Everything You Should Know About Continuous Controls Monitoring (CCM)

Originally published by Vanta.

Continuous controls monitoring (CCM) is a crucial aspect of making GRC processes more automated, accurate, and actionable through technology. It helps organizations transition from inefficient point-in-time checks to automation-driven compliance controls that provide a real-time view into their security posture. That’s why many proactive risk management teams are already prioritizing control automation for their GRC program.

This article will cover the in-depth information you need to embed CCM in your security and compliance program. We’ll discuss its main benefits and use cases, as well as offer some practical steps for implementing it within GRC operations.

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What is continuous controls monitoring? Definition and importance

Continuous controls monitoring refers to using technology-based solutions to support the practice of automated, ongoing (or highly frequent) tracking of the compliance, risk management, and security controls you’ve put in place. A control, in this context, is a safeguard or countermeasure used to detect, prevent, and minimize vulnerabilities around an organization’s data, infrastructure, and other assets.

‍A journal published by ISACA explains CCM as a subset of “continuous assurance, alongside continuous data assurance (verifying the integrity of data flowing through systems) and continuous risk monitoring and assessment (dynamically measuring risk).”

‍The need for CCM arose from various challenges of traditional control monitoring, such as:

• Delayed detection of control failures and compliance breaches due to point-in-time checks.
• Loss of time and resources due to manual and complex processes, which often leaves room for task fatigue, human error, and inconsistencies.
• Inability to keep up with changes in the regulatory landscape.
• Limited scope to track the volume and complexity of data that follows organizations expanding to new geographies, products, and technologies.

‍CCM effectively resolves these issues, leveraging technology to help teams keep relevant information updated and accessible and maintain a firm grasp of all GRC controls.

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Benefits of continuous controls monitoring

Like any form of GRC automation, CCM brings numerous benefits, most notably:

• Increased efficiency of compliance and audit processes: CCM significantly reduces the need for manual evidence gathering and documentation at regular intervals. Using the right tools, you get a centralized repository of all the data necessary for testing and monitoring controls, which drastically reduces painstaking compliance and audit processes.
• Cost reduction: CCM lets you remove inefficient processes and control deficiencies before they get out of hand, which cuts remediation costs. It also helps achieve timely compliance and avoid the risk of penalties. Finally, since teams can monitor controls more efficiently, they get more time to spend on higher-impact projects.
• Better strategic and operational decision-making: Continuous controls monitoring gives executives and department heads a comprehensive overview of the risks associated with strategic and operational decisions, ensuring clear, data-backed decision-making.
• Reduced risk of outages and data breaches: With continuous monitoring, you can proactively identify data and infrastructure vulnerabilities before they’re exploited, and remediate them faster to fortify your organization’s security.
• Streamlined incident response efforts: Besides preventing incidents from escalating, CCM informs the best actions you can take as a part of incident response plans.

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Continuous controls monitoring: Common use cases

CCM’s agile and responsive framework makes it useful for organizations in any industry. It’s particularly important in the IT, financial, and health sectors that deal with an ever-expanding profile of data privacy, regulatory, and security threats.

‍Here are four prominent use cases of a CCM system:

1. Risk quantification and monitoring: CCM helps your organization assess its risk posture on a more granular level. With automated configurations, you can gather the data you need to quantify risks and monitor them ongoingly. When a control fails, pre-configured alerts empower you to remediate it quickly.
2. Identification of control gaps and tracking performance: If implemented properly, CCM helps you track control gaps without laborious legwork. The consistent data availability allows for near real-time reporting.
3. Access management: Traditional access management is inefficient because it typically involves manual cross-referencing of human resource information system (HRIS) data with employee roles and permissions. CCM fixes this by performing automated tests that flag employees with roles that don’t have a corresponding access level.
4. Change management: Continuous monitoring systems integrate with device management platforms to enable secure changes in hardware and other configurations. Additionally, CCM supports upscaled operations following the pursuit of new frameworks and ongoing audits.

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How to implement continuous controls monitoring workflows

The exact process of continuous controls monitoring implementation depends largely on your existing processes, risk exposure, and compliance requirements. We have outlined four standard steps you can expect below:

1. Identify the key processes and controls.
2. Define control objectives.
3. Set up automated tests.
4. Ensure adequate monitoring and reporting.

