and organize audit processes that may otherwise be time-consuming and complex. Furthermore, more advanced solutions offer continuous monitoring and automated processes to enable even greater efficiency.
How to streamline the audit process with A-SCEND
A-LIGN’s automated compliance management software, A-SCEND, is an end-to-end audit solution. From readiness and evidence collection to reporting and certification (and more), A-SCEND streamlines the full audit lifecycle. Key features and benefits include:
- Automated Evidence Collection: Save time and resources.
- Cloud Integrations: Accelerate readiness to reporting.
- Continuous Monitoring: Reduce security and compliance risks.
- Policy Center: Access industry best practices at your fingertips.
- Automated Readiness Assessments: Get audit ready in half the time.
- Consolidated Audit Requests: Easily satisfy multiple audit requirements with one click.
To learn more about the strategic benefits of compliance, read A-LIGN’s 2023 Compliance Benchmark Report.
Contact A-LIGN to learn more about how A-SCEND can streamline your audit process to drive a competitive advantage for your organization.
Cybersecurity compliance is a competitive advantage. Cybersecurity compliance enables organizations to improve their security posture, comply with industry regulations, and to demonstrate the effectiveness of their cybersecurity controls to customers and partners.
However, despite the benefits, many organizations struggle with the challenges of their compliance program. According to A-LIGN’s 2023 Compliance Benchmark Report the greatest compliance strategy challenge is that audits are reactive, driven by customer requests versus internal management. The greatest audit process challenge is limited staff resources.
In this blog, we will share results from A-LIGN’s 2023 Compliance Benchmark Report to highlight some of the greatest challenges and provide tips for organizations that want to implement a more strategic compliance program.
The Challenge of Ad-Hoc Audits
The greatest challenge related to compliance strategy is that audits are ad-hoc and assessments are conducted at the request of customers or other stakeholders. There are several issues associated with this challenge:
- Reactive Approach: Ad-hoc audits are often conducted in response to a specific request, rather than as part of a proactive compliance program. This reactive approach can leave the organization vulnerable to compliance gaps that may not be identified until an audit is conducted.
- Lack of Consistency: Ad-hoc audits may be conducted differently each time, depending on the requirements of the customer or partner. This can lead to inconsistent audit findings and make it difficult to identify trends or patterns in compliance reports.
- Resource-intensive: Ad-hoc audits can be resource-intensive, as they require the organization to divert staff and resources to meet the requirements of each audit request. Frequently, this results in the duplication of work (such as collecting evidence). This can be a burden on the organization, especially if they are receiving multiple audit requests, but managing them individually.
Other challenges related to compliance strategy include the difficulty keeping up with new compliance requirements and the lack of a coherent compliance strategy entirely. When you consider these issues, it is clear that organizations would benefit by implementing a more strategic compliance program that proactively pursues and consolidates audits.
The Challenge of Limited Resources
When it comes to the specific challenges of the audit process, the greatest challenge for most organizations is limited staff resources dedicated to compliance. Organizations with limited resources will compound the challenge of conducting ad-hoc audits (and the issues associated with them). Additional issues related to limited staff resources include:
- Incomplete or inadequate assessments: With limited staff resources, auditors may not be able to conduct comprehensive assessments. This can result in incomplete or inadequate assessments that leave an organization without compliance certification.
- High turnover: Limited staff resources can result in high turnover, as employees may find themselves overworked or burnt out. This can create gaps in compliance expertise and result in a loss of institutional knowledge.
- Missed regulatory deadlines: When new regulatory compliance mandates emerge, a lack of staff resources may result in missed deadlines and compliance failures.
If an organization has limited resources dedicated to their audit process, then it is a strong indication that their cybersecurity program is lacking, which in turn makes them more likely to fall victim to a cyberattack.
Another major challenge for the audit process is the complexity of conducting multiple audits. Many organizations are subject to multiple compliance frameworks or regulations, each with their own specific requirements and reporting standards. Conducting audits across multiple frameworks can be complex and time-consuming, requiring significant staff resources and coordination.
To effectively manage these challenges, organizations should once again consider streamlining their audit process by identifying areas of overlap to reduce duplication of efforts or investing in audit technology that automates compliance management. And of course, choosing the right audit service provider can go a long way in alleviating limited staff resources and the complexity of conducting multiple audits.
Overcoming Challenges with Strategic Compliance
The challenges associated with cybersecurity compliance can be significant, particularly when it comes to conducting audits and managing the overall compliance process. However, by streamlining compliance frameworks and leveraging automated compliance management platforms, organizations can take steps to address these challenges and improve their compliance posture.
