10 Symptoms Of Check-Box Compliance

Security and risk pundits have long lamented the practice of going through the motions just to satisfy security regulations and standards like PCI, SOX, and HIPAA. Phoning it in may keep the auditors in check, but it won't mitigate the risks of attack. According to security and compliance pundits, the following are some of the telltale signs an organization is falling into the trap of check-box compliance.

1. Arguing over which standards are best.
Check-box-oriented organizations tend to get caught up in the regulatory minutiae so that they can't see the forest for the trees.

"Some organizations claim that they take the best of various policies and then go to work on a 'deeper policy,'" says Ron Gula, CEO and CTO of Tenable Network Security. "However, if you look closer at these sorts of things, they often target the union of various compliance standards and not the aggregation of all checks."

2. Losing sleep over an audit.
"If you are losing sleep about passing an upcoming security audit, you've got the check-box compliance disease -- and it's probably rampant in your organization," says Lamar Bailey, director of security research and development for nCircle.

As he puts it, security standards are the point of embarkation for the risk-management journey. They're not meant to be the end-all, be-all for securing an organization. They just get you started. Organizations that have a hard time even satisfying these beginner requirements should lose sleep over how insecure their systems are, not whether the auditor will break out a rubber stamp.

"These standards are like training missions in video games: They can help you acclimate, but they in no way represent the real game," Bailey says. "If you can't pass them with two hands tied behind your back, your need to quit and find another game."

[ Staying out of the checkbox compliance mentality is hard work. Recent studies show organizations are struggling to keep up with GRC See Risk And Regulatory Overload. ]

3. Putting line-of-business managers through spreadsheet hell.
If you make line-of-business managers fill in voluminous review forms, your organization is probably on the compliance-for-compliance-sake bandwagon, says Jason Garbis, vice president of marketing for Aveksa.

"Many times, enterprises approach access compliance by manually creating and emailing large, complex, and unwieldy spreadsheets," Garbis says. "If you're asking line-of-business managers to review a jargon-filled spreadsheet with hundreds of rows, chances are that this is a check-box review."

4. Viewing penetration testing as a panacea.
With so many compliance regulations requiring a penetration test, unsophisticated organizations seeking to cover only their bases view pen testing as an all-purpose security curative. If you're an organization that seeks to use pen testing instead of monitoring or vulnerability management, odds are you suffer from check-box compliance.

"If a company wanted to do the bare minimum, they could hire unsophisticated penetration testers and, when they don’t break in, claim 100 percent security," Gula says. "Of course, this type of penetration test is not a substitute for a full audit."

5. Using tools geared for forensics rather than prevention.
Unduly focusing on monitoring tools for the sake of establishing audit trails, without ever thinking about attack prevention, is a strong signal that your organization has its head so far in the regulations that it has forgotten the reason they're there in the first place.

"Most compliance regulations do not have security enforcement restrictions; they mainly focus on monitoring," says David Maman, CTO of GreenSQL. "Having a monitoring system instead of a prevention system is a modern take on closing the barn door after the cows have gotten out."

Next Page: Confusing logging and log storage with monitoring. 6. Confusing logging and log storage with monitoring.
Nevertheless, monitoring still does have a place in the overall risk-management framework. The problem is that most organizations confuse logging and log storage with effective monitoring.

"It can be very difficult for any size network to have a reliable logging infrastructure, and this is required by lots of compliance regulations," Gula says. "However, getting logs is much different than analyzing logs and looking for evidence of attacks and abuse."

7. Overbuying to get a specific compliance-oriented feature.
If your organization spends significant amounts of dough on tools that duplicate security features sported by tools they've already purchased just so you can nab one specific compliance-focused feature, then that's a dead giveaway you've fallen in the chec-kbox compliance trap, says Marcus Carey, security researcher at Rapid7.

It happens all the time, Carey says. "You call up a vendor because they're the only one that does X that you specifically need to satisfy some specific requirement of the regulation," he says. "You discover you can't buy X alone, so you end spending six figures on a solution that duplicates most of what you already have installed."

8. Generating a low access revocation rate.
Making information accessible on a need-to-know basis is a security fundamental, which is why access reviews are often included within so many regulatory requirements. Unfortunately, though, most check-box compliance organizations perform these perfunctorily to cover their derrieres. So unless your organization is extremely mature in its security processes, if an access review doesn't yield many changes, it was probably done just to satisfy requirements, Garbis says.

"If an organization is doing a good job of meeting compliance goals, each review process should generate a not-insignificant number of changes that have to be fulfilled," he says. "If a review process generates a very low number of follow-up changes, it's likely that this was a check-box review."

9. Spending more on system maintenance than security operation.
Check-box compliance tends to lure organizations into tons of make-work projects, so that in the long run they end up spending more time maintaining systems they buy to check those boxes than they do in actually making sure the organization stays secure, Carey says.

"[These] organizations have to hire full-time employees dedicated to systems that don't work," he says, "so they have a huge capital expense, man hours, and consulting hours on something that is effectively useless."

10. Systems cause more audit problems than solutions.
In the same vein, Carey says these check-box-prone organizations also tend to see more audit problems come out of their compliance systems than solutions.

"I see misconfigured or poorly designed systems causing a nightmare for organizations trying to explain every false-positive to an auditor," he says. "It's unfortunate the solution they bought to pass audits can ruin them when they actually procure it. That's a double whammy."

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