Our Company Has Outgrown Its Cybersecurity Program. What Do We Do?

A cybersecurity program that worked for an organization several years ago may no longer fit the organization it has become.

Companies grow. They add employees, customers, systems, vendors, locations, products and data. They enter new markets, make acquisitions, change technology, introduce artificial intelligence, take on new contracts and accumulate additional cybersecurity and compliance requirements.

The cybersecurity program does not always evolve at the same pace.

When that happens, the problem is not necessarily that the original program was poorly designed. The organization may simply have outgrown it.

Hotman Group helps organizations evaluate what their cybersecurity and Cyber GRC programs need to become as the business, risk environment, technology and requirements change. HG can help redesign, build, implement, remediate, operate and mature cybersecurity and GRC programs rather than simply adding another requirement or tool to an operating model that no longer fits.

How Do We Know If We Have Outgrown Our Cybersecurity Program?

Organizations do not usually receive a clear notification that their cybersecurity program has become outdated.

The signs tend to appear gradually.

Common indicators include:

• Cybersecurity responsibilities are still structured around an organization much smaller or simpler than the company is today.
• More cybersecurity and compliance work exists than the current team can reasonably perform.
• New requirements are continually added without reconsidering the overall program.
• Different business units have developed their own security or compliance processes.
• The organization has accumulated multiple cybersecurity frameworks that are managed independently.
• Cybersecurity work relies heavily on spreadsheets, email and institutional knowledge.
• Controls exist on paper but ownership or operation is inconsistent.
• Leadership cannot easily understand the organization's most important cyber risks.
• Audit preparation requires significant manual effort every time.
• GRC technology no longer supports the organization's processes or reporting needs.
• The company has expanded into new markets, products, technologies or regulatory environments.
• Customer security expectations have become more demanding.
• Cybersecurity decisions are increasingly reactive.
• The program depends too heavily on a few individuals.
• Policies, processes and controls have accumulated without a deliberate review of whether they still make sense.

One or two of these issues may be isolated problems. Several appearing together can indicate that the organization needs to reconsider the cybersecurity program as a whole.

Why Do Companies Outgrow Their Cybersecurity Programs?

Cybersecurity programs are built for an organization at a particular point in time.

The organization then changes.

Growth creates more users, systems, data, vendors and business processes.

New customers introduce security requirements.

New contracts introduce additional frameworks.

Acquisitions introduce different technologies, controls and ways of working.

New regulations create obligations that did not previously exist.

Cloud adoption changes architecture and responsibility.

Artificial intelligence introduces new use cases, governance questions and risks.

Leadership changes may alter risk tolerance or strategic priorities.

Over time, the cybersecurity program can become a collection of additions made in response to individual events rather than a program intentionally designed for the organization that exists today.

Does Growth Mean We Need More Cybersecurity People?

Not automatically.

Growth may create a genuine need for additional expertise or capacity. But adding people to an inefficient operating model can make an expensive problem larger without fixing it.

Before assuming headcount is the solution, determine why the workload has increased.

The organization may be performing duplicate work across frameworks.

Processes may be unnecessarily manual.

Control ownership may be unclear.

Work may sit with the cybersecurity team even though another business function should operate it.

Technology may be poorly implemented.

Or the organization may genuinely need additional cybersecurity leadership, specialized expertise or operating capacity.

Organizations facing this decision can evaluate whether they need a vCISO, vGRC, Cyber GRC consultant or full-time hire and what cybersecurity and GRC work should be outsourced.

What If Our Cybersecurity Program Has Become Fragmented as We Grew?

This is common.

As organizations grow, responsibilities often spread across cybersecurity, IT, legal, compliance, privacy, finance, human resources and individual business units.

That distribution is not inherently a problem. Cybersecurity is cross-functional and many controls should be operated outside the security team.

The problem occurs when responsibilities spread without governance connecting them.

Different teams may begin maintaining their own processes, controls, evidence and risk information. New frameworks may become separate compliance programs. Technology may be purchased to solve individual problems without considering how it fits the broader program.

