A Better Handle
Smart CIOs are working a new priority: Greater visibility into their governance, risk and compliance efforts. Holistic approaches are helping.
By George V. Hulme
Holistic is happening. For medical researchers, a holistic approach
involves considering the totality of a patient’s biological, psychological
and sociological factors. For scientists, the holistic approach involves
thinking of biology, sociology and psychology as complex, sometimes
chaotic systems. And for CIOs, a holistic approach can help improve
risk and compliance efforts by allowing them to manage various areas
of risk, including regulatory, financial, strategic, operational and compliance risk.
These new approaches and solutions are
needed by CIOs and their companies to
gain traction in the area of risk. Further,
CIOs need to integrate their compliance,
security and governance efforts—the people,
policies, processes and technologies—
into a unified governance, risk and compliance
(GRC) initiative. This holistic
GRC solution can help CIOs manage their
IT risk efficiently and effectively.
IT solution providers—including suppliers
of network management, system
management and enterprise resource planning
solutions — are developing a broad
range of GRC management tools. Their
aim: Help CIOs to model controls and procedures,
associate those controls with relevant
policies and regulations, and enforce
compliance across the organization. In this
way, both CIOs and business executives can
improve their visibility into key compliance
risks. They also can determine what supporting
evidence is needed to demonstrate
compliance with internal policies as well
as external regulations.
High Costs
The costs of GRC are substantial. In fact,
market watcher AMR Research estimates
that U.S. businesses spent nearly $30 billion
on GRC in 2007, a nearly 9 percent
increase from the previous year. Complying
just with Sarbanes-Oxley cost U.S. businesses
$6 billion in 2007, AMR estimates.
“The adoption of IT security, financial
fraud and regulatory compliance monitoring
systems has been proliferating,” says
Dennis Chesley, Principal at consultants
PricewaterhouseCoopers. “Organizations
want to get better at adopting controls, capturing
risk and governance information,
and tying these systems into other parts of
the company.”
That’s true whether the risks are financial,
geopolitical, natural disasters, legal or
those associated with IT security and against the jeopardy associated with all of
these risks, companies have put policies and
technologies in place to manage and mitigate
risk; identity management
systems to make certain
that only authorized users
will have access to critical IT
resources; intrusion detection
and prevention systems
to protect against or stop
breaches; backup and disaster
recovery systems; and even
records and file management
systems as ways to mitigate
potential legal liability.
Underlying the challenge
of examining risk is the fact
that at many companies, information about
corporate policy, risk and compliance has
been squirreled away in literally hundreds,
if not thousands, of documents and spreadsheets.
The same degree of ineffective practices
may be found in how multiple teams
—security, network, applications, internal
audit—each review and report on identical
systems and controls.
“You don’t want to have workers from
the internal audit department, IT security,
and the application or infrastructure teams
all coming down to conduct assessments
on the same sets of systems,” says Richard
Ptak, Principal Analyst at industry watchers
Ptak, Noel & Associates. “But that’s
exactly what is happening. Internal controls
and systems are being evaluated multiple
times, causing a significant amount
of redundant work.”
In the Beginning
Although technology certainly can be
enlisted to help cut the costs of risk and
compliance, it’s often not where the compliance
process starts. Rather, the first step
involves quantifying the organization’s
level of risk tolerance. Next comes putting
into place governance policies based on
those tolerances. Then, the key areas of risk
that need to be managed are identified.
Only then is it time to build the underlying
technological controls to help the
organization enforce those polices.
“We often begin by helping an organization
gain a better understanding of its
core principles and risk tolerances,” says
PricewaterhouseCoopers’ Chesley. “The
idea is to gauge accurately how well its
people, processes, information and technologies
are aligned so we
can better integrate their
governance, risk and compliance
efforts. Typically,
there are multiple groups
reporting on the same controls,
and their results often
don’t reconcile.”
The number of controls a
large corporation must manage
can be extremely high,
and they often extend to
every technology deployed.
These include controls such
as identity and access management, security
event managers, disaster recovery and
records-management systems. “There’s
hardly an area of IT that GRC efforts don’t
touch,” says industry analyst Ptak.
CA’s recent introduction of CA GRC
Manager makes it possible for CIOs and
other IT managers to improve fact-based
decision-making and oversight of their
entire portfolio of IT risks and controls. It
does so by mapping and monitoring related
policies, best practices and regulatory compliance
requirements within a central
repository of risks and controls, and through
management of the ongoing execution of
policy remediation efforts. “The CA GRC
Manager permits companies to centrally
view, analyze and manage their IT risks,”
says Jacob Lamm, a CA Executive Vice
President of the Governance Group. “This
transparency accelerates decision-making
—and makes it possible to focus first on the
most pressing risks.”