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Step 1: Identify the key processes and controls

Continuous monitoring doesn’t yield the same benefits to all processes, so the first step is to identify the most critical processes that can be automated, as well as their corresponding controls.

‍One way to do it is to pull historical data from previous internal audits, control breakdowns, and self-assessments. You can then combine your findings with the controls from established frameworks, such as:

• ISO 27001
• NIST Cybersecurity Framework
• SOC 2

‍After you have your list of controls, you need to define clear priorities. You can use various criteria to do so—for instance, you may decide it’s worth implementing CCM for controls with:

• High risk scores calculated based on risk assessments
• Complicated sub-processes that can lead to human error
• Abundant data availability from the tools used to implement that control

‍Due to all these considerations, process and control identification can take quite a bit of time and effort. Still, it’s crucial to give this step the attention it deserves as having a list of control priorities will make further decisions easier.

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Step 2: Define control objectives

Objectives outline the primary function of your controls and act as reference points to help you determine their performance. Much like the controls themselves, you can define objectives based on internal data and specific frameworks.

‍In the former case, you need to make sure your control objectives are aligned with your overarching business objectives. It pays to factor in your risk appetite, as one of the primary purposes of your controls is to mitigate risks.

‍As you expand your scope, focus on compliance with relevant frameworks when defining objectives. For example, if you’re working with ISO 27017 to protect your cloud infrastructure, your security control objectives may include the following:

• Ensure adequate monitoring of cloud services.
• Remove customer assets when a cloud service is terminated.
• Align virtual and physical cloud networks.

‍The goal here is to have a baseline structure for CCM relationships—for example, X control is supposed to work for Y objective—which may make configurations easier.

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Step 3: Set up automated tests

Automated tests are the essence of continuous controls monitoring, and you can start implementing them after mapping out your critical controls and objectives. Such tests are typically conducted in the pass/fail format and serve a simple but important purpose—outlining what happens if a control objective isn’t met.

‍You can carry out various types of tests, such as:

• Asset management queries
• Security posture checks
• Policy adoption status
• Onboarding/offboarding task progress
• Security setting configuration checks
• Observational tests

‍The specific tests you’ll implement mainly depend on your processes and controls. For example, cybersecurity controls can be tested using asset management queries. If one of your controls is to ensure all assets are protected by encryption, you can use queries to get the percentage of protected assets within a given time frame.

‍Testing frequency is a crucial consideration when setting up automated tests. Remember that continuous compliance and security are among the key purposes of CCM, so your test should run frequently, preferably at hourly intervals, to serve your GRC program needs.

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Step 4: Ensure adequate monitoring and reporting

The final step of CCM implementation is to track your control performance. You’ll do this through key risk indicators (KRIs) and other metrics, which should alert you of any control deficiencies and help you take timely corrective action.

‍When defining KRIs, make sure they meet the following criteria:

• Alignment with controls and objectives
• Specificity and focus on a clear signal
• Sensitivity and timeliness that enable early warning signals
• Quantifiability to ensure precision

‍After outlining KRIs, set up a system for managing alerts and addressing control weaknesses. Brainstorm remediation plans beforehand—or leverage those provided to you by your CCM tool—so that you can react proactively to any potential deficiencies uncovered.

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Prerequisites for implementing a CCM system

The first prerequisite for implementing a CCM system is a centralized hub for managing data, documents, and controls. Access to control and compliance reports is an added benefit, as it further reduces the amount of time spent interpreting data generated from scattered controls.

‍Additionally, see that your system allows for high-frequency checks—risk experts consider hourly tests to be the most aligned with CCM best practices.

‍The most obvious requirement for implementing a CCM system is having a capable automation-enabled GRC solution. Depending on your workflow specifics, you can use one or more platforms to automate data imports, control tests, and report generation and connect everything into one cohesive system.

‍Ideally, CCM-friendly tools should support control monitoring across security frameworks and business domains. It also needs to integrate seamlessly with your existing system to present a holistic view of your GRC posture.