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Continuous Control Monitoring is a technology-based, iterative approach that enables organizations to detect anomalies that can go unnoticed with a traditional, manual, and periodic testing approach. It improves cyber risk identification, ensures effective IT compliance, creates opportunities for cost savings, and strengthens cyber resilience. Above all, it gives the true status of a company’s cyber risk and compliance posture through a transparent view of its internal controls.

Strong internal controls are essential given the complex regulatory environment and intensifying cyber risk. CISOs, CROs, and CCOs are turning to technology to streamline and automate their internal controls for long-term, sustainable IT and cyber risk and compliance management processes as paper-based, manual processes, electronic document management, and generic desktop tools have proved to be inadequate.

What are the Challenges Posed by Manual Approach to Control Testing and Monitoring?

A strong internal control system has become a prerequisite as organizations strive to become cyber resilient and compliant with regulations such as NIST, PCI, SOC 2, and HIPAA. However, applying proper internal controls and assessing their effectiveness is an ongoing and complex process.

Take the NIST Cybersecurity Framework for instance. The framework includes five functions – Identify, Protect, Detect, Respond, and Recover – which are further broken down into 23 categories and 108 sub-categories. Manually testing every corresponding control on a periodic basis is not only a time intensive but also error-prone and ineffective given today’s digital environment.

Major Bottlenecks

  • Resource Intensive: Manual processes consume significant resources, decreasing overall productivity and affecting the bottom-line
  • Unreliable: Based completely on human expertise, manual testing can be error-prone and unreliable
  • Expensive: Huge costs incurred to recruit people for testing controls and the time and resources spent on the process
  • Risk Prone: Manual interference and negligence pose risk of discrepancies, undetected risks, and non-compliance
  • Non-repeatable: Owing to lengthy and complex procedure, the repeated verification of tests at standard intervals becomes difficult

What is Continuous Control Monitoring?

Continuous control monitoring (CCM) is the automated, continuous testing and monitoring of controls across IT compliance, financial transactions, and regulatory compliance that enables organizations to proactively identify risks, improve cybersecurity and compliance posture, and reduce audit costs. It equips organizations to effectively remediate risks by assessing controls across the entire population, not just samples, in a more frequent manner.

According to Deloitte, “Continuous control monitoring (CCM) is a technology-based solution to continuously monitor processes and help [organizations] to transition from traditional, sample-based testing models to economical monitoring of full populations.”

Automated, continuous testing of internal controls ensures that they are working as intended. It allows organizations to easily configure and schedule tests related to completeness, accuracy, validity, authorization, and segregation of duties, and eliminates the key challenges of existing paper and spreadsheet-based systems.

There are four key elements for the complete Continuous Control Monitoring process:

  • Control Monitoring

    Monitoring controls that are already operating and ensuring they continue to operate as expected.

  • Risk Assessment of Entire Population

    Eliminating the risk of failing to identify anomalies outside of a sample test. Testing against the full population to achieve a higher degree of accuracy.

  • Autonomous Evidence Gathering

    Automating the process of gathering of evidence to avoid delayed audits and control tests.

  • End-to-End Control Testing

    Increasing efficiency and effectiveness of control testing using automated and repeatable workflows

Why Does Continuous Control Monitoring Matter?

A robust internal control system is critical for organizations to ensure regulatory compliance in today’s volatile world, but testing and monitoring security controls and gathering the evidence to show compliance is a time-consuming and rigorous process. Relying on manual and sample-based testing is resource-intensive, expensive, non-repeatable, and ineffective.

That’s where continuous control monitoring (CCM) and autonomous evidence collection come in. In today’s times of rising cyber risks, regulations, requirements, and the demands to do more with less, value-driven processes are essential.

CCM is the use of automated tools and technologies that enable you to continuously -- or at intervals you select -- monitor and test risk management processes and controls for effectiveness. By leveraging this autonomous monitoring approach, you can ensure effective compliance, reduce costs, improve operational efficiencies, and above all, get the true status of your organization’s compliance health through a transparent view of its internal controls.

How to Set Up Continuous Control Monitoring?

Setting up CCM typically involves the following steps:

1. Identifying Key Controls

First and foremost, organizations need to identify processes or controls related to the applicable industry control frameworks, such as NIST, PCI, SOC 2, HIPAA, and others, as well as various regulations issued by oversight bodies. Here, key controls are prioritized for continuous monitoring.

2. Defining Control Objectives

Once key controls have been identified, the next step is to define the control objectives or goals, i.e, defining the risk or compliance categories that are intended to be mitigated through a control.

3. Specifying Automated Tests or Metrics

Organizations must specify and embed automated tests or metrics that will help verify whether the controls are effective and working as intended.

4. Determining the Process Frequency

The next step is to determine the process frequency to perform the control tests – either continuously or at select intervals.

5. Establishing Well-Defined Processes

Organizations need to establish well-defined processes for managing the notifications, communicating and investigating the identified exceptions or deviations, and addressing the control weaknesses.

How does Continuous Control Monitoring Work in the Cloud?

Cloud computing is becoming more and more entrenched in corporate IT. Already, 96% of organizations use at least one public cloud, while 84% have at least one private cloud. Meanwhile, 37% of large enterprises say their annual cloud spend exceeds $12 million, while 53% of small and medium businesses spend more than $1.2 million on the cloud per year. That’s according to the Flexera 2022 State of the Cloud Report.

As a shared resource, the data contained within the cloud is vulnerable to security and privacy threats. Every year, bad actors find newer and better ways of attacking the cloud to steal sensitive data. Continuous monitoring of controls is one of the best measures to boost cloud security.

