In this blog, we provide a comprehensive guide on governance, risk and compliance frameworks with a focus on GRC implementation steps. We aim to educate organizations on the importance, process and benefits of implementing a GRC framework effectively.
There’s no shortage of changes and challenges businesses face, elevating and eroding operational stability. However, by using the right implementation strategy for a governance, risk and compliance (GRC) framework, you can take control of your organization and minimize a wide range of risks. With a GRC implementation plan, your organization gains a systematic approach to simultaneously limiting risk and empowering your teams to thrive.
In this article, we explain how GRC frameworks work, essential implementation considerations, some common challenges for companies, and how to overcome them.
Understanding the GRC Framework
A GRC framework is a methodology used to unify your governance, risk management, and compliance initiatives. You use it to establish procedures and standards that current and future employees can rely on as they navigate risks from compliance, deviations from governance principles, and unforeseen events.
Why Do Organizations Need a GRC Implementation Roadmap?
A GRC framework is necessary because it gives you a dependable, repeatable structure for managing challenges that could otherwise upend your operations or damage your reputation.
Many companies already have frameworks in place for other core initiatives. For example, you wouldn’t simply tell HR to “Go hire some good people, please.” Instead, you have specific interview and recruitment protocols you follow.
Similarly, without a GRC framework, individuals and entire departments make decisions without understanding their impact on the organization’s standards, risk tolerance, or compliance requirements. For example, without governance standards, employees at a healthcare organization may create weak, easy-to-guess passwords. This would expose the organization’s apps and data to brute-force attacks, potentially damaging breaches.
Key Steps in GRC Implementation
Successful GRC implementation typically focuses on people, process and change management. Here’s how segmenting GRC into these buckets may work.
People
The people who interface with your GRC framework should have clearly defined roles. For example:
- Leaders in your C-Suite should advocate for your GRC program and allocate resources to it. A supportive executive sponsor is critical in securing resources, aligning the GRC program with the organization’s strategy, and establishing a “tone at the top” for the organization’s stance toward GRC framework implementation.
- Risk managers need to constantly assess risks and provide strategies for mitigating them. They are also responsible for reporting to organizational leadership that keeps risk on mind and enables risk-based decision-making.
- Employees need to understand their roles in adhering to compliance standards and avoiding or minimizing risk in their daily decisions.
Process
With the right processes, you establish consistency and enable scalability, particularly because your processes can apply to as many people or departments as needed. For instance, you may want to implement processes in connection with:
- The workflows used to identify and prioritize risk. For instance, instead of simply building and deploying internet-facing software, you can give your dev team instructions requiring them to outline attack vectors new software may introduce.
- Regular compliance checks and audits. Your GRC framework can provide risk management professionals with checklists that tell them which compliance tools and techniques the organization should implement, such as encryption protocols and the automatic deletion of out-of-date data.
Change Management
Due to the hierarchical nature of many organizations, change management needs to start at the top. Decision-making stakeholders, such as executives, VPs, and managers, need to embrace the program and recognize employees who do the same.
You should then implement an employee education system, so your team members understand how to best support your initiative.
It’s also important to implement your program in phases. This allows people to understand how your GRC policies impact their daily activities before they become a ubiquitous facet of your operations. Obtaining a GRC assessment and roadmap can help prioritize the order of operations for implementing your GRC program.
Common Challenges and How to Overcome Them
Like with any important business endeavor, implementing cyber GRC programs may involve some hurdles. Not to worry. Here are some obstacles you can expect so you can start planning now to prevent or overcome them.
Complex Compliance Regulations
Many industries face the ongoing challenge of keeping up with compliance requirements and ensuring that the right controls are in place to address them. Compliance with these frameworks is typically required by either customers or regulatory agencies. Common compliance requirements that we see include HIPAA, PCI, NIST, FFIEC, SOX, SOC-2, and ISO 27001.
Staying up to date with regulatory guidance, choosing the right cyber protection solutions, and figuring out incident reporting scope and timelines can be overwhelming. For example, in the banking industry, organizations are required to report cyber security incidents within 36 hours of determining a qualified event has occurred.
