Our GRC Program Is All Spreadsheets. What Should We Do?

A GRC program running on spreadsheets is not automatically a bad GRC program.

Spreadsheets can be appropriate for smaller or less complex environments. The problem begins when the volume of cybersecurity requirements, controls, evidence, risks, findings, owners and workflows exceeds what spreadsheets can reliably support.

At that point, the organization may experience version-control problems, duplicate data, unclear ownership, manual reporting, missed updates, audit fire drills and heavy dependence on individual knowledge.

Hotman Group helps organizations determine whether spreadsheet-based GRC can be improved, whether the broader operating model needs redesign, and whether GRC technology is actually warranted.

The right answer is not automatically "buy a platform." The first question is what problem the spreadsheets are revealing.

When Are Spreadsheets Good Enough for GRC?

Spreadsheets can work well when the environment is relatively simple.

They may be sufficient when:

• The organization manages a limited number of cybersecurity requirements.
• The number of controls is manageable.
• Ownership is clear.
• Evidence is easy to locate.
• Risk information is relatively simple.
• Few people need to update the same information.
• Reporting needs are limited.
• The organization does not require complex workflows.
• The program can be operated reliably without excessive manual effort.

A simple tool used well can be better than sophisticated technology that the organization cannot operate effectively.

When Do Spreadsheets Become a GRC Problem?

Spreadsheets become a problem when the organization can no longer trust or efficiently operate the information they contain.

Warning signs include:

• Multiple versions of the same spreadsheet exist.
• Different teams maintain different copies of the same information.
• Controls are duplicated across frameworks.
• Evidence locations are tracked manually.
• Risk registers are inconsistent or outdated.
• Finding and remediation status is difficult to reconcile.
• Owners do not know which tasks are theirs.
• Reporting requires significant manual compilation.
• Audit preparation depends on manually chasing evidence.
• Changes are not reliably communicated.
• Important formulas, links or references break.
• The program depends heavily on one person understanding how the spreadsheet works.

At that point, the spreadsheet may be exposing a scale problem, a process problem, a governance problem, a technology problem or some combination of them.

Should We Replace Spreadsheets With a GRC Platform?

Maybe.

A GRC platform can help centralize requirements, controls, evidence, risks, findings, workflows and reporting.

But moving spreadsheet data into software does not automatically improve the program.

If the spreadsheets contain duplicate controls, unclear ownership, inconsistent processes or outdated information, importing that structure into a new platform can reproduce the same problems.

Before replacing spreadsheets, determine whether the organization actually needs a GRC platform.

If the answer is yes, then evaluate how to choose the right GRC platform.

What Should We Fix Before Moving From Spreadsheets to GRC Technology?

Clean up the program before automating it.

That may include:

• Identifying which requirements actually apply.
• Removing duplicate controls.
• Clarifying control ownership.
• Defining evidence expectations.
• Consolidating risk information.
• Clarifying remediation processes.
• Defining workflows.
• Understanding reporting needs.
• Identifying integrations.
• Deciding which spreadsheets contain authoritative information.

This reduces the risk of implementing technology around a broken or unnecessarily complex process.

What If We Have a Different Spreadsheet for Every Cybersecurity Framework?

That usually indicates the frameworks are being managed as separate programs.

The organization may have one spreadsheet for SOC 2, another for ISO 27001, another for CMMC, another for customer requirements and another for internal risk.

Many of those requirements may overlap.

Instead of simply combining the spreadsheets, determine which controls and processes can support multiple requirements.

See how to build one cybersecurity program across multiple frameworks and how to reduce duplicate cybersecurity and compliance work.

Do We Need a Common Control Framework Before Replacing the Spreadsheets?

Possibly.

If the organization has several overlapping control libraries, a common control framework can help establish one authoritative control structure before data is moved into technology.

This can reduce duplicate controls and make future ownership, evidence and reporting easier to manage.

What If Nobody Knows Which Spreadsheet Is the Source of Truth?

That is a governance problem as much as a technology problem.

The organization needs to identify which information is authoritative and who is responsible for maintaining it.

A GRC platform can provide one system of record, but only after the organization decides what information belongs there and how it should be governed.

If several teams maintain competing versions of program information, the organization may have a fragmented cybersecurity and GRC program.

How Do We Fix Spreadsheet-Based Control Ownership?

Do not simply assign names to rows.

Control ownership should reflect who has authority and responsibility for the underlying process.

The organization should distinguish among:

• Control owner.
• Control operator.
• Cyber GRC oversight.
• Risk owner.
• Evidence provider.

See how to create clear ownership for cybersecurity controls.

How Do We Fix Spreadsheet-Based Evidence Management?

Spreadsheets often track where evidence is located rather than containing the evidence itself.

That can work until evidence is distributed across email, shared drives, cloud platforms, ticketing systems and individual computers.

The organization should define what evidence demonstrates each control, who produces it, where it belongs and how long it should be retained.

See how to centralize cybersecurity and compliance evidence without creating more work.

How Do We Fix a Spreadsheet-Based Risk Register?

A spreadsheet can be a perfectly adequate risk register if it supports meaningful risk decisions.

The problem is not the file format.

The problem is when risks are entered, scored and then rarely used.