Market watcher Ptak calls CA GRC
Manager a suite of solutions to execute
good governance and management, based on the understanding of risk, good data discovery
and the potential for risk. “You
have tools that enable you to define policies,
apply policies, and implement and
monitor the application of those policies,”
he adds.
For the State of Colorado Department
of Human Services (CDHS), that
capability is welcome. The department’s
compliance load is a heavy one: It must
contend with the federal Health Insurance
Portability and Accountability Act
(HIPAA), various federal and state
regulations, nearly 20 state cyber-security
policies and a passel of other IT mandates.
As Colorado’s second largest agency,
CDHS has an annual operating budget of
$1.8 billion, employs more than 5,000
employees and works with thousands of
community-based service providers. The
department also oversees the state’s 64
county departments of social and human
services, including mental health and
developmental disability services, the
juvenile corrections system, and all state
and veterans’ nursing homes.
Within CDHS are numerous IT teams,
each specializing in a unique technology
management area, such as network security,
engineering, messaging, and network
and applications. Unfortunately, coordination
among these teams is sometimes less
than optimal, according to Kelley Eich,
Director of Technical Operations in the
CDHS’s office of IT services. “At any
given moment, if there’s an incident or
deviation from our policy, we could have
four separate teams taking action, each
without knowing what the others are
doing,” she explains. “When it comes to
effectively and efficiently seeing and managing
risks, this creates challenges.”
That’s no small management burden,
considering that the agency must contend
with 50 rules from HIPAA alone that
govern the use of certain IT systems. To
better manage these IT policies and their
associated risks, CDHS earlier this year
licensed CA GRC Manager. “What
caught our eye,” Eich says, “is that it
comes with pre-populated polices, such as
those that relate to our HIPAA mandates.
Having those criteria already available
helps us to better manage these efforts
right out of the box.” Over time, she adds,
the CDHS will augment CA GRC
Manager with policies, procedures and
standards that are specific to its agency and
business objectives.
The overall goal, Eich explains, is to
streamline risk- and governance-related
projects and teams, as well as to aggregate
IT policies as they relate to various regulations
and internal security and governance
policies. “As CA GRC Manager is
deployed,” she adds, “we should be able to
make sure that our various departments are
better focused on risk remediation, and
CA GRC Manager should give us a more
complete view of our risk posture at any
given time.”
Streamlined Savings
The cost savings from streamlining these
efforts can be considerable, mainly due to
the automation of many processes associated
with managing risk. For example,
consider a financial services firm that
needs to assess a set of its systems for compliance
with laws, regulations and internal
policies. The execution of such a program
could be governed separately by internal
IT policies, local and federal regulations,
and financial industry regulations, each
with a separate set of security and compliance
teams. “We often get calls from risk
managers or chief operating officers,
explaining that their companies are conducting
four to five risk and control assessments
each quarter,” explains Chesley of
PricewaterhouseCoopers. “Most of the
assessments seek the same information, and
managers want a way to stop the waste and
achieve a clearer, easier way to manage
these processes. That’s one of the main drivers
for these types of solutions.”
GRC solutions can benefit companies
in other industries, too. These solutions
help compliance managers analyze and
report rapidly on multiple regulations and
policies, explains analyst Ptak. Also, by providing
comprehensive analyses, these solutions
can help managers quickly understand
their risk profiles. This helps organizations
to not only streamline their risk and governance
efforts and cut redundant processes,
but also to adapt their operations more
effectively to constantly changing regulatory
requirements.
But even the best technological solutions
can’t work alone. CIOs and their
staffs also need to change their attitudes
toward compliance. Also, many CIOs
now seek ways not only to unify the governance,
risk and compliance efforts of
their staff, but also to use the information
to better manage business risks. “Many
organizations consider GRC to be a competitive
edge,” says analyst Ptak. “They
can reduce the costs associated with governance
and compliance, and they can
more effectively adapt to an ever-changing
risk landscape.”
Adds CA’s Lamm: “Companies that
deploy effective holisitic governance systems
are going to run consistently better
than those that don’t.”While he’s talking
about IT governance, Lamm is quick to
point out that the same is true when it
comes to using technology to govern financial,
market and many other types of risk.
The end goal is a single governance solution
for setting and enforcing the organizational
policy for risks. For smart CIOs,
that’s a safe proposition.

George V. Hulme is a Minneapolis-based freelance writer
who has covered business and technology for nearly 20 years.