Achieving Compliance with Application Security Regulations: A CISO’s Guide

by GuardRails on May 3, 2023

Introduction

No one said being a Chief Information Security Officer (CISO) was an easy job. There are numerous concerns competing for attention from CISOs that keep them busy. One of the more pressing concerns pertains to meeting regulatory requirements for application security compliance.

Over the past several decades the use of information systems and applications has become a part of normal operations by organizations across various industries. Many of these industries such as financial services, telecommunications, and healthcare, among many others have a long-standing history of having to meet regulatory compliance standards. As more and more of these orginizations digitally transform, so does the importance of ensuring compliance with application security regulations has grown as well.

Failure to meet application security regulation compliance requirements can be costly to an organization. Fines can be in the millions of dollars. Not to mention the potential bad press, loss of confidence and customers that may occur as well. Security leaders, specifically CISO’s must address must find the most effective and efficient methods to meet these requirements.

In this article we will identify several of the more well-known standards and examine some of the top regulatory requirements included in them. Also, what steps can be taken by a CISO to ensure compliance.

Top Regulatory Requirements for Application Security Compliance

Application security regulatory requirements can vary depending on the industry. As previously mentioned, meeting complying with these standards is extremely important. Especially in regards to potential financial impacts and negative press. Furthermore, it’s important to meet these standards to ensure that certain levels of quality are being met for the products and services provided by an organization. It’s a competitive advantage to have high standards and documented compliance achievements in place.

Listed below are several of the more well-known and used regulatory standards that contain application security controls.

The Payment Card Industry Data Security Standard, or PCI DSS, is the information security regulatory standard used globally by the major credit card companies. There are a total of 12 requirements in PCI DSS that companies must comply with, of which Requirement 6 relates to developing and maintaining secure systems and applications.
The Health Insurance Portability and Accountability Act (HIPAA) of 1996 and the Health Information Technology for Economic and Clinical Health (HITECH) Act of 2009, are two regulatory standards related to the security of healthcare information in the United States. Combined, these two standards provide guidance on protecting the confidentiality, integrity, and availability of electronic records and related applications used in the healthcare industry.
The Sarbanes-Oxley Act of 2002 (SOX) is a regulatory standard in the United States that requires publicly traded companies use certain practices in their financial record keeping and reporting to prevent fraudulent activities. Since many of the financial reporting systems are IT based, SOX requires companies to use internal controls to secure these IT systems and applications.
The General Data Protection Regulation (GDPR) is a European Union (EU) regulatory standard for data protection and privacy for EU citizens, but it has impacts globally as well. One of the areas that GDPR addresses is the transfer of personal data within and outside of the EU. Thus the information systems and applications used in this process are within scope of the regulation.
The International Organization for Standardization (ISO) and the International Electrotechnical Commission (IEC) are two organizations that develop and publish standards used worldwide for various technical and nontechnical fields. In regards to securing information systems and applications, the ISO/IEC 27001 Information security management standard is widely used globally. The related security controls (ISO/IEC 27002) for this standard contains controls for ensuring the security of applications.
The National Institute of Standards and Technology (NIST) Is a government agency in the United States that establishes standards and security controls for information technology, information systems, applications and many other areas. NIST standards and guidelines are primarily intended for organizations in the United States, but many organizations globally reference their materials to help manage and reduce risks.

Overall, all of these standards have a significant impact on application security for the organizations that must comply with them. Depending on the standard the level of effort and expertise necessary to comply can have a significant impact on an organization’s operations. Nevertheless, the benefits of meeting these requirements can be immense.

How to Achieve Compliance with Application Security Regulations

The rapid-pace and dynamic nature of the current technical landscape may make achieving and maintaining compliance with application security regulations seem like a daunting task for CISOs. Nevertheless, achieving these goals is challenging but definitely within reach for an effective CISO. Especially, if a well- planned approach that incorporates industry better practices, the challenges can be reduced and managed.

At a high-level, here are some steps that can be taken by a CISO to help achieve compliance with application security regulations:

Proactive Mindset – Stay up-to-date and well informed on industry and regulatory information
Continuous Learning – Become a Subject Matter Expert (SME) on the details of relevant regulations
Strategic Thinking – Make service management (i.e., ITSM) practices a core competency
Embrace Automation – Automate processes as much as possible; Incorporate DevSecOps practices into the organization

As previously mentioned, the benefits of compliance can be immense for an organization. By no means should compliance be viewed as a “silver bullet” to cyber threats. But, it is part of a sound defense-in-depth approach that focuses on three core areas of People, Processes and Technology that must be addressed to become a high-performing organization.

Security Controls for Application Security Compliance

Compliance standards normally contain a set of controls that should be put in place to meet their requirements. This is extremely beneficial for a CISO, because the controls provide industry accepted guidance on what must be done to properly secure IT systems and applications. Furthermore, implementing controls from an industry standard is more effective and less time consuming than trying to develop a set of controls from scratch. Plus, using an industry standard is supporting evidence that a CISO has administered proper due care in securing the cyber assets of an organization in the event a breach does occur and accusations of having a weak security posture arise.

The guidance in security controls is normally easily understood and contains specific actions to take in order to be compliant. For example, ISO 27002, Control 8.29 – Security Testing in Development and Acceptance, requires that “new information systems, upgrades and new versions [to] be thoroughly tested and verified during the development processes. Security testing should be an integral part of the testing for systems or components”. The controls goes on to mention security testing should include testing of: user authentication, access restrictions, cryptography, configurations, operating systems, firewalls and other security components.

Another set of widely used security controls can be found in NIST Special Publication 800-53 Revision 5 (SP 800-53r5) – Security and Privacy Controls For, Information Systems and Organizations. Specifically, control CM-12(1) – Information Location | Automated Tools to Support Information Location advises organizations to “use automated tools to identify [information types] on [system components] to ensure controls are in place to protect organizational information and individual privacy.”

These controls are not too specific, but do provide enough guidance on what actions should be taken to achieve compliance. This is especially beneficial to CISOs that may be from smaller organizations or do not have a vast amount of resources available for their security program.

How GuardRails Can Help You Achieve Compliance

GuardRails is an asset to a CISO wanting to simplify the compliance effort. GuardRails can assist with achieving compliance with application security regulations by automating many of the control requirements. Activities such as security testing and implementing automation are key features of GuardRails products.

GuardRails’ customizable rule features allows organizations to focus on specific standards or requirements that govern their industry. Furthermore, this ability to customize allows organizations to make necessary adjustments to rules to meet changing requirements in standards as time goes on.

Conclusion

CISOs and other security leaders must achieve and maintain compliance with the security regulations for their respective organizations. There are various standards to follow depending on the industry. Some of the more well-known standards are HIPAA, PCI DSS, SOC2, GDPR, and others. No matter which standard an organization must comply with, achieving and maintaining compliance with application security regulations is of the utmost importance for a CISO.

Effective CISOs do not shy away from taking the necessary steps to ensure compliance with the regulations impacting their organization and/or industry. By making the most of the tools and resources from organizations like GuardRails the challenges of meeting these requirements can be greatly reduced.