The result can be significant cybersecurity activity without a coherent view of the whole.

If that describes the organization, see how to fix a fragmented cybersecurity and GRC program and how to build a Cyber GRC operating model.

Should We Redesign the Cybersecurity Program Around a Framework?

A cybersecurity framework can provide valuable structure, but the organization's program should not exist solely to satisfy a framework.

Start with the organization.

Understand the business, important assets, cybersecurity risks, customers, contractual requirements, regulatory obligations, technologies, operating environment and risk tolerance.

Then determine which frameworks and requirements need to be supported.

A framework can help organize cybersecurity practices and provide a common reference point. But simply implementing another framework does not necessarily address weak governance, unclear ownership, resource constraints or ineffective processes.

If growth has resulted in numerous requirements, the organization may need to build one cybersecurity program across multiple frameworks rather than redesign the program separately around each one.

What If We Have Accumulated Too Many Cybersecurity and Compliance Requirements?

Growth often brings more requirements.

A new customer may require SOC 2.

International expansion may introduce ISO 27001 or additional privacy requirements.

A government contract may introduce CMMC, NIST or other federal requirements.

Healthcare activities may introduce HIPAA requirements.

Payment environments may introduce PCI DSS.

Other customers and contracts may bring their own security expectations.

The organization should not automatically create an independent program for every requirement.

Start by understanding how to prioritize too many cybersecurity and compliance requirements.

Then identify where requirements overlap and where controls, policies, processes and evidence can be reused. This can help reduce duplicate cybersecurity and compliance work.

Do We Need a Common Control Framework as We Grow?

Possibly.

A common control framework can help organizations manage multiple cybersecurity requirements through a shared set of underlying controls.

Instead of maintaining entirely separate control sets for every framework, the organization identifies common security objectives and maps applicable requirements to the controls that satisfy them.

This can improve consistency and reduce unnecessary duplication.

But a common control framework should solve an actual program problem. It should not become another administrative layer that the organization has to maintain.

Organizations with several frameworks should evaluate whether a common control framework makes sense for their environment.

Should We Buy a GRC Platform Because the Company Has Grown?

Growth can make GRC technology more valuable, but company size alone does not determine whether a platform is needed.

The organization should understand what problems it expects the technology to solve.

Those may include managing multiple frameworks, controls, evidence, policies, risks, issues, vendors, assessments, workflows or reporting.

If the organization has not defined its processes, governance, ownership and requirements, implementing software may simply automate an unclear operating model.

Before purchasing technology, determine whether the organization actually needs a GRC platform and how to choose the right GRC platform.

If spreadsheets are becoming unmanageable, see what to do when a GRC program is running on spreadsheets.

What If We Already Bought a GRC Platform and It Is Not Working?

Do not immediately assume the organization needs another platform.

The problem may be the technology.

But it may also involve implementation, workflows, ownership, data structure, control design, governance, training or unrealistic expectations about what the software would accomplish.

Replacing the platform without diagnosing the cause can recreate the same problem with different software.

Start by understanding why the existing GRC platform is not working.

If the technology itself is appropriate but the implementation is not, the organization may need to reconsider how the GRC platform should be implemented.

How Should Cybersecurity Governance Change as a Company Grows?

Governance needs to evolve as cybersecurity decisions become more complex and responsibilities become more distributed.

Smaller organizations may operate effectively through informal communication among a small group of leaders.

As the organization grows, that model becomes harder to sustain.

Governance should establish:

• Who is accountable for the cybersecurity program.
• Who owns cybersecurity risks.
• Who operates individual controls and processes.
• How cybersecurity decisions are made.
• How issues are escalated.
• How risk acceptance works.
• How cybersecurity priorities are established.
• How different business functions participate.
• What information leadership receives.
• How the program adapts when the organization changes.

This does not mean centralizing every cybersecurity activity under one person.

It means creating clear accountability across a program that may be operated by many people.

Organizations struggling with this can examine how to establish clear cybersecurity control ownership and who should own cyber risk.

How Should Cybersecurity Risk Management Change as the Business Grows?

