What Is a Common Control Framework and Do We Need One?

A common control framework is a structured set of cybersecurity controls that an organization uses to support multiple frameworks, regulations, contractual requirements and customer expectations through one coordinated control environment.

Instead of maintaining a separate control set for every framework, the organization defines the cybersecurity controls it actually operates and maps multiple requirements to those controls where the underlying security objective aligns.

Hotman Group helps organizations determine whether a common control framework will actually reduce complexity, then design, rationalize and implement the control structure around the organization's real cybersecurity risks, requirements, processes and operating model.

A common control framework can be valuable, but it is not automatically the right answer. If poorly designed, it can become another layer of documentation rather than simplifying the program.

Why Do Organizations Build Common Control Frameworks?

Organizations usually consider a common control framework after cybersecurity and compliance requirements begin to accumulate.

One framework may be introduced because of a customer.

Another may support a business objective.

A contract may add a new requirement.

A regulator may introduce additional obligations.

Different teams may implement each requirement independently.

Over time, the organization can end up maintaining several versions of similar controls, collecting the same evidence repeatedly and assigning different owners to essentially the same cybersecurity practices.

A common control framework can create one authoritative control structure underneath those requirements.

How Does a Common Control Framework Work?

The organization defines its own cybersecurity controls based on the practices it actually needs to operate.

Then applicable framework and regulatory requirements are mapped to those controls.

For example, one organizational access review control may support requirements from several cybersecurity frameworks.

The organization operates the access review once according to a defined process, maintains the appropriate evidence and maps the applicable requirements to that control.

That is different from creating a separate access review control for every framework.

Is a Common Control Framework the Same as Framework Mapping?

No.

Framework mapping identifies similarities and differences among requirements.

A common control framework creates an organizational control structure that those requirements can map into.

Mapping tells the organization that requirements are related.

The common control framework defines how the organization will actually operate cybersecurity controls to address those requirements.

Is a Common Control Framework the Same as Control Rationalization?

They are closely related.

Control rationalization identifies redundant or overlapping controls and determines whether they can be consolidated.

A common control framework is often the structure that results from that work.

The organization may begin with hundreds of framework-specific controls and end with a smaller set of authoritative organizational controls that support multiple requirements.

The objective is not simply fewer controls. The objective is a control environment that is clearer, easier to own, easier to evidence and more representative of how cybersecurity actually operates.

When Does an Organization Need a Common Control Framework?

A common control framework becomes more useful when an organization manages enough overlapping requirements that separate control sets are creating significant complexity.

Signs that it may be worth considering include:

• Several cybersecurity frameworks are managed simultaneously.
• The organization maintains different control libraries for different frameworks.
• The same evidence is repeatedly collected for multiple assessments.
• Different teams own different versions of similar controls.
• Policies and procedures are duplicated across compliance programs.
• GRC technology contains redundant controls.
• New frameworks are difficult to integrate into the existing program.
• Leadership cannot easily understand the overall control environment.
• Audit and assessment work consumes increasing amounts of time.
• The organization wants a more scalable Cyber GRC operating model.

When Does an Organization Not Need a Common Control Framework?

Not every organization needs one.

If the organization manages only one or two relatively simple sets of requirements, a formal common control framework may add more structure than value.

Likewise, if the real problem is unclear ownership, poor processes or weak control operation, creating a control framework does not automatically solve those issues.

The organization should understand the problem first.

If requirements are only one symptom of a broader issue, see how to fix a fragmented cybersecurity and GRC program.

What Should a Common Control Framework Be Based On?

It should be based on the organization, not simply copied from one external framework.

The control structure should consider:

• Cybersecurity risks.
• Business objectives.
• Applicable frameworks and regulations.
• Contractual and customer requirements.
• Existing cybersecurity practices.
• Technology environment.
• Organizational structure.
• Control ownership.
• Evidence requirements.
• Available resources.
• How the program will actually operate.

A useful common control framework translates many external requirements into a control environment the organization can understand and operate.

Should We Use One Existing Framework as the Common Control Framework?

Sometimes an existing framework can serve as a strong foundation, but the choice should be intentional.

An organization may select a framework because it aligns well with its risk model, customers, industry or operating environment.

Other requirements can then be mapped to it.

But the organization should not force every requirement into one framework if important obligations do not fit cleanly.

In many cases, the better approach is an organizational control framework informed by several external frameworks rather than treating one of them as universally authoritative.

How Do We Decide Which Controls Belong in the Common Control Framework?

Start with the cybersecurity practices the organization actually needs to operate.

Then evaluate the applicable requirements.

