Compliance is not a proxy for due care

Regulatory compliance is a necessary step for IT leaders, but it’s not sufficient enough to reduce residual IT security risk to tolerable levels. This is not news. But why is this the case? Here are three reasons:

  • Compliance regulations are focused on “good enough,” but the threat environment mutates rapidly. Therefore, any definition of “good enough” is temporary. The lack of specificity in most regulations is deliberate to accommodate these factors.
  • IT technologies change rapidly. An adequate technology solution today will be obsolete within a few years.
  • Circumstances and IT networks are so varied, that no single regulation can address them all. Prescribing a common set of solutions for all cases is not possible.

The key point to understand is that the compliance guidance documents are just that — guidance. Getting certification for the standard, while necessary, is not sufficient. If your network becomes the victim of a security breach and a third party suffers harm, then compliance to the guidelines alone will not be an adequate defense, although it may help mitigate certain regulatory penalties. All reasonable steps to mitigate the potential for harm to others must have been implemented, regardless of whether those steps are listed within the guidance.

A strong security program is based on effective management of the organization’s security risks. A process to do this effectively is what regulators and auditors look for.