Consolidating audits and automating compliance processes can help reduce duplication, improve efficiency, and ensure that compliance requirements are being met consistently across the organization. Ultimately, investing in these strategies can help organizations to stay ahead of emerging threats and protect their sensitive data and systems against cyberattacks.
Learn more about the most common cybersecurity compliance challenges and best practices for strategic compliance — Read A-LIGN’s 2023 Compliance Benchmark Report.
As cyberattacks continue to grow and evolve, cybersecurity has become a top concern for organizations of all sizes and industries. One way that organizations can protect themselves and demonstrate their commitment to cybersecurity is by establishing and maintaining robust compliance programs.
Compliance with recognized cybersecurity frameworks and standards can help organizations build trust with existing and potential customers and partners by demonstrating that they have implemented effective security controls to protect sensitive data and systems.
In this blog, we will share statistics from A-LIGN’s 2023 Compliance Benchmark Report that demonstrate the benefits of using cybersecurity compliance as a competitive advantage. Read on for tips that will help you leverage compliance as a way to win new business.
The Benefits of Cybersecurity Compliance
One of the primary benefits of cybersecurity compliance is that it can help organizations improve their overall security posture. Compliance with cybersecurity frameworks can help organizations identify and address security weaknesses and vulnerabilities, reducing the risk of cyberattacks and data breaches. With the right assessments and certifications, organizations can establish effective security policies and procedures that can help prevent cyber incidents before they happen.
Many industries are subject to legal and regulatory requirements related to cybersecurity. In these cases, compliance isn’t a nice-to-have, it is an obligation. Maintaining compliance helps organizations avoid potential legal or regulatory penalities or reputational damage resutling from non-compliance.
Beyond regulatory requirements and basic security, compliance can also provide organizations with a competitive advantage in the marketplace. By demonstrating that they have implemented effective security controls, organizations can differentiate themselves from competitors who may not have implemented similar controls or who have experienced cybersecurity breaches in the past.
With the right certifications and controls and a strategic plan for highlighting the value of compliance, organizations can win new business and expand their customer base. If two organizations are competing for a customer’s business, the one with a more robust compliance program is often viewed as the more trustworthy option.
According A-LIGN’s research, the majority of organizations (72%) have conducted an audit or assessment to help win new business. Conversely, 29% of organizations have lost a new business deal because they were missing a compliance certification. This demonstrates that audits and assessments are an important aspect of the sales process since they can validate the effectiveness of an organization’s cybersecurity controls.
Tips for Leveraging Cybersecurity Compliance as a Competitive Advantage
There are numerous cybersecurity frameworks and standards to choose from, each with its own set of requirements and controls. It’s important for organizations to choose the framework that best aligns with their business needs and risk profile. Organizations should also consider the compliance requirements of their customers and partners. The A-LIGN 2023 Compliance Benchmark Report includes benchmarking data that can help organizations select the cybersecurity framework that is best suited for their industry.
Cybersecurity compliance requires organizations to implement effective security controls. It’s important for organizations to take a risk-based approach to control implementation, focusing on the controls that are most critical to their business and risk profile. Organizations should also ensure that controls are regularly reviewed and updated to ensure their ongoing effectiveness.
Most importantly, organizations should adopt strategic compliance initiatives, such as consolidating audits and auditors to save time and money. Implementing audit technology solutions, such as A-LIGN’s automated compliance management platform, A-SCEND, enables organizations to automate evidence collection and continuously monitor compliance to discover and remediate compliance risks.
Cybersecurity compliance has become such a competitive advantage that the C-suite has taken notice. According to A-LIGN’s survey results, when asked about the driving force behind their compliance program, there was an even split between the desire to increase revenue/win new clients and a mandate from the board-level or C-suite. These results suggest that even at the highest level, organizations recognize that cybersecurity compliance is a competitive advantage.
To learn more about the competitive advantages of strategic compliance, read A-LIGN’s 2023 Compliance Benchmark Report.
We are thrilled to announce that A-LIGN has received ISO/IEC 27001:2022 accreditation (ISO 27001) from the ANSI National Accreditation Board (ANAB) on May 17, 2023. This accreditation expands A-LIGN’s portfolio of ISO certification service offerings, which includes ISO/IEC 27001:2013 (ISO 27001 2013), ISO/IEC 27701:2019 (ISO 27701) and ISO 22301:2019 (ISO 22301) and allows us to remain at the forefront of industry standards.