What are Some of the Top Cloud Threats and Vulnerabilities and Associated Controls?

Since the pandemic, more organizations have come to rely on the cloud for remote working, collaboration, commerce, and more. As cloud usage skyrockets, so have the associated security risks. The best way to safeguard your organization is by establishing pre-emptive controls.

Top Threats & Vulnerabilities Key Controls

The most common cloud vulnerability, misconfigurations, can leave cloud assets exposed to breaches, malicious activity, and outages. They typically stem from misunderstandings of shared responsibility or a lack of knowledge about security settings.
• Restrict inbound and outbound ports
• Run penetration tests
• Regulate cloud access permissions
• Disable legacy or insecure protocols
Poor identity, access, and privilege management

With remote workforces, IT administrators have less control over who accesses which data and when. Attackers are seizing this opportunity to steal user credentials and hijack cloud accounts by exploiting weaknesses in identity and access management.
• Regulate access to cloud networks
• Enforce the principle of least privilege
• Configure robust password policies
• Remove unused credentials
• Ensure proper key management
• Educate employees about their security responsibilities
Insecure APIs

Cloud applications typically communicate with each other through APIs. But if these APIs don’t have regular security updates as well as proper authentication and authorization, they can create the perfect entryway for attackers to access sensitive data.
• Encrypt data
• Use an API gateway to authenticate traffic
• Leverage tokens and keys to verify user identity
• Integrate two-factor authentication
Shared tenancy vulnerabilities

In a multi-tenant environment, a vulnerability in one container can allow an attacker to compromise the containers of other tenants on the same host. Side-channel attacks can also occur due to a lack of authentication controls for shared resources.
• Encrypt data
• Enforce multi-factor authentication
• Use virtualization instead of containerization for data isolation
• Understand shared responsibilities
• Automate data backups
Third-party vulnerabilities

Third-party software in the cloud may contain vulnerabilities that were intentionally inserted by threat actors or rogue developers to compromise cloud environments.
• Conduct due diligence on third-party software
• Look for products that are officially supported with compliance certifications, bug bounty programs, etc.
DDoS attacks

Criminals can flood cloud networks with overwhelming traffic, rendering resources unavailable to both customers and employees. The more systems residing in the cloud, the greater the impact of a DDoS attack.
• Employ web application firewalls
• Use load balancers to restrict internet traffic
• Leverage access control lists to regulate incoming traffic
Insider threats

Malicious insiders with legitimate access to cloud systems can cause far more damage than outsider threats. They can also go undetected for months.
• Monitor cloud user analytics to identify behavioral anomalies
• Encrypt data; safeguard encryption keys
• Establish secure landing zones
• Implement incident response plans

What are Some of the Standards and Frameworks for Ensuring Cloud Compliance?

Cloud security controls aren’t just necessary for threat mitigation, but also for compliance. There are a multitude of standards, frameworks, and regulations that companies in the cloud are expected to adhere to, including:

  • ISO/IEC 27001/ 27002 – Provides a baseline for an information security management system and control framework
  • ISO/IEC 27017:2015 – Supplements ISO 27002 with additional implementation guidelines for cloud security controls
  • ISO/IEC 27018:2019 – Identifies controls to protect personally identifiable information (PII) in the public cloud
  • ISO/IEC 17788:2014 – Provides a terminology foundation for cloud computing
  • ISO/IEC 17789:2014 – Specifies cloud computing roles, activities, and functional components
  • NIST Cloud Computing Reference Architecture – Defines the responsibilities of cloud providers, consumers, brokers, auditors, and carriers
  • NIST CSF – Provides standards, guidelines, and best practices to mitigate cybersecurity risks
  • SOC Reporting – Helps provide assurance around cloud security controls
  • PCI-DSS – Identifies baseline requirements to protect cardholder data
  • HIPAA – Provides standards to protect personal health information
  • CIS AWS Foundations v1.2 – Describes best practice security controls specific to Amazon Web Services (AWS)
  • CIS Controls Top 20 - Prioritizes actions to guard against cyber threats.


How Do I Implement CCM in the Cloud?

Here are the key steps involved in implementing Continuous Control Monitoring in the cloud:

  • Set up cloud security controls in line with compliance frameworks
  • Establish a centralized repository of controls mapped to the corresponding risks, regulations, testing processes, policies, etc.
  • Prioritize cloud security controls that require continuous monitoring
  • Define control objectives and corresponding assertions

  • Build automated tests and metrics that indicate the success or failure of each assertion

  • Determine the frequency of control testing

  • Identify, report, and remediate control deficiencies

What are the Benefits of Continuous Control Monitoring?

Continuous Control Monitoring enables organizations to:

  • Reduce risk by sending automatic notifications to control and process owners when exceptions occur, or when deviations are identified
  • Improve the business velocity by accelerating the audit and compliance process by monitoring controls continuously with automated evidence collection and keep the compliance and audit programs on schedule
  • Optimize costs and improve profitability by allowing staff to focus on risky items vs running tests
  • Increase the efficiency of managing multiple compliance frameworks by applying test results to multiple controls across different regulations
  • Increase the accuracy of identifying anomalies with complete testing against limited sampling in manual assessment
  • Increase scalability with elevated coverage of control testing across the organization and reduce the attack surface
  • Increase visibility with a near real-time view of the compliance status and track evidence trail

To learn more and request a demo of autonomous control testing and monitoring, click here.

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