Why Compliance Maintenance Is Cybersecurity’s Achilles’ Heel

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Case in point

Just six months after achieving ISO 27001 certification, a mid-sized financial services firm faced a harsh reality. Their surveillance audit uncovered 12 major non-conformities, putting both their hard-earned certification and client trust in serious jeopardy. The culprit? Gaps in compliance maintenance and a false sense of security post-certification. The firm saw compliance as a one-time milestone, not an ongoing journey.

This scenario plays across industries. While organizations invest heavily in achieving initial certification, they plan to do nothing until the next audit or an external party uncovers issues in compliance maintenance.

The Overlooked Phase of Compliance: Maintenance

Organizations undergoing the complex journey of complying with cybersecurity standards have to follow a comprehensive approach, encompassing several key elements. These elements include scoping, gap assessment, policy development, implementation of security controls, and compliance maintenance. While the first four elements are achievable by hiring a certified security professional who would guide them through the planning and execution phases, the actual challenge arises when it comes to ongoing monitoring and maintenance. Often, organizations overlook this phase once they achieve the certification and eventually find themselves in the soup during follow-up surveillance audits or assessments.

While some organizations fail to adhere due to the lack of awareness about the importance of the phase, others fall short because they fail to

  • Allocate sufficient resources
  • Establish clear ownership
  • Integrate compliance into their day-to-day operations
  • Priortize and maintain industry-specific compliance requirements

Furthermore, a recent survey by PwC reported that 85% of organizations admitted that compliance requirements have grown increasingly complex over the last three years. Understanding these requirements adds to the challenges of compliance maintenance.

Eventually, this leads to lapses, non-conformities, or even loss of cybersecurity certification during follow-up audits or surveillance assessments.

Which Organizations Struggle and Why?

Organizations handling large volumes of sensitive customer data, particularly in healthcare and financial services, face significant challenges in maintaining compliance. Regulated industries where compliance is closely linked to business operations and customer trust also struggle with the ongoing demands of cybersecurity compliance maintenance.

This challenge becomes even more evident when looking at industry-specific standards that require ongoing validation of compliance.

For instance, an organization obtaining ISO 27001 certification has to undergo surveillance audits annually during the three-year certification cycle to ensure that its Information Security Management System (ISMS) remains effective and compliant with the standard. This also ensures that the organization is equipped enough to address new risks and vulnerabilities. However, if the organization does not maintain the requirements of the standard or compliance, it can result in non-conformities being identified during the surveillance audit, putting its certification status and overall security posture at risk.

Similarly, PCI DSS Requirement 11.3.2 mandates quarterly ASV scans across the card data environment. However, if an organization neglects to perform these reviews, it can create significant gaps in compliance, leading to failed assessments or even exposure to data breaches due to missed vulnerabilities.

In the case of SOC 2 Type 2, the audit period can vary from 3-12 months, depending on the size and operational business of organizations. Therefore, organizations complying with SOC 2 Type 2 have to undergo the audit process as per the discussed timeline to assess their overall security posture. This is possible if organizations adhere to compliance maintenance through continuous evidence collection, regular control testing, and documentation updates.

In essence, compliance maintenance is not just about staying audit-ready. It’s about embedding cybersecurity into everyday operations to ensure long-term resilience, trust, and regulatory alignment.

What is Cybersecurity Compliance Maintenance?

Compliance maintenance in the context of cybersecurity is the ongoing process of monitoring, managing, and updating security controls, policies, and procedures to ensure continuous adherence to regulatory standards and frameworks after initial certification or compliance is achieved.

Key Aspects of Compliance Maintenance

Compliance maintenance requires a structured and ongoing effort to ensure that all key aspects remain effective and aligned with certification standards. They include:

  • Continuous monitoring: This involves regular review of systems, networks, and control activities to detect vulnerabilities, misconfigurations, or non-compliance.
  • Policy and documentation updates: As part of this activity, IT people are required to keep all compliance-related documentation, including policies, procedures, and risk assessments, updated and aligned with both organizational changes and regulatory updates.
  • Periodic internal audits: This includes conducting scheduled self-assessments or internal audits to identify gaps before external audits.
  • Security awareness training: Security awareness training is periodically provided to employees to ensure that they understand and adhere to security policies and compliance obligations.
  • Incident management: Organizations are required to implement and maintain an incident response plan to handle potential breaches and to report as per regulatory requirements.
  • Evidence collection and log maintenance: This involves maintaining logs, reports, and documentation as proof of control operation, especially for frameworks like SOC 2, ISO 27001, or PCI DSS.
  • Third-party risk management: Vendors and partners who process or access sensitive data are regularly assessed to ensure that they are aligned with the compliance or regulatory standards of the organization.
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What are the benefits of Compliance Maintenance in Cybersecurity?

Maintaining cybersecurity compliance offers numerous benefits. While ongoing compliance efforts help organizations stay prepared for upcoming surveillance audits or assessments, they also prevent last-minute chaos of gathering resources, checking implemented security controls and meeting other compliance requirements.