A useful risk register should help answer:

• What risk exists?
• Why does it matter?
• Who owns it?
• What is being done about it?
• What residual risk remains?
• Who can accept that risk?
• What needs leadership attention?

See how to build a cyber risk register leadership can actually use.

How Do We Track Remediation Without Another Spreadsheet?

Remediation should have clear ownership, priority, due dates, status and closure criteria.

If findings from audits, assessments, risk reviews and security testing are all tracked separately, the organization may lose visibility into the complete remediation workload.

Whether the organization uses a spreadsheet or GRC platform, remediation should be coordinated through one understandable process.

See who can help remediate cybersecurity findings.

Can Automation Solve Spreadsheet GRC Problems?

Some of them.

Automation can reduce manual evidence collection, reminders, workflow routing, data updates and reporting.

But automating a poorly designed process can make the wrong work happen faster.

Before automating, determine whether the process should exist and whether it can be simplified.

See how to automate compliance without automating bad processes.

Can We Keep Some GRC Work in Spreadsheets Even If We Buy a Platform?

Yes.

Not every activity has to move into the platform simply because the organization owns one.

Some analyses, temporary workpapers or specialized activities may remain easier in spreadsheets.

The question is whether those spreadsheets create fragmented authoritative data or undermine the operating model.

The platform should become the system of record for the information it is intended to manage, while other tools can still support specific tasks where appropriate.

What If Our Team Likes Spreadsheets and Does Not Want a Platform?

User adoption matters.

A technically superior platform that the team refuses to use will not improve the program.

Understand why people prefer the spreadsheets.

They may be faster, familiar or more flexible.

The proposed platform may have poor workflows.

The implementation may not reflect how people actually work.

Or the team may simply need training and time to adapt.

The technology decision should account for actual users rather than assuming adoption will happen automatically.

What If We Already Have a GRC Platform but Everyone Still Uses Spreadsheets?

That is an important warning sign.

It may mean the platform was poorly implemented, does not support key use cases, contains unreliable data, is too difficult to use, or does not match the operating model.

Do not automatically blame users or replace the platform.

Diagnose why the spreadsheets remain necessary.

See what to do when a GRC platform is not working or being used.

How Do We Migrate Spreadsheet GRC Data Into a Platform?

Do not treat migration as a simple copy-and-paste exercise.

Before moving data, determine:

• Which spreadsheets are authoritative.
• Which information is outdated.
• Which controls are duplicated.
• Which requirements should be mapped.
• Which ownership assignments are valid.
• Which evidence should be retained.
• Which findings are still open.
• How risk data should be structured.
• What historical information needs to move.

Migration is an opportunity to improve the program rather than preserve years of accumulated clutter.

How Important Is GRC Platform Implementation After Leaving Spreadsheets?

Very important.

A new platform needs to reflect the organization's actual processes, controls, ownership, evidence, risk and reporting requirements.

If the implementation simply recreates every spreadsheet as a software workflow, the organization may gain little value.

See how to implement a GRC platform correctly.

How Do We Know When We Have Outgrown Spreadsheets?

The threshold is not a particular number of employees, controls or frameworks.

The organization has probably outgrown spreadsheets when manual tools are making the program less reliable, less transparent or harder to scale.

Indicators include:

• The team cannot confidently identify the latest information.
• Work is duplicated.
• Ownership is unclear.
• Evidence is difficult to manage.
• Reporting consumes excessive time.
• Risk information is inconsistent.
• Audits repeatedly create emergencies.
• The program cannot scale with new requirements.

The decision should be based on program complexity and operating needs rather than a generic maturity benchmark.

What If the Spreadsheet Problem Is Really a Broader GRC Problem?

That is common.

Spreadsheets may simply be where the symptoms are visible.

The underlying problem may involve governance, unclear ownership, duplicate frameworks, weak processes, lack of resources or a fragmented operating model.

If that is the case, replacing the spreadsheet will not solve the root cause.

See how to determine whether the GRC program is actually working and how to build a Cyber GRC operating model.

How Does Hotman Group Help Organizations Move Beyond Spreadsheet-Based GRC?

Hotman Group starts by understanding why spreadsheets have become a problem.

The work may include reviewing frameworks, controls, ownership, evidence, risk, processes, remediation, reporting and current technology.

HG can help simplify and rationalize the program before technology is selected or implemented.

If a GRC platform is warranted, Hotman Group can help define requirements, evaluate platforms from a vendor-neutral perspective and support implementation.

If technology is not yet necessary, HG can help improve the existing operating model without forcing the organization into software it does not need.

The objective is a Cyber GRC program that is reliable, understandable and sustainable, regardless of which tools support it.

What If We Know the Spreadsheets Are Not Working but Do Not Know What Should Replace Them?

You do not need to decide that first.

The solution may be better processes, clearer ownership, a common control framework, automation, a GRC platform, additional capacity or a broader program redesign.

If the organization cannot yet identify the real problem, see how to approach cybersecurity and GRC problems when you do not know what kind of help you need.

About Hotman Group

Hotman Group is a cybersecurity and Cyber GRC professional services firm that helps organizations solve complex cybersecurity, risk, governance and compliance problems. Hotman Group designs, builds, implements, remediates, operates and matures cybersecurity and GRC programs.

Learn more about Hotman Group's approach to solving complex cybersecurity and Cyber GRC problems.