Understanding Policy and Compliance Management in ServiceNow GRC: Concepts, Lifecycle, and Real-Time
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Governance, Risk, and Compliance (GRC) is more than just audits or checklists — it’s about ensuring your organization follows rules, manages risks, and meets regulatory obligations in a structured way.
Within ServiceNow GRC, Policy and Compliance Management bridges the gap between organizational expectations (policies) and evidence of adherence (controls and compliance).
This post explains the core concepts, lifecycle, and real-world examples to help you understand how it works in practice.
1. Policies: Defining Organizational Rules
A policy is a high-level statement that defines what must be done within the organization. Policies provide guidance, set expectations, and create accountability.
Examples of policies in real organizations:
Information Security Policy
Access Control Policy
Data Retention Policy
Vendor Risk Policy
Real-Time Scenario:
In a finance company, an Access Control Policy ensures all system access requests go through manager approval and quarterly review. Without a formal policy, auditors would have no single source of truth during compliance checks.
2. Policy Statements: Making Policies Actionable
A policy statement is a specific requirement within a policy. It is measurable, enforceable, and testable.
Example Policy Statement:
“All users must enable multi-factor authentication (MFA) for remote access.”
Real-Time Scenario:
A company rolling out MFA across multiple applications uses policy statements to track which systems comply and which need remediation. This makes reporting to management and auditors simple and consistent.
3. Policy Lifecycle: From Draft to Retired
Policies in ServiceNow have a structured lifecycle, ensuring accountability and continuous governance.
| Draft | Policy is created | Security team drafts Data Retention Policy |
| Review | Stakeholders provide input | IT, Legal, and Compliance teams review and provide comments |
| Approval | Policy is formally approved | CISO approves the Information Security Policy |
| Published | Policy is active and visible | Employees are notified to acknowledge (attestation) |
| Retired | Policy is no longer applicable | Old vendor risk policy is retired after process update |
Lifecycle workflows in ServiceNow help track progress, approvals, and versioning, ensuring policies are always current and auditable.
4. Compliance: Aligning Policies to Standards
Compliance ensures that your organization meets laws, regulations, industry standards, and internal policies.
Examples:
ISO 27001
GDPR
SOX
Real-Time Scenario:
A healthcare company maps its Data Protection Policy to GDPR requirements. Each policy statement links to specific GDPR articles, making it easy to see which parts of the organization are compliant and where gaps exist.
Authority Documents in ServiceNow act as the source of compliance requirements, which are then linked to policies, controls, and audits.
5. Controls: Enforcing Policies
A control is an activity or process that ensures a policy is followed and compliance requirements are met.
Types of Controls:
Manual – Human-performed actions (e.g., quarterly access review)
Automated – System-enforced actions (e.g., password complexity rules)
Hybrid – Combination of manual and automated
Control Objectives explain why a control exists.
Real-Time Scenario:
An organization maps its Access Control Policy to controls such as:
User Access Approval (manual)
Periodic Access Review (manual)
Automated De-provisioning (automated)
Mapping controls to policies and regulations provides traceability, making audits more straightforward.
Entity Scoping: The “Where” and “Who” of Controls
Entity Scoping defines where and to whom a control applies. ServiceNow uses Entity Types, Entities, and Entity Filters to scope controls accurately.
Entity Type: The category of objects a control applies to.
Examples: User, Group, Department, Business Application, Location
Entity: The specific object the control applies to.
Examples: HR Payroll System (Business Application), Finance Department (Department), John Doe (User)
Entity Filter: Criteria to dynamically select entities based on attributes or status.
Examples: All active users, employees in Finance, critical business applications
Real-Time Scenario:
For ISO 27001 Access Control compliance:
| Policy | Access Control Policy |
| Control Objective | Ensure only authorized users have access to sensitive systems |
| Entity Type | Business Application |
| Entity | HR Payroll System |
| Entity Filter | All active users in HR department |
| Control | Quarterly access review + automated de-provisioning |
Proper Entity Scoping ensures controls are applied accurately, dynamically, and audit-ready.
6. Policy Exceptions: Handling Real-World Constraints
Sometimes a policy cannot be fully implemented due to operational or technical constraints. This is handled via policy exceptions.
Real-Time Scenario:
A legacy application cannot support MFA. A policy exception is logged in ServiceNow, with:
Justification for the exception
Compensating controls (e.g., enhanced monitoring)
Expiration date for review
Exceptions make risks visible and ensure they are not ignored.
7. Policy Attestation: Confirming Awareness
Attestation is the process of ensuring employees acknowledge and understand published policies.
Real-Time Scenario:
After publishing the Information Security Policy, all employees receive attestation tasks in ServiceNow. The compliance team can see who has acknowledged and follow up on non-responses. This streamlines audit readiness.
8. Issue and Remediation Management
When a control fails or a compliance gap is identified, ServiceNow can:
Automatically create issues
Assign remediation tasks
Track progress and verify closure
Real-Time Scenario:
During a quarterly access review, a control failure is detected (a user still has access after leaving). ServiceNow automatically generates an issue, assigns it to IT, and tracks closure.
9. End-to-End Example: Access Control Compliance
Scenario: ISO 27001 Access Control Compliance
Authority Document: ISO 27001 uploaded, access control requirements defined
Policy Creation: Access Control Policy created; policy statements defined and published
Control Definition: Manual and automated controls created with Control Objectives
Entity Scoping: Entity Types, Entities, and Entity Filters defined to target the correct users and systems
Mapping: Controls linked to policy statements and ISO requirements
Testing: Quarterly access review performed, evidence collected
Reporting: Compliance dashboard shows % of compliant controls, failed tests, and open issues
This workflow connects policies, statements, controls, objectives, entities, and compliance, making it traceable, auditable, and actionable.
Conclusion
ServiceNow GRC’s Policy and Compliance Management is more than a checklist — it is a framework that turns policies into enforceable, measurable actions and links them directly to compliance requirements.
By understanding the lifecycle of a policy, mapping policy statements to controls, handling exceptions, and using attestation and issue management, organizations can:
Improve visibility into compliance across teams
Reduce audit preparation time
Ensure accountability and continuous governance
In short, integrating policies, compliance, and controls in a workflow-driven platform helps organizations move from reactive compliance to proactive, audit-ready governance.