Additionally, organizations increase their chances of completing the recertification or re-assessment process smoothly by keeping necessary resources, infrastructure, policies and procedures up to date and available. This helps them avoid missing recertification deadlines and facing potential penalties.

Maintaining compliance also improves operational resilience, mitigates reputational damage, and enhances risk management.

Beyond these benefits, the practice of continuous compliance also strengthens the overall security posture of an organization.

Compliance Maintenance Activities for PCI DSS, ISO 27001, SOC 2 Type 2 Certifications

PCI DSS v4.0.1

 RequirementsDescription
Quarterly ReviewPassword rotationEnsure passwords are changed at regular intervals  
 Review of audit log retentionAudit logs are retained, secured, and accessible as per PCI DSS  
 Internal vulnerability scansIdentify and remediate security weaknesses within the systems and networks
 ASV scansIdentify and remediate external security risks using an ASV
Biannually Review  Firewall rule set reviewReview and validate the firewall and router rule sets to avoid unnecessary traffic
 Configuration of network security controlsReview and manage network security controls to restrict unauthorized access to CDE  
 Review of user access privilegesReview and ensure appropriate user access rights across applications, internal users, and third-party vendors

ISO 27001:2022

RequirementsDescription
Annually ReviewInternal ISMS AuditValidate and ensure whether ISMS is effectively implemented   
 Management ReviewTop seniors review ISMS’s overall performance and ensure that it meets the organization’s objectives                           
 Risk assessmentReview current risks and ensure implemented controls are adequate and effective  
 Documentation review & updatingEnsure that policies, procedures, and records are updated 
 Surveillance auditsExternal review by the certifying body to ensure continued compliance    

SOC 2 Type 2

RequirementsDescription
Quarterly/ Biannually/ Annually ReviewControl monitoring & testingEnsure controls are operating effectively as documented  
 User access reviewReview user accounts & their access to limit the access rights to systems and data                              
 Vulnerability Identification & remediationPerform scans of systems to identify and remediate vulnerabilities   
 Network Penetration TestingConduct internal and external network penetration testing to validate security controls   
 Incident ManagementTest the effectiveness of organization’s IR plan through exercises and simulations  
 Review of policy & proceduresReview ensures the relevancy and effectiveness of policies & procedures                            
 Risk Assessment & ManagementIdentify and evaluate new threats and vulnerabilities, including those associated with third-party providers
 Customer ManagementIdentification of policies, procedures, and evidence on how customer data is handled, stored, and accessed

Take Control of Your Compliance Maintenance with Ampcus Cyber

The glaring challenges arising from compliance maintenance in cybersecurity can leave organizations in a vulnerable state of non-conformity, risking their reputation, exposing them to regulatory penalties, and even leading to the potential loss of hard-earned certifications.

Ampcus Cyber, a trusted and leading cybersecurity compliance service provider, helps organizations overcome these challenges through dedicated support for compliance maintenance. As an agnostic compliance provider, Ampcus Cyber adapts to an organization’s unique needs, size, and operational environment to provide both pre- and post-certification support, enabling a sustainable security posture. With a wide range of certified professionals and consultants who bring over 50 years of deep expertise and knowledge in various GRC frameworks, such as PCI DSS, ISO 27001, SOC, and NIST, Ampcus Cyber ensures the organization remains aligned with evolving standards, regulatory requirements, and industry best practices.

As part of the compliance execution and maintenance processes, Ampcus Cyber follows the unique T-SAMA (Train, Scope, Assess, Mitigate, and Audit) approach to align people, processes, and procedures with regulatory requirements and organizational security goals. This not only streamlines resource allocation but also ensures clear ownership of compliance responsibilities across the organization. The in-house experienced security professionals offer expert guidance tailored to business goals and operations, helping organizations navigate complex privacy and industry-specific compliance requirements. By maintaining a strong focus on sector-specific standards and helping embed compliance into day-to-day operations, Ampcus Cyber ensures that organizations sustain long-term security posture and regulatory readiness.

What does Ampcus Cyber Offer?

As part of compliance maintenance, Ampcus Cyber’s expert team connects with the organization periodically and ensures that controls and changes in the infrastructure environment post-certification are maintained. Additionally, other comprehensive support services include:

  • Real-time compliance dashboard and reporting
  • 24/7 support for compliance-related questions
  • Control monitoring
  • Risk assessment & treatment planning
  • Vulnerability & network penetrating testing
  • Access management & review
  • Policy management & review
  • Security awareness & role-based training
  • Incident response readiness review
  • Firewall & network configuration reviews
  • Internal audits & external reviews
  • Surveillance & recertification audit support
  • Revise outdated security implementations

With a success rate of 95%, Ampcus Cyber’s post-certification compliance maintenance approach ensures that organizations not only achieve compliance but also sustain it in the face of evolving regulatory demands.

Ready to simplify your compliance journey? Partner with Ampcus Cyber today to maintain, manage, and maximize your cybersecurity compliance.

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