How to Overcome Complicated Compliance Regulations
One powerful way to stay a step ahead of regulations is to perform compliance audits with an objective, independent examiner. Audit and assurance specialists can help you verify and test your compliance controls, identify gaps, address issues, and provide assurance that the processes you have in place are functioning optimally.
These specialists will bring the nuanced experience needed to ensure that internal controls comply with the regulations that apply to your particular organization and industry.
Internal Resistance to Change
A GRC framework implementation may shock your current company culture. Internal stakeholders may resist change because they don’t understand the benefits of a well-run GRC program. Stakeholders in large organizations may also be daunted by the complexity of standardizing approaches across multiple business areas and geographical locations.
Different areas of an organization manage cyber risk in different ways and to varying degrees — and some don’t at all. A GRC implementation requires all areas to standardize and agree on how exactly to manage and report on risks and issues going forward. Considering the daunting nature of the task at hand, it’s no wonder how common resistance to change can be.
How to Overcome Resistance to Change
When dealing with resistance to change, it’s important to acknowledge the level of effort required while effectively communicating the benefits of implementing a GRC framework, such as:
- Improved risk and compliance management: A GRC framework will help identify, assess and manage risks, ensuring compliance with internal policies and external requirements.
- Better decision-making and transparency: Implementing a GRC framework will provide real-time data and insights, making risk visible throughout the organization and leading to informed business decision-making.
- Increased stakeholder trust: A GRC framework will build trust with internal and external stakeholders, such as customers, investors and regulators.
- Cost savings: The efficiency and transparency a GRC implementation will generate can ultimately reduce the operational cost of risk management and the likelihood of incurring legal and regulatory compliance fees.
Investing in GRC software is another important step you can take to streamline and enhance the risk management capabilities provided by implementing a GRC framework.
Evaluating GRC Software
The marketplace is littered with great GRC software, such as Archer, SAP GRC, and ServiceNow GRC. However, it can be difficult to determine what the best fit is for a given organization. Key steps in identifying the right fit for your organization include:
- Identify the features you need right now for your specific environment and see which tools have them. For example, some companies may have specific risk or compliance reporting requirements that are labor-intensive and not easily repeatable. Identifying these needs can help evaluate tools’ reporting features and determine which tool best meets the organization’s needs.
- Predict your future needs and factor those in as well. Integration capabilities should be a factor when choosing GRC software if you eventually want to automate integration between your GRC solution and an identity and access management (IAM) tool.
- Assess whether any tools align with your users’ skill sets or existing tech stack. For example, if your organization already successfully uses ServiceNow in another capacity, it would be wise to consider ServiceNow GRC due to its platform familiarity and the likelihood that you have in-house experts who can become key partners in your success.
How to Approach a GRC Implementation Project
The best way to establish a realistic GRC implementation is to segment your project into smaller chunks and assign time frames for each. You should then add additional time for testing, both in between phases and once you have “v1” of your project in place. Of course, each organization’s needs are different, and your implementation plan will be shaped by crucial considerations such as:
- How complex is your environment?
- What is the urgency of implementing the GRC framework?
- Will you be investing in GRC software?
- How many resources are dedicated to the project at hand?
For example, your implementation project plan could look something like this:
- Assess your current GRC practices, get stakeholders on board, and establish goals and objectives.
- Test your work by running other stakeholders’ assessments and goals to get their feedback. Adjust accordingly.
- Identify any GRC software and experts needed to help with your implementation.
- Review the performance of your top software choice on a trial basis, even if that means using synthetic data or hypothetical situations, to see how it performs.
- Once you have your tools and team — external or internal — in place, use them to develop policies and processes that align with the goals outlined in the first step.
- Implement and test your GRC framework.
While using a newly adopted GRC framework or software solution, be sure to regularly evaluate your team’s performance, feedback and concerns while adhering to it. Change takes time, and feedback will help ensure you’re on the right track.
Use a GRC Framework to Guide Your Organization
You can use a strategic GRC framework implementation to promote a culture of accountability, transparency and trust. Overall, GRC frameworks provide a holistic approach to risk management and compliance, reducing the likelihood of material risks and compliance issues, enhancing overall efficiency, and improving decision-making and accountability.
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