Compliance as a Service: Counter-counterpoint

Posted February 19th, 2008 - 1 comment

Compliance as a Service – Counter-counterpoint

Matt and Mark have both responded to my response.  Matt writes:

Thanks for keeping us honest Ian! I would be pretty blind to claim that overall regulatory compliance can be solved with any IT solution (…or set of …or service of). But I didn’t make that distinction in my previous post. But, is that the basic point you’re making? …that IT compliance is a subset of overall Compliance? Or is there more to it?

Yes and no.  I do believe the IT compliance is a subset of overall Compliance, but that wasn’t my basic point.  My most basic point was, because Big C Compliance is so truly tied to people and process it cannot be delivered as a service.  The reason I responded to you and Mark about this was that I didn’t want the conversation to start off with a definition of Big C that was too limited and too IT-centric.

Understanding that big-C Compliance requires much more than IT controls, would it seem more realistic if we said IT-compliance-as-a-service? or IT-Audit-as-a-service?

IT audit/compliance can and should be delivered as a service.  And not just the tools and tooling for it, but ownership of the compliance state and risk as well.  To me this is a natural extension to Managed Security Services and companies like Counterpane and IBM offer this to an extent.  Continue reading "Compliance as a Service: Counter-counterpoint"...

February 19th, 2008 | Tags: , , , , | Category: Professional | One comment

Why Compliance Cannot be Delivered as a Service

Posted February 15th, 2008 - 4 comments

My friend Mark MacAuley can always be counted on to stir things up. He’s seen plenty of enterprise deployments and architectures and comes at problems with a combination of Yankee ingenuity and healthy cynicism. Over on Identitystuff, Mark writes about offering Compliance as a service:

The new frontier is CaaS – Compliance as a Service. Fixed cost, consistent automated reporting, a defensible model for implementing and showing transparency.

Although the intent of Compliance is good, in Mark’s estimation Compliance is 100% cost with no positive yield to the bottom line.

The trouble is that Mark refers to Compliance as if it is an IT service that can be delivered like outsourced help desk or security management. Compliance, the Big “C,” cannot be delivered as a service. The Big “C” is the interplay between people, processes, and IT systems to achieve the mission of the business in the context of regulatory and market pressures. It isn’t binary; it isn’t something you have one day and not the next. This dynamic interplay requires continuous measurement and feedback loops to ensure that deviations are corrected and, ideally, prevented.

Compliance is a matter of controls – instituting a variety of controls and then charting the business’ distance in relation to those controls at all times. Let’s take a simple common non-business example. When a cop pulls you over for speeding, you often get asked two questions:  Continue reading "Why Compliance Cannot be Delivered as a Service"...

  1. Did you see that speed limit sign?
  2. Do you know how fast you were going?
February 15th, 2008 | Tags: , , , , , | Category: Professional | 4 comments