Documentation is a key part of security compliance — here’s how to do it right
Documentation Security Compliance – Maintaining security compliance is a multifaceted responsibility. It’s not enough to simply implement the required controls and enforce security policies. In order to remain fully compliant, businesses must thoroughly document their compliance efforts as well. Maintaining formal, written documentation of all compliance-related activities is a requirement of many regulatory guidelines, but all too often, it’s treated as an afterthought.
In many cases, compliance documentation is inadequate due to varying responsibilities. In many organizations, compliance efforts spread across departments and different individuals are responsible for various aspects of the security plan. As a result, documentation tends to be inconsistent at best, with varying standards and levels of detail. Unfortunately, such an approach to compliance can land your company in hot water should it ever be selected for a compliance audit.
Specific security compliance documentation standards vary by regulation (HIPAA has different requirements than PCI DSS, for instance) but there are some general best practices that you can follow to ensure that your compliance documentation is up-to-date and meets the requirements put forth for your organization.
Select the Right Manager
Even with a dedicated compliance department, many companies struggle with documentation. Regulatory requirements tend to be highly technical, and require writers with the technical expertise to develop them thoroughly and accurately. When the wrong individuals are tasked with creating compliance documentation, there is the potential for errors and omissions. If professional technical communicators are unavailable, establish specific standards for the creation of documentation for staff to follow, or consider outsourcing the project.
Understand the Requirements
The first step to managing compliance documentation is understanding what is required of your company and developing a consistent means of recording the necessary information. In general, this means:
- Describing the specific requirement and how it relates to your business
- Outlining the specific controls in place to meet that requirement
- Listing the name and contact information for the person in charge of implementing the control
- Designating the date that the control/documentation needs to be reviewed and/or updated
Many organizations implement a content management system specifically for the purpose of maintaining security compliance documentation. Doing so allows for information to be accessed and updated online in real time, without relying on paper copies. An efficient CMS allows for additional information to be imported as well; for instance, when you invest in a Cisco video conference system from KBZ, the information from training sessions completed by employees can be seamlessly added to the CMS, keeping records up-to-date.
Conduct Regular Audits
Compliance documentation is an ongoing process, and IT needs to schedule annual documentation reviews as part of their compliance activities. Ideally, reviews should not be conducted by those who have responsibility for specific security controls, but by other individuals who have knowledge of the controls and can identify gaps or other potential issues that need to be addressed when necessary. The annual documentation review should be focused on identifying required changes, as well as comparing the existing documentation to current regulations to ensure full compliance.
The best time to conduct documentation audits is in conjunction with your scheduled risk assessments. Most security regulations require regular risk assessments, with controls put in place in relation to the results of the assessment. Including a documentation review as a part of that process allows you to identify areas that need improvement or change, as well as activities that need to be added to your security controls.
Focus on the User
Finally, the most effective compliance documentation is user-focused, both in terms of employees who may need to access the information and regulators who will be auditing your efforts. While a focus on the technical aspects of the documentation is necessary, you also want to ensure that the documentation is usable. This means keeping it user-focused, easily accessible, and accurate. Nothing is more frustrating than attempting to find documentation that is hopelessly out-of-date or incorrect, so being user-friendly means committing to maintaining the most current documentation possible.
Failing to correctly maintain your security compliance documentation puts your company at risk for failing an audit, which could result in costly fines and other sanctions. A scattershot and disorganized approach to documenting your efforts is not adequate for anyone’s needs, and could leave your company vulnerable to security breaches in addition to regulatory infractions. By taking the time to develop a comprehensive and thorough approach to compliance documentation, you’ll save time and money in the long run.