Cybersecurity risk management should mature with the complexity and impact of the business.

Leadership needs to understand which cyber risks could materially affect business objectives, customers, operations, financial performance, reputation and strategic plans.

That requires more than a list of vulnerabilities or compliance findings.

The organization needs a repeatable way to identify, assess, prioritize, treat, accept and monitor cyber risk.

As the organization grows, risk information also needs to become useful to a wider group of decision-makers.

Organizations can evaluate what a cybersecurity risk assessment should actually tell leadership, how to build a cyber risk register leadership can use, and how to explain cyber risk to executives and the board.

What If Our Cybersecurity Strategy No Longer Matches the Business?

Then the strategy should change.

Cybersecurity strategy should support what the organization is trying to accomplish now and where the business is going next.

A strategy designed before major growth, acquisitions, cloud transformation, new markets, new products or major technology changes may no longer address the organization's most important risks.

Cybersecurity priorities should be reconsidered when business objectives and risk materially change.

See how to build a cybersecurity strategy that actually supports the business.

What If a New Customer or Business Opportunity Creates a Cybersecurity Requirement?

This is a common growth trigger.

A new opportunity can introduce cybersecurity requirements the organization has never encountered before.

Before building a new compliance program, determine what the requirement actually means, what is in scope, what existing practices can be reused, what gaps exist and what the business opportunity requires.

See what to do when a customer introduces a new cybersecurity requirement and how to add a new cybersecurity framework without creating another silo.

What If Our Cybersecurity Program Still Passes Audits?

Passing audits does not mean the program still fits the organization.

Audits evaluate defined requirements within a defined scope. They provide useful assurance, but they do not necessarily answer whether the overall cybersecurity program is efficient, integrated, appropriately governed or aligned with current business risk.

An organization can continue passing audits while relying on increasingly manual processes, duplicated controls, key-person knowledge and unsustainable effort.

Organizations should distinguish between satisfying assessment requirements and understanding whether the cybersecurity program itself is healthy.

See whether passing an audit means the organization is actually secure and whether the work is done.

How Do We Redesign a Cybersecurity Program That No Longer Fits?

Do not begin by throwing everything away.

An organization that has outgrown its cybersecurity program usually has valuable controls, processes, technologies, expertise and institutional knowledge already in place.

The objective is to understand what should be retained, what should be improved, what should be consolidated and what no longer makes sense.

A redesign should consider:

• Business objectives and strategy.
• Current and emerging cyber risks.
• Applicable cybersecurity and compliance requirements.
• Existing controls and processes.
• Governance and accountability.
• Control and risk ownership.
• Organizational structure.
• Available expertise and capacity.
• Technology and GRC systems.
• Evidence and assurance practices.
• Leadership reporting.
• Third-party dependencies.
• Customer security expectations.
• Future growth and likely change.

The resulting program should be designed for the organization the business is becoming, not merely patched to preserve the program it used to have.

How Does Hotman Group Help Organizations Modernize and Mature Cybersecurity Programs?

Hotman Group helps organizations determine why their existing cybersecurity and Cyber GRC programs no longer fit and what needs to change.

The work may involve cybersecurity strategy, governance, risk management, program design, framework rationalization, control design, process improvement, remediation, GRC technology, leadership support, program operations or additional expertise and capacity.

HG can help assess the current environment, design the future operating model, implement changes, remediate gaps and help operate and mature the program over time.

The objective is not modernization for its own sake.

The objective is a cybersecurity program that fits the organization's actual business, risks, requirements and resources and can continue adapting as those conditions change.

What If We Know Our Cybersecurity Program Needs to Change but Do Not Know Where to Start?

Start with the problems the organization is experiencing.

You do not need to determine in advance whether the answer is a new strategy, governance model, framework, GRC platform, assessment, remediation project, vCISO, vGRC or additional internal staff.

Determining the right intervention should follow diagnosis.

If the organization knows the program needs help but cannot identify exactly what kind, see how to determine what kind of cybersecurity or GRC help is actually needed.

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.