The compliance landscape is constantly changing and organizations are often challenged to meet the requirements of multiple regulations and frameworks. Keeping up with ever-changing, often overlapping, requirements are a significant burden for most organizations, leading to audit fatigue and frustration for everyone involved.

At any given time, an organization is tracking a dozen or two compliance requirements or trying to fulfill these different common controls and compliance codes. Consequently, there are governance and compliance efforts to manage each independently, requiring significant time and effort for compliance and risk management teams. It becomes exhausting for the team and inefficient for the organization to perform manual checks on similar frameworks. 

For example, from a compliance perspective, PCI DSS 12.1 focuses extensively on security policy on how it would be established, published, maintained, and at last disseminated.  Whereas ISO 27001 5.2 also speaks on the importance and mandate for the top management to have a top-down information security policy and have it strictly implemented. 

There are multiple other frameworks like NIST CSF ID.GV- 1 and AICPA SOC2CC5.3 which speak the same thing overall regarding security policy and its implementation. If a compliance auditor or officer can have a common compliance platform instead of going through each one subsequently, it will save them countless hours of effort and time.

That’s why a common control framework (CCF) is considered a viable option. Rather than investing countless hours on compliance checks, it can save valuable time and enhance productivity multifold by testing this control once and using it wherever it is mapped, rather than spending time trying to run the same tests for each framework. In this article, we will dive deep to understand the underlying paradigm of the common control framework and the benefits it entails.

What is a common control framework?

An internal control framework is a structured guide that organizes and classifies expected controls or control issues. Some organizations design control frameworks for general purposes, such as the COSO internal control framework, while others are more specific, such as the IT control framework of COBIT. 

An organization comprises multiple frameworks for distinct sets of controls. This helps the organization develop controls that create and preserve value while minimizing risk. However, the drawback of having common compliance frameworks is that it increases operational inefficiency and redundancy.

A Common Control Framework (CCF) is a complete set of control requirements, aggregated, correlated, and streamlined from across the broad spectrum of information security in the industry and privacy standards. By using a CCF, an organization can meet the requirements of security, privacy, and other compliance programs while minimizing the risk of too much control. 

Why do organizations need a common control framework for internal controls?

Reduce business disruption – Implementing a common control framework that focuses on the organization’s risk and compliance management is an effective way to reduce business disruption across the organization. 

Adopt a compliance-first approach – By focusing on security first and mapping the security-centric controls to compliance frameworks, you can be compliant with various security certifications, standards, and regulations. Most frameworks share the same underlying security principles, with slight differences in how you provide evidence and how your auditors assess your environment.

Streamline compliance and risk management – A common control framework helps you and your auditors with existing compliance assessments. The core framework is able to identify any gaps in other frameworks that can  be rectified proactively. You can perform an analysis of your current control record against existing standards and avoid auditor fees for readiness assessments. 

Benefits of using a common control framework for internal controls 

An organization can benefit from CCF in multiple ways.

The CCF is updated regularly to ensure the organization is aware of any changes to the compliance frameworks in use.

Using an established reference set of control requirements and associated controls allows the organization to get a head start in optimizing the control environment.

From SOX 404-ITGC to PCI-DSS, a common control framework can simultaneously manage multiple frameworks effectively while increasing operational efficiency. By leveraging a CCF, additional compliance frameworks can be quickly assessed and a faster assessment performed. 

Compliance fatigue should be reduced for organization owners and audit control partners. We’ve noticed nearly a 20-30% reduction in the time otherwise spent in finding the right controls for organization and industry-specific regulations and a reduction in assessment time.  

It provides a holistic view of the organization’s control environment as the CCF progresses through the audit and compliance pipelines of SOX and PCI audit obligations.

The organization will be able to assess its control environment and identify its maturity model in relation to other organizations.

The organization can begin evaluating controls to identify departments or tasks that can be automated. It can help the organization develop a consistent approach to performing and documenting controls across the organization and in potential acquisitions.

When acquisitions need to be integrated into the organization’s environment, a CCF facilitates onboarding and allows those acquisitions to become compliant faster.

What are the steps for auditing compliance codes and internal controls?

For auditing compliance codes and internal controls, there are mainly six steps to follow:

Step 1: Validate the framework

Checking with a control framework begins with validating the framework that the management has chosen to support business goals. The framework must be selected and implemented by management, not by internal audit.

If no framework is in place, the audit may still choose to check against a common internal control framework such as the COSO internal control framework or the COBIT IT control framework. The output of this practice would be recommendations for evaluating internal control environments and implementing controls accordingly.

Step 2: Align internal controls

The next step is mapping the controls. In this step, auditors align the organization’s internal controls with the controls expected in the framework. In the best case, the control alignment has already been performed by management, but the exercise is often not complete before the audit.

Step 3: Conduct a gap analysis

The result of the control alignment is a list of internal controls versus expected controls. For design testing, auditors identify missing controls and poorly designed controls as gaps in the internal control environment.

Step 4: Document control design gaps and create action plans

The auditor discusses the gaps with management, who then implement corrective action plans to close the risk within the stipulated time frame. The audit team will continue testing while management designs new controls.

Step 5: Test the effectiveness of the controls and create action plans

The next step is testing the effectiveness of the controls, which the auditors focus on to check the efficiency in real-time.

Step 6: Monitor mitigation activities

Once testing is complete, the final step is to monitor the progress of management’s corrective action plans. Depending on the use case of the framework, corrective action plans would vary.

How can you implement multiple frameworks using VComply?

Though due to compliance necessity, an organization needs to manage multiple frameworks it often results in time wastage and operational inefficiency. A compliance management platform like VComply can help you navigate this situation seamlessly.

VComply is a leading cloud-based GRC platform that helps streamline the risk and compliance management programs of organizations with a strong focus on collaboration. VComply provides a solid foundation for managing risk and compliance so you can improve operational efficiencies and implement a culture of trust, transparency, and integrity. 

The benefits of implementing compliance and risk management platform VComply are: 

• Save 10+ hours per week – Receive automatic status updates, compliance task notifications, and verify uploaded evidence with a single click.
• An easy-to-use platform for everyone – It is intuitive, easy-to-use, and does not require a learning curve. 
• Seamless collaboration – Collaborate effectively with your compliance and risk management team as well as cross-functional departments. Break down silos to promote transparency and accountability across the board.

Conclusion

Having a common control framework and following it effectively takes a tremendous amount of effort and time. Although the benefits outweigh the costs, having multiple control frameworks in place can quickly make the situation worse if not managed properly. 

Using VComply integrated compliance management system, organizations can streamline the assessment of multiple frameworks through common controls, identify gaps, and easily create a standard control framework to eliminate redundant testing.