# Security Compliance Governance Framework

## Overview

This document establishes the organizational framework for security compliance governance, ensuring adherence to regulatory requirements, industry standards, and internal security policies through systematic controls and continuous monitoring.

## Compliance Governance Structure

### Governance Hierarchy

**Board of Directors**
- Ultimate accountability for security compliance
- Risk appetite and tolerance setting
- Resource allocation for compliance programs
- Oversight of compliance performance and incidents

**Executive Leadership**
- Strategic compliance direction and priorities
- Cross-functional compliance coordination
- Regulatory relationship management
- Compliance investment decisions

**Chief Information Security Officer (CISO)**
- Security compliance program leadership
- Regulatory interpretation and implementation
- Compliance risk assessment and management
- Security control effectiveness oversight

**Compliance Committee**
- Multi-disciplinary compliance coordination
- Policy development and review
- Exception review and approval
- Performance monitoring and reporting

### Roles and Responsibilities

**Compliance Officer**
- Regulatory monitoring and interpretation
- Compliance program development and maintenance
- Training and awareness coordination
- Audit and assessment management

**Security Architects**
- Control design and implementation
- Technical compliance solution development
- Security standard interpretation
- Architecture review and approval

**Business Unit Leaders**
- Operational compliance implementation
- Resource allocation for compliance activities
- Business process integration
- Performance accountability

**Internal Audit**
- Independent compliance assessment
- Control effectiveness evaluation
- Compliance program audit
- Remediation tracking and verification

## Regulatory Compliance Frameworks

### SOC 2 Type II Compliance

**Trust Service Criteria**

*Security*
- Logical and physical access controls
- System operations and availability
- Change management procedures
- Risk mitigation and monitoring

*Availability*
- System availability commitments
- Capacity planning and monitoring
- Incident response and recovery
- Performance monitoring and reporting

*Processing Integrity*
- System processing completeness and accuracy
- Data validation and error handling
- Processing authorization and approval
- System monitoring and alerting

*Confidentiality*
- Data classification and handling
- Access control and authorization
- Encryption and data protection
- Confidentiality agreement management

*Privacy*
- Privacy notice and consent management
- Data collection and use limitation
- Data quality and retention
- Data subject access and correction

### ISO 27001 Information Security Management

**Control Categories**

*Information Security Policies*
- Management direction and support
- Information security policy framework
- Policy review and maintenance
- Compliance monitoring and reporting

*Organization of Information Security*
- Management commitment and leadership
- Information security coordination
- Contact with authorities and special interest groups
- Information security in project management

*Human Resource Security*
- Prior to employment screening
- Terms and conditions of employment
- Disciplinary processes and procedures
- Information security awareness and training

*Asset Management*
- Responsibility for assets
- Information classification and handling
- Media handling and disposal
- Equipment maintenance and disposal

*Access Control*
- Business requirements for access control
- User access management
- User responsibilities and system access
- System and application access control

### PCI DSS Payment Card Industry Standards

**Core Requirements**

*Build and Maintain Secure Networks*
- Install and maintain firewall configuration
- Do not use vendor-supplied defaults for passwords
- Protect stored cardholder data
- Encrypt transmission of cardholder data

*Implement Strong Access Control Measures*
- Restrict access by business need-to-know
- Assign unique ID to each person with computer access
- Restrict physical access to cardholder data
- Regularly monitor and test networks

*Maintain Information Security Policy*
- Maintain policy that addresses information security
- Implement incident response procedures
- Regularly test security systems and processes
- Maintain vulnerability management program

## Industry-Specific Compliance

### Healthcare - HIPAA Compliance

**Administrative Safeguards**
- Security Officer designation and responsibilities
- Workforce training and access management
- Information access management procedures
- Security awareness and training programs
- Security incident procedures and response
- Contingency plan development and testing
- Periodic security evaluations and assessments

**Physical Safeguards**
- Facility access controls and procedures
- Workstation use restrictions and controls
- Device and media controls and disposal
- Equipment maintenance and disposal procedures

**Technical Safeguards**
- Access control and unique user identification
- Audit controls and monitoring procedures
- Integrity controls for electronic health information
- Person or entity authentication procedures
- Transmission security and encryption requirements

### Financial Services - SOX Compliance

**Internal Control Requirements**

*Management Assessment*
- Annual internal control assessment
- Control deficiency identification and remediation
- Material weakness evaluation and reporting
- Control effectiveness documentation and testing

*External Auditor Attestation*
- Independent assessment of internal controls
- Management assertion evaluation
- Control testing and validation procedures
- Opinion on control effectiveness

*IT General Controls (ITGCs)*
- Access controls and user management
- Change management and deployment procedures
- Computer operations and job scheduling
- Backup and recovery procedures and testing