Curious about the key differences between ISO 27001 2013 and the new 2022 edition? We’ve got you covered with a quick summary of the 9 most important changes. If you’re hungry for more details, tune in to our webinar from April.
1. Updated context and scope
ISO 27001:2022 places increased emphasis on understanding the context of the organization, including its internal and external factors that may impact the information security management system (ISMS). This update encourages organizations to conduct a comprehensive analysis of interested parties, necessary processes, and roles within the ISMS.
2. Statement of Applicability (SoA)
While the requirements for the SoA itself remain largely unchanged, the updated controls in ISO 27001:2022 necessitate a revised SoA. Organizations should review their existing SoA from the 2013 version and make adjustments to incorporate a mapping of the 2022 controls. This demonstrates preparedness for the revised standard and facilitates effective communication with stakeholders.
3. Controlled changes to the ISMS
A notable addition in ISO 27001:2022 is Clause 6.3, which focuses on controlled changes to the ISMS. It requires organizations to carry out planned changes to the ISMS when the need arises, emphasizing the importance of a structured and systematic approach to managing changes within the system.
4. Enhanced operational planning and control
ISO 27001:2022 introduces additional guidance in Clause 8.1 for operational planning and control. Organizations are now required to establish criteria for actions identified in Clause 6 and control those actions accordingly. The standard also highlights the need to control any externally provided processes, emphasizing the importance of managing third-party relationships.
5. Reorganization and reduction of annex controls
One of the most significant changes in ISO 27001:2022 is the reorganization and reduction of annex controls. The number of controls has been reduced from 114 to 93, simplifying the categories and aligning them more effectively with the current hybrid and remote work environments. This update acknowledges the evolving nature of technology and aims to ensure the standard remains relevant and efficient.
6. Introduction of new controls
ISO 27001:2022 introduces 11 new controls in the annex section, covering areas that were already being practiced by organizations but are now formally included in the standard. These new controls address emerging threats and challenges, such as threat intelligence, information security for the use of cloud services, ICT readiness for business continuity, and more.
7. Recategorization of controls
To improve clarity and organization, the controls in ISO 27001:2022 have been recategorized into four main categories: organizational, people, physical, and technological. This reorganization simplifies the structure and enhances the standard’s usability, allowing organizations to more easily identify and implement the relevant controls.
8. Emphasis on needs and expectations of interested parties
ISO 27001:2022 adds a requirement in Clause 9.3 for management review to consider changes in the needs and expectations of interested parties. This highlights the significance of aligning the ISMS with the evolving priorities and requirements of stakeholders, enabling organizations to adapt and respond effectively to changes in their operating environment.
9. New controls for current challenges
The updated standard introduces controls that address current challenges and technologies. As these challenges continue to evolve in the industry, updates focus on staying current and relevant. For example, controls such as threat intelligence, web filtering, and secure coding.
What’s next?
All organizations that hold a current ISO 27001:2013 certification are required to undergo a transition audit to be certified to the 2022 version. Certification and recertification against ISO 27001:2013 are allowed until April 30, 2024. However, companies should begin to update their ISMS to comply with the requirements in this new revision as soon as possible. Any company currently certified against ISO 27001:2013 must transition no later than October 31, 2025.
To ensure a successful transition, organizations are required to:
- Perform a gap assessment: Map your existing controls to the newly revised standard and determine what changes your ISMS will need to make to achieve certification under the new version of the standard.
- Update the SoA: This document serves as a catalog of controls relevant to the ISMS. At a minimum, the SoA is required to include necessary controls, justification for inclusion, implementation status and justification for exclusion of controls. The SoA may also include risk mapping, control owners, and operating frequencies.
- Update the risk treatment plan: The risk treatment plan should include the risks relevant to implemented controls, risk responses, risk mitigation owners and administrative items such as timelines, budgets, etc.
- Implement and verify effectiveness of information security controls: The implementation and effectiveness of new or changed information security controls selected by your organization will be evaluated to ensure they meet the requirements of ISO/IEC 27001:2022.
For more information about the updated ISO 27001 standard and A-LIGN’s certification services, we invite you to watch our webinar or contact us today. Our team of experienced auditors is here to guide you through the certification process and ensure the security and resilience of your organization’s information assets.
At A-LIGN, we are committed to helping our clients achieve their certification goals and maintain the highest standards of information security. With our expanded certification services and expertise in ISO/IEC 27001:2022, we look forward to assisting organizations in their journey towards a more secure future.
Get started by downloading our ISO 27001 checklist.
