Best Practices
Industry best practices for compliance program management.
Best Practices
This guide covers industry best practices for managing your compliance program effectively. Apply these principles to build a mature, sustainable compliance practice.
Program Management
Establish Governance
Define Clear Ownership:
- Assign a compliance owner/officer
- Establish executive sponsorship
- Create compliance committee if needed
- Define roles and responsibilities
Set Clear Objectives:
- Document program goals
- Align with business objectives
- Set measurable targets
- Review and adjust regularly
Maintain Regular Cadence
| Activity | Frequency | Purpose |
|---|---|---|
| Gap review | Weekly | Track remediation progress |
| Risk review | Monthly | Assess risk posture |
| Metric reporting | Monthly | Track program health |
| Policy review | Quarterly | Keep policies current |
| Full assessment | Annually | Comprehensive evaluation |
Consistency is more important than perfection. A regular cadence keeps compliance from becoming a last-minute scramble.
Documentation
Policy Best Practices
Structure:
- Clear, descriptive titles
- Defined scope and applicability
- Version control with dates
- Approval signatures
- Review schedule
Content:
- Written in plain language
- Specific and actionable
- Aligned to control requirements
- Realistic and enforceable
Maintenance:
- Annual review at minimum
- Update when processes change
- Track version history
- Archive old versions
Evidence Collection
What to Collect:
- Screenshots with timestamps
- System-generated reports
- Signed acknowledgments
- Configuration exports
- Log samples
How to Organize:
- By control or framework
- With clear naming conventions
- Including collection dates
- With context/descriptions
When to Collect:
- Continuously throughout the year
- Before audit period starts
- When controls change
- After remediation
Gap Management
Prioritization Framework
Use a consistent approach:
Assess Severity
Rate the compliance and business impact.
Consider Effort
Estimate remediation difficulty.
Evaluate Dependencies
Identify related gaps and blockers.
Set Priority
Rank based on impact vs. effort.
Quick Wins
Target gaps that are:
- High impact, low effort
- Blocking other gaps
- Required for audit
- Visible to stakeholders
Long-term Remediation
For complex gaps:
- Break into phases
- Set intermediate milestones
- Track progress regularly
- Communicate timeline to stakeholders
Risk Management
Risk Assessment
Annual Assessment:
- Review all risk categories
- Reassess likelihood and impact
- Update risk ratings
- Document methodology
Ongoing Monitoring:
- Track emerging risks
- Monitor risk indicators
- Update as situations change
- Report significant changes
Risk Treatment
| Strategy | When to Use |
|---|---|
| Mitigate | Can reduce risk cost-effectively |
| Transfer | Risk better managed by third party |
| Accept | Risk within tolerance, documented |
| Avoid | Change approach to eliminate risk |
Risk acceptance requires documented approval. Don't accept risks by default through inaction.
Vendor Management
Due Diligence
Before Engagement:
- Security questionnaire
- SOC 2 or equivalent report
- Data processing terms
- Service level agreements
Ongoing Monitoring:
- Annual reassessment
- Performance review
- Incident notification tracking
- Contract compliance
Third-Party Risk
| Risk Level | Monitoring Frequency |
|---|---|
| Critical/High | Quarterly review |
| Medium | Semi-annual review |
| Low | Annual review |
Training and Awareness
Security Awareness
Topics to Cover:
- Phishing and social engineering
- Password security
- Data handling
- Incident reporting
- Policy compliance
Delivery Methods:
- New hire onboarding
- Annual refresher training
- Simulated phishing tests
- Targeted role-based training
Compliance Training
- Role-specific requirements
- Framework-specific training
- Regulatory updates
- Tools and processes training
Audit Preparation
90 Days Before
- Review scope with auditor
- Identify key contacts
- Assess current readiness
- Create remediation plan for gaps
60 Days Before
- Execute remediation plans
- Gather evidence
- Conduct self-assessment
- Address findings
30 Days Before
- Final evidence collection
- Prepare control narratives
- Brief interview subjects
- Resolve remaining issues
During Audit
- Single point of contact
- Timely evidence provision
- Track requests and responses
- Daily status updates
Continuous Improvement
Learn from Findings
After audits or assessments:
- Conduct root cause analysis
- Identify systemic issues
- Update processes
- Prevent recurrence
Metrics and KPIs
Track meaningful metrics:
| Metric | Purpose |
|---|---|
| Gap close rate | Remediation velocity |
| Time to remediate | Response efficiency |
| Risk exposure trend | Risk trajectory |
| Training completion | Awareness coverage |
| Evidence freshness | Documentation currency |
Maturity Progression
Build toward higher maturity:
| Level | Characteristics |
|---|---|
| Initial | Ad hoc, reactive |
| Developing | Documented, some consistency |
| Defined | Standardized, organization-wide |
| Managed | Measured, controlled |
| Optimizing | Continuous improvement |
Common Pitfalls
Avoid These Mistakes
| Pitfall | Better Approach |
|---|---|
| Last-minute audit prep | Continuous readiness |
| Check-the-box mentality | True control implementation |
| Documentation without implementation | Evidence of operation |
| Ignoring low-severity gaps | Address before they escalate |
| Siloed compliance efforts | Integrated with business |
Building Culture
Leadership Engagement
- Executive visibility on compliance
- Resources for compliance program
- Recognition for compliance efforts
- Leading by example
Employee Engagement
- Make compliance accessible
- Explain the "why"
- Provide easy reporting mechanisms
- Celebrate successes
Next Steps
- Video Tutorials - See best practices in action
- Quick Start - Apply to your program
- Dashboard - Track your progress