## Compliance Program Management

### Program Development and Implementation

**Compliance Assessment**
- Regulatory requirement identification and analysis
- Current state assessment and gap analysis
- Risk assessment and prioritization
- Resource requirement determination

**Program Design**
- Control framework selection and customization
- Policy and procedure development
- Training and awareness program design
- Monitoring and reporting mechanism establishment

**Implementation Planning**
- Phased implementation approach and timeline
- Resource allocation and responsibility assignment
- Change management and communication strategy
- Success criteria and measurement definition

### Control Implementation and Management

**Control Design Principles**
- Risk-based control selection and implementation
- Defense-in-depth security architecture
- Segregation of duties and authorization controls
- Monitoring and detection capability integration

**Control Testing and Validation**
- Regular control effectiveness testing
- Independent validation and verification
- Remediation tracking and completion
- Continuous improvement and optimization

**Documentation and Evidence**
- Control documentation and procedure maintenance
- Evidence collection and retention procedures
- Audit trail maintenance and protection
- Documentation review and update processes

## Risk Management and Assessment

### Compliance Risk Framework

**Risk Identification**
- Regulatory change monitoring and assessment
- Business process risk evaluation
- Technology risk assessment and management
- Third-party and vendor risk evaluation

**Risk Assessment Methodology**
- Likelihood and impact evaluation criteria
- Risk scoring and prioritization framework
- Risk tolerance and appetite alignment
- Risk treatment and mitigation strategies

**Risk Monitoring and Reporting**
- Key risk indicator development and tracking
- Regular risk assessment and review cycles
- Executive and board risk reporting
- Risk trend analysis and forecasting

### Continuous Monitoring

**Monitoring Framework**
- Real-time control monitoring and alerting
- Periodic control testing and validation
- Performance metric tracking and analysis
- Compliance dashboard and reporting

**Key Performance Indicators**
- Control effectiveness metrics and trends
- Compliance incident frequency and severity
- Audit finding resolution time and quality
- Training completion and effectiveness rates

**Management Reporting**
- Monthly compliance status reporting
- Quarterly risk and control assessment
- Annual compliance program review
- Ad-hoc incident and exception reporting

## Audit and Assessment Management

### Internal Audit Program

**Audit Planning and Scheduling**
- Risk-based audit planning and prioritization
- Annual audit plan development and approval
- Resource allocation and scheduling coordination
- Stakeholder communication and coordination

**Audit Execution and Reporting**
- Audit scope definition and methodology
- Evidence collection and evaluation procedures
- Finding documentation and classification
- Audit report preparation and distribution

**Remediation Management**
- Management response and action plan development
- Remediation tracking and progress monitoring
- Validation testing and closure verification
- Lessons learned and process improvement

### External Audit Coordination

**Auditor Selection and Management**
- Qualified auditor selection criteria and process
- Audit scope and timeline negotiation
- Audit coordination and support provision
- Audit result review and management response

**Regulatory Examination Preparation**
- Examination readiness assessment and preparation
- Documentation organization and presentation
- Stakeholder coordination and communication
- Issue resolution and follow-up management

## Training and Awareness

### Compliance Training Program

**Role-Based Training Requirements**
- General compliance awareness for all employees
- Specialized training for compliance-sensitive roles
- Management training on oversight responsibilities
- Technical training for control implementation

**Training Content and Delivery**
- Regulatory requirement education and interpretation
- Policy and procedure training and updates
- Best practice sharing and case study analysis
- Incident response and escalation procedures

**Training Effectiveness Measurement**
- Training completion tracking and reporting
- Knowledge assessment and competency validation
- Behavioral change measurement and evaluation
- Continuous improvement and content updates

### Awareness and Communication

**Communication Strategy**
- Regular compliance updates and newsletters
- Policy change notifications and explanations
- Success story sharing and recognition
- Incident lessons learned and prevention

**Culture Development**
- Compliance culture assessment and improvement
- Leadership modeling and demonstration
- Employee engagement and participation
- Recognition and incentive programs

## Continuous Improvement

### Program Maturity Assessment

**Maturity Model Framework**
- Initial: Ad-hoc and reactive compliance
- Managed: Documented and repeatable processes
- Defined: Standardized and integrated procedures
- Quantitatively Managed: Measured and controlled
- Optimizing: Continuous improvement and innovation

**Capability Assessment**
- Current maturity level evaluation
- Target maturity level definition
- Gap analysis and improvement planning
- Progress monitoring and measurement

### Innovation and Enhancement

**Technology Integration**
- Compliance automation and tool evaluation
- Artificial intelligence and machine learning application
- Cloud-based compliance solution adoption
- Integration with business systems and processes

**Best Practice Adoption**
- Industry benchmark analysis and comparison
- Regulatory guidance interpretation and implementation
- Peer organization collaboration and learning
- Professional development and certification
