We speak with many IT Managers each week who are seeking to be compliant with NIST SP 800-171 with a goal of becoming CMMC Certified. One of the recurring themes we see are that IT Managers are often tasked with a complex task which is to explore a major IT system change such as virtualization or moves to cloud services at the same time they are seeking to become compliant with one of these standards or achieve CMMC Certification.
Small business owners and IT Managers have a lot to consider when they have a goal of compliance and proper cyber hygiene. Many are not aware that decisions regarding how their system is setup could actually create extra expenses and excessive spending if they choose the wrong solution. As an example, many of the people we speak with are not aware that Microsoft has directly stated that Office 365 Commercial does not meet the requirements of DFARS 252.204-7012 compliance requirements because it does not meet FedRAMP Moderate standards.
As a company that operates as both a cyber security focused Managed IT Service Provider (MSP) and an Information Security Compliance Consultant the choice of what to focus on first leaves many decision makers with a big question: What should I focus on first?
Our answer is always the same: The safest way for any company to proceed is to focus on understanding compliance first. The reason for this is that NIST SP 800-171, DFARS 252.204-7012, and CMMC Certification have specific controls that dictate what types of solutions and services should be in place. In addition for cloud service providers there are special rules and requirements if they will be handling CUI or CTD or CDI. Our advice: Get the compliance understanding first before you spend money on IT changes that may not work for you later.
When a company decides to make a major systems change, it can be an exciting time. New software or hardware can bring increased productivity, streamlined processes, and a competitive edge. However, before making any changes, it is important to consider the potential risks associated with the change. One of the most critical risks is compliance. A compliance GAP analysis should always be done before a major systems change to ensure that the company remains in compliance with all relevant regulations.
What is a compliance GAP analysis?
A compliance GAP analysis is a process that evaluates a company's compliance with relevant laws, regulations, and standards. The process involves identifying the gaps between the company's current compliance practices and the requirements of the relevant regulations. A compliance GAP analysis is critical before a major systems change because it ensures that the company understands the compliance requirements of the new system and can implement the necessary changes to remain compliant.
Why is compliance important?
Compliance is important for several reasons. First, compliance helps companies avoid legal penalties and fines. Failing to comply with relevant regulations can result in significant financial penalties, damage to a company's reputation, and even criminal charges. Second, compliance ensures that companies are meeting ethical and social responsibilities. Companies have a responsibility to protect their customers, employees, and the environment. Compliance helps ensure that companies are meeting these responsibilities. Finally, compliance can help companies gain a competitive edge. Many customers prefer to do business with companies that are transparent and ethical.
Why is a compliance GAP analysis important before a major systems change?
A major systems change can impact a company's compliance with relevant regulations. For example, a new software system may collect additional data from customers, which may require the company to comply with additional data protection regulations. Additionally, a new system may require changes to existing processes, which may impact compliance. Conducting a compliance GAP analysis before making any changes helps companies identify potential compliance risks and develop a plan to address them. This ensures that the company can implement the new system without violating any regulations or facing penalties.
What does a compliance GAP analysis involve?
A compliance GAP analysis involves several steps. First, the company must identify the relevant regulations and standards that apply to the new system. This may include industry-specific regulations, such as HIPAA for healthcare companies, or general data protection regulations, such as GDPR. Second, the company must evaluate its current compliance practices to identify any gaps between its current practices and the requirements of the relevant regulations. This may involve reviewing policies and procedures, conducting employee interviews, and reviewing existing data protection measures. Finally, the company must develop a plan to address any identified gaps and ensure compliance with the relevant regulations.
Conclusion
In conclusion, a compliance GAP analysis should always be done before a major systems change. Compliance is critical for avoiding legal penalties, meeting ethical responsibilities, and gaining a competitive edge. A compliance GAP analysis helps companies identify potential compliance risks associated with a major systems change and develop a plan to address them. By conducting a compliance GAP analysis, companies can implement new systems without violating any regulations or facing penalties.
