Cybersecurity Compliance for Small Business Owners

Charting a Path Towards Cybersecurity Audit Success Navigating a cybersecurity audit process may seem daunting. This post simplifies the task, outlining steps to approach an audit confidently and establish a strengthened security framework. Conducting a Gap Analysis: - An initial gap analysis plays a vital role in the preparatory stage. By assessing the current controls against the framework's requirements, pinpointing areas of non-alignment becomes possible, enabling necessary improvements. Prioritizing and Implementing Controls: - It is advisable to prioritize control implementation and maturity based on evidence of potential threats or attacks. Strengthening basic controls should take precedence in areas where no such engagement is evident. All controls must align with one or more agreed-upon business risks. Documenting Policies and Procedures: - Clear and concise documentation of policies and procedures is essential for any cybersecurity framework. They serve as a touchpoint for both staff and auditors, providing insight into the processes and controls in place. Conducting Regular Internal Assessments: - Regular internal assessments ensure the organization's preparedness ahead of the official audit. These evaluations scrutinize controls against the framework's requirements. Automating Evidence Collection: - Automated collection and testing of evidence supporting the implemented controls not only strengthen the organization's case during the audit but also aid in meeting ongoing regulatory requirements. Promptly Remedying Identified Issues: - If the audit highlights any non-compliance areas or deficiencies, they should be promptly addressed, and corrective measures implemented as required. Engaging a Third-Party Assessor: - When ready, involving an accredited third-party assessor to conduct the official framework audit is a significant step. Ensure to provide them with the necessary documentation. Maintaining Ongoing Compliance: - After acquiring certification, maintaining compliance with the chosen cybersecurity framework becomes a continuing commitment. Regularly reviewing and updating policies and procedures will ensure alignment with any changes in the framework. Leveraging Digital Safe Harbor Laws: - Digital Safe Harbor Laws in four states provide a tort defense to organizations that implement published cybersecurity frameworks. These legal benefits can further encourage companies to adhere to such frameworks. In essence, a cybersecurity framework audit becomes less daunting when approached systematically. This step-by-step guide can provide a solid footing, ensuring that cybersecurity audits are handled with confidence and skill, leading to dependable risk mitigation. #cybersecurity #regulatory

Many of you are feeling overwhelmed by the new DORA requirements. Today I wanted to share a few more thoughts on leveraging your existing ISO Management Systems to conform to this new regulation. 1. ICT Risk Management  DORA Req: Identify, assess, and mitigate ICT risks. -  ISO27001 : Risk assessments (6.1.2), risk treatment (8.2). -  ISO22301 : Business impact analysis (8.2). -  ISO31000 : Comprehensive risk assessment (6.4). -  ISO27036 : Cybersecurity requirements for third-parties (5.2). 2. Incident Reporting and Management  DORA Req: Implement mechanisms for prompt incident detection, management, and reporting. -  ISO27001 : Incident response (6.1.3, 8.3). -  ISO22301 : Continuity plans (8.4), testing plans (8.5). -  ISO31000 : Risk management strategies (6.5). -  ISO27036 : Supplier risk management (8.4). 3. Third-Party Risk Management  DORA Req: Manage ICT third-party service providers. -  ISO27001 : External provider controls (8.1.4, Annex A.15). -  ISO22301 : Third-party risk assessment (8.2.3), continuity strategies (8.3). -  ISO31000 : Context understanding (6.3.3), organizational context (5.4.1). -  ISO27036 : Supplier requirements (8.1). 4. Cybersecurity Measures and Policies  DORA Req: Develop and implement robust cybersecurity measures and policies. -  ISO27001 : Leadership commitment (5.1), control objectives (Annex A). -  ISO22301 : Continuity planning (8.1), objectives (6.2). -  ISO31000 : Risk treatment plans (6.5.3). -  ISO27036 : Cybersecurity requirements for suppliers (8.2). 5. ICT System Security  DORA Req: Ensure secure ICT systems. -  ISO27001 : Secure design (8.2.2), secure communication (Annex A.13). -  ISO22301 : Continuity plans (8.4.4), recovery plans (8.4.5). -  ISO31000 : Communication (6.2), risk analysis (6.4.3). -  ISO27036 : Supplier performance monitoring (8.3). 6. Monitoring and Continuous Improvement  DORA Req: Establish continuous monitoring and improvement processes. -  ISO27001 : Performance monitoring (9.1), corrective actions (10.2). -  ISO22301 : Nonconformities (10.1), process improvement (10.2). -  ISO31000 : Risk management review (6.6), framework improvement (5.7). -  ISO27036 : Supplier performance evaluation (8.4). 7. Governance and Accountability  DORA Req: Define clear governance structures and accountability mechanisms. -  ISO27001 : Roles and responsibilities (5.3), management review (9.3). -  ISO22301 : Leadership commitment (5.1), continuity roles (5.3). -  ISO31000 : Risk management commitment (5.2), accountability (5.4.3). -  ISO27036 : Supplier relationship management (8.1). 8. Documentation and Reporting  DORA Req: Maintain comprehensive documentation and reporting mechanisms. -  ISO27001 : Documentation (7.5), risk treatment documentation (6.1.3). -  ISO22301 : Continuity documentation (7.5), internal audits (9.2). -  ISO31000 : Reporting (6.7), documentation improvement (5.7.2). -  ISO27036 : Supplier documentation (8.2). A-LIGN Atoro #DORA Kevin Shinners

