GRC Questions !!Help

[SandeepKSingh]

My company is in the middle of a quarterly audit to ensure that it is compliant with industry regulations (e.g., GDPR, HIPAA). During the audit, an issue arises where one of the critical systems was not updated with the latest security patches. The system's failure to meet the necessary security standards might pose a risk to the company's data security, resulting in a potential compliance violation.

The objective is to identify, assess, and mitigate the risk posed by this system vulnerability while ensuring compliance with the relevant regulations. The company needs to track this risk, update controls, and work toward achieving compliance before the next audit.

[Ravi Gaurav · Accepted solution]

Hi @SandeepKSingh 

To address this issue effectively and ensure compliance before the next audit, follow these steps to identify, assess, mitigate, and monitor the risk:

Note the below answer is from servicenow E-book .

1. Identify the Risk

Objective: Understand the scope and nature of the vulnerability.
Actions:

1. Perform a Risk Analysis:

   • Identify the unpatched system and the critical vulnerabilities it poses.
   • Categorize the data and services this system handles (e.g., sensitive customer data, PHI under HIPAA, personal data under GDPR).

2. Engage Key Stakeholders:

   • Notify the IT, Security, and Compliance teams about the issue.
   • Determine the responsible system owner and relevant third-party vendors, if applicable.

3. Document the Risk:

   • Create a risk record in your organization's GRC (Governance, Risk, and Compliance) tool (e.g., ServiceNow GRC) with details like:
     • System name and owner.
     • Description of the unpatched vulnerability.
     • Potential impact on confidentiality, integrity, and availability (CIA).

---

2. Assess the Risk

Objective: Evaluate the severity of the risk and its compliance implications.
Actions:

1. Impact Assessment:

   • Assess the data type handled by the system:
     • GDPR: Does the system process personal data of EU residents?
     • HIPAA: Is it involved in storing or transmitting PHI?
   • Determine the potential consequences of a data breach (e.g., fines, lawsuits, reputation loss).

2. Likelihood Assessment:

   • Analyze how exposed the system is (e.g., is it publicly accessible?).
   • Check if exploitation of the vulnerability has been reported in the wild.

3. Risk Rating:

   • Use a risk matrix (Likelihood vs. Impact) to assign a severity level (Low, Medium, High, Critical).
   • Ensure that this is communicated to the Audit and Compliance teams.

---

3. Mitigate the Risk

Objective: Address the root cause to minimize risk exposure.
Actions:

1. Apply Patches:

   • Prioritize patching based on the risk severity.
   • Test patches in a staging environment before deployment to production.

2. Implement Compensating Controls:

   • If immediate patching is not feasible, use interim measures like:
     • Network segmentation to isolate the vulnerable system.
     • Enhanced monitoring for unusual activity (e.g., IDS/IPS alerts).
     • Disabling unnecessary services or ports.

3. Enhance Security Policies:

   • Revise patch management policies to prevent recurrence.
   • Implement automated tools for vulnerability scanning and patch compliance (e.g., Qualys, Nessus).

4. Update the Compliance Framework:

   • Adjust existing controls in your GRC system to include monitoring of patching processes.

---

4. Monitor and Validate

Objective: Ensure risk remediation is successful and compliance is achieved.
Actions:

1. Track Progress:

   • Use a risk register or GRC module to track mitigation actions.
   • Assign tasks and deadlines to responsible teams.

2. Conduct Validation Testing:

   • Perform a security scan to confirm the patch is applied successfully.
   • Review logs for any unusual activity post-remediation.

3. Prepare for the Next Audit:

   • Update your compliance documentation to include evidence of:
     • Risk assessment and mitigation.
     • Updated controls and patch policies.
   • Conduct an internal review to identify any remaining gaps.

---

5. Report and Communicate

Objective: Ensure all stakeholders are informed and reassured of compliance.
Actions:

1. Executive Summary:

   • Prepare a report summarizing:
     • The nature of the vulnerability.
     • Actions taken to mitigate the risk.
     • Current compliance status.

2. Communicate with Auditors:

   • Share evidence of remediation efforts and updated controls.
   • Proactively address any additional queries.

---

6. Strengthen Long-term Compliance

• Automate Patch Management: Use tools like SCCM, WSUS, or cloud-native patching solutions.
• Implement Regular Risk Assessments: Schedule quarterly vulnerability scans and compliance reviews.
• Train Staff: Ensure system administrators are aware of the latest patching best practices and compliance requirements.