When pursuing federal clients or servicing existing ones, there are unique compliance needs due to the sensitivity of government information. Many standards (such as FedRAMP) and laws (like FISMA) exist to create consistent security standards for organizations seeking federal agency clientele.
Sometimes these standards have similar frameworks, putting organizations in a position where they need guidance on which certification to pursue. For instance, FISMA and FedRAMP often appear early in an organization’s compliance journey — but the two aren’t interchangeable.
In this blog, we’ll clarify:
- What is FISMA?
- What is FedRAMP?
- The differences between FISMA vs FedRAMP
- How to choose between FISMA vs FedRAMP
What is FISMA?
FISMA refers to the Federal Information Security Modernization Act of 2014. First issued in 2002, FISMA was amended in 2014 to modernize federal security practices, addressing evolving security concerns as technology progressed.
FISMA is not a standard: it is a United States federal law requiring federal agencies to develop, document, and implement an agency-wide program to provide information security for the information and systems that support the operations and assets of the agency, including those provided or managed by another agency, contractor, or other sources.
The Risk Management Framework (RMF) is a key element of FISMA, as it brings together all the FISMA-related security standards and guidance to promote the development of comprehensive and balanced information security programs by agencies.
Together, FISMA and RMF outline the cybersecurity standard for all companies that are seeking federal contracts and an ATO from government agencies. FISMA establishes the standards and requirements of an agency’s cybersecurity program, and RMF is how that program is implemented to meet those standards and requirements.
What is FedRAMP?
FedRAMP, or Federal Risk and Authorization Management Program, is a government program that provides a standardized approach to security assessment, authorization, and continuous monitoring specifically for cloud products and services used by federal agencies to store, process, and transmit federal information.
Its main objective is to provide federal departments and agencies with a cost-effective and risk-based approach to cloud adoption. The creation of FedRAMP allowed cloud service providers (CSPs) to be assessed and authorized by federal agencies.
Understanding the Differences Between FISMA and FedRAMP
The main differences between FISMA and FedRAMP include:
- The type of ATO that is granted (one-to-one vs. “do once, use many”)
- Who each is relevant for (FedRAMP is specifically for cloud service providers)
- The pathways to authorization
When becoming FISMA compliant, organizations are awarded an RMF ATO from the specific federal agency with which the organization is working, which is considered a one-to-one process. A one-to-one process means that each agency that an organization is seeking authorization from will have different requirements because of the unique needs that an agency may have. As a result, multiple ATOs from multiple agencies must be maintained in order to keep those federal contracts. Thus, each authorization is done one at a time.
When becoming FedRAMP authorized, organizations are awarded an ATO that can be leveraged by any federal agency, which supports a “do once, use many” framework that provides a streamlined process for cloud service providers (CSPs). FedRAMP can be more rigorous because it is intended to be used by any agency.
In addition, FedRAMP is specifically designed with the needs of CSPs in mind, making it the appropriate assessment for cloud providers.
Under FedRAMP, organizations pursue one of two authorization pathways. They either pursue a provisional authorization to operate, or P-ATO, through the Joint Authorization Board (JAB) or a FedRAMP Authorization via a direct Agency sponsorship. Either path requires a 3PAO, or third-party assessment organization, to determine that the provider can demonstrate that the cloud services meet the baseline controls in FedRAMP. Once the 3PAO assesses and reviews the documentation, the results are submitted for FedRAMP review and approval, at which time, an organization is awarded a P-ATO or ATO, depending on the authorization pathway chosen.
Choosing Between FISMA and FedRAMP
When it comes to choosing between FISMA and FedRAMP, the decision ultimately lies with the organization itself.
Many times, client specifications will determine which standard an organization chooses to pursue. If your company’s offering is a cloud-based solution, then FedRAMP is typically required, otherwise the compliance framework is typically determined by your federal client requirements.
Both RMF and FedRAMP fulfill the FISMA mandates and aim to protect sensitive government data from cybersecurity threats, and both follow the controls set within NIST SP 800-53.
Regardless of the assessment that is right for your organization, the NIST guidelines allow organizations to use cloud services with increased security and efficiency.
Becoming FISMA Compliant
Whether it’s pursuing a RMF ATO or a FedRAMP ATO, Federal agencies base their security controls baselines on NIST SP 800-53, in addition to agency-specific cybersecurity requirements.
A-LIGN is an expert in federal compliance and a top FedRAMP assessor. As an accredited 3PAO, A-LIGN can help organizations navigate the process of complying with multiple audits and gaining multiple authorizations at the same time.
