It is often much easier to justify investing security resources that are legally or contractually mandated than basing such investments on the overall value to the company of an adequately funded information risk management group. Given this disparity of funding “must do” tasks while overlooking “should do” tasks, security teams can take the initiative and do the “non-essential” actions that strengthen their organizations’ security as they meet compliance requirements. This approach also provides a security group the information it needs to justify requests for risk management resources.
The compliance standards currently applicable to application security include PCI-DSS, HIPAA, FFIEC, GLBA, ISO 27001/27002, and Sarbanes Oxley. A organization’s failure to comply to their standards can lead to fines, legal action, and sometimes even business shutdown. When executive management is faced with these possibilities, a typical conversation with the company’s security staff usually results in the conclusion that, “The company must spend $A on X compliance mandate because non-compliance with regulation X carries an estimated cost of $B.”
As obvious as it may seem that compliance requirements should convince management to allocate funds for security, the necessity for compliance is often insufficient to get management to actually make the needed investments.
Government and/or industry-mandated regulations can frequently differ in how they impact an organization, and typically can be applied differently to each organization. Some organizations may be able to change specific aspects of how they do business, and thus meet mandated requirements by changing the parameters of compliance. Other organizations, after estimating that the punishment for non-compliance will cost less than the costs necessary to comply, may decide to simply ignore the notification to comply.
At WhiteHat we think a more realistic way to look at compliance issues is that in some instances you MIGHT get hacked, but for ignoring certain regulations you WILL get audited. In either case it is essential to understand the “historical record” of how a particular compliance standard has been applied within an industry; and to then be able to estimate the capital and operational expenditures required for your organization to comply. This way, when management asks you to justify your request for funding based on how NOT DOING SO would impact business, you’ll have the information immediately at hand, which will make the decision-making process far easier.