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.
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.
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:
Monitoring controls that are already operating and ensuring they continue to operate as expected.
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.
Automating the process of gathering of evidence to avoid delayed audits and control tests.
Increasing efficiency and effectiveness of control testing using automated and repeatable workflows
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.
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.
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.
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
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 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.
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
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
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:
Here are the key steps involved in implementing Continuous Control Monitoring in the cloud:
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
Continuous Control Monitoring enables organizations to:
To learn more and request a demo of autonomous control testing and monitoring, click here.