Contact the A-LIGN team today to discuss the benefits of FISMA or FedRAMP for your organization.
Are you looking to strengthen your organization’s cybersecurity measures and demonstrate your commitment to protecting sensitive information? Understanding the relationship between SOC 2 and HITRUST can be instrumental in achieving these goals. SOC 2 and HITRUST are two widely recognized frameworks that provide comprehensive guidelines for managing security controls and ensuring the confidentiality, integrity, and availability of sensitive data. While each framework has its own unique focus and requirements, they are not mutually exclusive. In fact, they complement each other in many ways, allowing organizations to simultaneously complete both assessments and reap benefits from both.
In this blog post, we will explore the synergies between SOC 2 and HITRUST and how leveraging both frameworks can enhance your organization’s cybersecurity posture and instill confidence in your stakeholders.
Types of HITRUST Assessments
HITRUST has two methods to approach complying with the HITRUST CSF with each providing their own unique benefits, depending on the needs of an organization. They include the Self-Assessment, and a Validated Assessment, which leads to HITRUST certification. They each function on varying degrees of assurance based on the cost, effort-level, and time required. The benefits of any type of HITRUST CSF Assessment include:
- Scalability for organizations of any size
- Allows for organizations to understand their current level of compliance with the CSF and areas of general risk
HITRUST Self-Assessment
The HITRUST MyCSF is designed to be completed by an organization in order to minimize time and resources when demonstrating compliance with the CSF. The self-assessment can also be used as a stepping stone to a validated assessment. The benefits include:
- Low to medium level of effort needed to complete
- Can be quickly completed
However, one of the disadvantages of completing a self-assessment report is that it provides the lowest level of assurance, as no validation comes from the self-assessment: it simply results in a HITRUST issued CSF Self-Assessment report.
Validated Assessment
A Validated Assessment is a more rigorous assessment process, with an increase in assurance level performed by a CSF assessor firm to validate the information gathered by the organization. One of the benefits of receiving a CSF validated assessment includes providing an increased assurance level to the relying entity.
The process is more rigorous due to on site testing at the entity to be performed by an authorized CSF assessor. A validated assessment requires a medium to high level of effort for completion, due to the on-site time and rigorous testing procedures. Upon completion, HITRUST reviews the complete assessment and issues a Validated Report as the outcome if the organization has failed to receive a rating of 3 or higher on any of the controls.
Certified Assessment
While an organization goes through the same audit-process when receiving either a validated assessment or a certified assessment, becoming HITRUST certified means that the organization received at least a 3 on HITRUST’s scale and has shown a high-level of maturity.
The benefits of receiving a CSF certified assessment include:
- The report is good for 2 years, with an interim assessment completed at the one-year mark.
- Provides the most complete assurance level certified by HITRUST. The organization that receives a certified assessment must meet all of the certification requirements of the CSF.
A certified assessment is only earned once an organization successfully demonstrates that they are able to meet all of the controls in the CSF required for certification at the appropriate level based on organizational needs.
SOC 2 and HITRUST
What is SOC 2?
SOC 2 reports describe the internal controls at a service organization, based on the AICPA’s Trust Principles:
- Common Criteria (Security)
- Availability
- Processing Integrity
- Confidentiality
- Privacy
SOC 2 reports provide users with management assertions, a description of both the system and the controls, tests and the results of the tests, and the independent service auditor’s report. The SOC 2 is widely used by service organizations that provide services to other business entities.
HITRUST and the American Institute of Certified Public Accountants (AICPA) have developed a collaborative approach that aligns the AICPA’s Trust Principles with the HITRUST CSF criteria. This allows licensed CPA firms, who are also CSF assessor firms to issue a SOC 2 plus HITRUST report that includes both the SOC 2 criteria and HITRUST CSF. This makes HITRUST and SOC 2 complementary services through this converged reporting model. The benefits for your organization include:
- Save time
- Save on costs
- Gain efficiency
- Increase your client satisfaction
This streamlining process allows organizations to simplify the process of leveraging their HITRUST CSF for SOC 2 reporting.
Download our HITRUST checklist now!
Cybersecurity tactics and best practices constantly evolve as new threats emerge. And it doesn’t matter how great your security is if third-party vendors aren’t as prepared.
This is why The HITRUST CSF exists — to establish standards dedicated to protecting sensitive information.
HITRUST is a standards organization focused on security, privacy and risk management. HITRUST CSF was developed to provide healthcare organizations with a comprehensive security and privacy program.