Each Monday in July, I’m going to throw out an idea to small businesses in the #DIB who may feel like although CMMC is on the horizon, it’s still overwhelming. I hope these Mondays in July help to reframe things in manageable, realistic bites that are value-added to your cybersecurity and compliance efforts. 🧠 Bite 2 of 4: Start gathering documentation There’s something referred to as “the progress principle,” where researchers found that small wins — such as making headway on a project — boost people’s motivation. One of the things I found most daunting at the start of my own “CMMC journey” (ugh, that sounds so stupidly pretentious) is knowing that we’d need to gather a metric ton of artifacts, evidence, and documents. You eventually need proof that you’ve been doing things. By the nature of business, you have a lot of things that at a minimum will get you on the right track. You may not think you have a lot of that formalized, but I’m betting you have more than you realize - especially if you are an ISO9001/AS9100 business. ✅ HR / Administrative Records These help you check the box with access control, personnel screening, training, and policy enforcement proof. By gathering some of this existing data, you can later write policies (if you don’t already have them formalized). ·      Employee Handbook (Acceptable Use Policy, 3.1.22) ·      Background Checks (Personnel Screening examples – 3.9.1) – black out that PII, of course. ·      Signed NDAs or Confidentiality Agreements (Protecting CUI – 3.1.20) ·      Onboarding/Offboarding Checklists (Account management – 3.1.1–3.1.5) ·      Security Awareness Training Logs (Awareness – 3.2.1) ·      Job descriptions showing separation of duties (3.1.4) ✅ Physical & Facility Controls These support physical protection and access control families: ·      Visitor Logbooks (3.10.3) ·      Badge Access or Lock/Key Assignment Logs (3.10.1–3.10.6) ·      Alarm/Surveillance System Contracts or Invoices ✅ IT & Systems Management Many small businesses have informal systems that, when documented, satisfy CMMC: ·      IT Vendor Contracts / MSP Agreements (outsourcing functions – 3.12.1, 3.13.1) ·      Asset Lists or Purchase Records (System inventory – 3.4.1) ✅ Quality & Operational Management Often found in ISO 9001 / AS9100 systems: ·      Corrective Action Reports (can map to incident response or risk mitigation) ·      Internal Audit Reports (3.12.1–3.12.3) ✅ Financial or Insurance Documents These can help show due diligence or business continuity: ·      Business Continuity or Disaster Recovery Plans (3.11.1, 3.11.2) ·      Service Provider Agreements (clarify data handling expectations) ✅ Communications and Email Even informal communications can help demonstrate implementation: ·      Emails to staff about MFA rollouts, phishing training, or policy reminders ·      Meeting notes or team check-ins discussing security tasks