Though it’s been historically targeted toward organizations in the healthcare industry, the HITRUST CSF has been gaining traction in other sectors. With malicious attacks on the rise, companies across all industries should consider adopting the HITRUST CSF to minimize risk exposure.
Why the HITRUST CSF is Popular Among Healthcare Organizations
HITRUST was founded in 2007 to make information security a focus of the healthcare industry. This standard gives customers confidence in knowing their data and confidential information are secure.
Many healthcare organizations are required to maintain HIPAA compliance. HIPAA, or the Healthcare Insurance Portability and Accountability Act, is a U.S. law that establishes a set of safeguards that covered entities must follow to protect health information.
However, there is no official way to measure HIPAA compliance. The HITRUST CSF provides a list of prescriptive controls or requirements that can demonstrate compliance, making the CSF a certifiable security and privacy framework. Therefore, it was an essential complement to HIPAA compliance for healthcare organizations.
Why Other Industries Should Adopt the HITRUST CSF
In 2019, HITRUST made the CSF industry agnostic. This made it possible for organizations in any industry to pursue the certification — although many organizations are unaware of the benefits HITRUST Certification can provide their teams.
HITRUST Certification is not mandated by law. Still, the HITRUST CSF is considered the most comprehensive cybersecurity and privacy framework because of the way it maps to over 40 other security and privacy standards, including HIPAA, SOC 2, NIST SP 800-53 and ISO 27001, just to name a few.
The HITRUST CSF allows organizations to combine several assessments and standards into one framework. Organizations decide what regulatory factors they want to include in their assessment based on the level of risk and the regulatory requirements.
By taking an “assess once, report many” approach, assessors can perform several different audits while the organization feels like they’re only undergoing one — saving time, money, and resources.
Key Industries that Could Benefit from HITRUST Adoption
Even though most industries will benefit from adopting the HITRUST CSF, several industries could reap more significant rewards while using this framework.
Hospitality
Hotels, lodging facilities, and travel booking sites are at an increased risk of virtual attacks, such as the Marriott data breach that occurred in mid-2022.
That’s why major players in the industry now require strict adherence to security and privacy best practices. Sabre, for example, is the largest technology platform for booking and payment applications in the hospitality industry. In 2019, Sabre began requiring its vendors to provide a HITRUST CSF Assessment, as the company wanted a way for its vendors to demonstrate the effectiveness of their information privacy and security controls.
Suppose hospitality organizations want to keep using Sabre as their primary booking and payment application. In that case, the organizations must undergo a HITRUST CSF Assessment to ensure they are safely managing customer data.
Utilities
Strong security is essential for utility companies. The nation’s critical infrastructure system could crumble without stable access to necessities like water and electricity.
With critical infrastructure coming under increased attacks, as seen with Russia’s attacks on Ukraine’s electrical grid, many nations worldwide are focusing on protecting vital resources. To help mitigate the risk of an attack, organizations need to take a proactive approach to cybersecurity, such as adopting a framework like the HITRUST CSF.
Organizations with International Customers
While not technically an industry of its own, organizations with a large number of international customers will benefit from the adoption of the HITRUST CSF.
In 2018, the EU adopted the General Data Protection Regulation (GDPR) to protect the private information of those in the European Union. However, similar to the case with HIPAA, there is no official way to measure GDPR compliance.
Adding GDPR to a HITRUST assessment is a great approach for addressing the questions and concerns clients may have about your organization’s GDPR compliance.
The Singapore Personal Data Protection Act shares many similarities with GDPR, although this international regulation only applies to Singapore. Along the same vein, the Brazilian General Data Protection Law (LGPD) has also gained popularity in recent years, once again demonstrating how many privacy laws have been adopted worldwide.
With no formal certification process for many of these new regulations, organizations that are currently doing business or are looking to do business overseas should add additional regulations to their HITRUST assessment to better demonstrate data safety.
Get Started with HITRUST
Organizations across all industries need to ensure they can protect any data that might be shared. One of the best ways to do this is by achieving HITRUST Certification.
The HITRUST CSF Certification draws from multiple well-known, pre-existing frameworks to provide a complete, certifiable security and privacy standard. With the foundation already set, many see that their HITRUST Certification simplifies the process of satisfying other requirements.
With more than 400 successful HITRUST Assessments completed, A-LIGN’s team of HITRUST experts is here to answer any questions and walk you through the entire certification process.
Interested in learning more about HITRUST CSF? Complete the form below and one of our cybersecurity and compliance professionals will reach out within 24 hours.