Controls should be designed to address cybersecurity objectives such as:

• Access management.
• Identity and authentication.
• Asset management.
• Configuration management.
• Vulnerability management.
• Logging and monitoring.
• Incident response.
• Risk management.
• Third-party risk management.
• Security awareness.
• Data protection.
• Change management.
• Business continuity.
• Governance and policy management.

Framework requirements can then be mapped to those organizational controls.

How Do We Avoid Making the Common Control Framework Too Complicated?

Design it around usability.

A control framework becomes difficult to operate when it contains excessive detail, duplicate controls, overly technical language or a structure that makes sense only to compliance specialists.

Controls should be clear enough that owners understand what they are responsible for and what successful operation looks like.

Where details vary by system, business unit or requirement, those differences can often be handled through procedures, implementation statements or scoped evidence rather than creating an entirely new control.

How Does a Common Control Framework Reduce Duplicate Work?

It creates one authoritative control environment.

Instead of maintaining several versions of the same cybersecurity practice, the organization operates one control and maps multiple requirements to it where appropriate.

This can reduce:

• Duplicate control documentation.
• Repeated evidence collection.
• Duplicate testing.
• Inconsistent ownership.
• Policy duplication.
• Framework-specific spreadsheets.
• Conflicting control language.

See how to reduce duplicate work across cybersecurity frameworks.

How Does a Common Control Framework Help With Evidence?

When several framework requirements map to one control, the evidence for that control may support several obligations.

The organization can define what evidence proves the control is operating and maintain that evidence in a consistent location or process.

This can reduce the need to repeatedly recreate or recollect the same information.

See how to centralize cybersecurity evidence without creating more work.

How Does a Common Control Framework Help With Control Ownership?

One authoritative control should have clear ownership regardless of how many frameworks reference it.

The control owner understands the process, maintains the control, coordinates evidence and participates in remediation when necessary.

This is more sustainable than assigning different people to different framework-specific versions of the same underlying security activity.

See how to create clear ownership for cybersecurity controls.

Can a Common Control Framework Help With Audit Readiness?

Yes.

If controls operate continuously and evidence is maintained consistently, audit preparation becomes less dependent on recreating information for each assessment.

The organization can understand which controls support which requirements and retrieve evidence from the operating program.

This can make audits more predictable and reduce last-minute activity.

See how to prepare for cybersecurity audits without constant fire drills.

Can a Common Control Framework Help Maintain Compliance After Certification?

Yes.

A common control framework can help shift compliance from individual certification projects to continuous program operation.

Controls remain active after the assessment.

Evidence continues to be generated.

Changes to requirements can be evaluated against the existing control structure.

New frameworks can be incorporated without rebuilding the program from scratch.

See how to maintain cybersecurity compliance after certification.

Can a Common Control Framework Support Multiple Cybersecurity Frameworks?

That is one of its primary purposes.

Organizations can map requirements from multiple frameworks to the same underlying organizational controls where those requirements align.

This allows the cybersecurity program to support multiple external obligations without operating several independent programs.

See how to build one cybersecurity program across multiple frameworks.

How Do We Add a New Framework to an Existing Common Control Framework?

Map the new requirements to the existing organizational controls first.

Identify:

• Requirements already satisfied.
• Controls that need modification.
• Evidence that can be reused.
• New scope considerations.
• Genuinely new requirements.

Create new controls only where the existing control environment does not adequately address the requirement.

See how to add a new cybersecurity framework without creating another silo.

Can a Common Control Framework Help With CMMC?

Potentially.

Organizations pursuing CMMC may already operate security controls that support NIST SP 800-171 requirements.

An existing common control structure can help identify those areas of reuse.

But CMMC has specific scoping, implementation and assessment considerations that still need to be addressed.

Organizations pursuing CMMC can review where to start with CMMC Level 2, what is actually in scope for CMMC, and whether existing security controls can be reused for CMMC.

Can a Common Control Framework Help With SOC 2 and ISO 27001?

Yes.

Organizations can often reuse significant portions of their existing control environment across SOC 2 and ISO 27001.

The two have different structures and assurance models, so the organization still needs to understand their unique requirements.

But policies, risk processes, access controls, incident response, vulnerability management and many other underlying practices may support both.

See how much work ISO 27001 may require after SOC 2.

Should a Common Control Framework Live in a GRC Platform?

It can, but the control structure should not be designed around software limitations.

A GRC platform can help manage control mappings, evidence, ownership, testing, issues and reporting.

But the organization should define the control model first and then determine how technology should support it.

See whether the organization needs a GRC platform and how to choose the right GRC platform.

What If Our Existing GRC Platform Has a Messy Control Library?

Do not assume the platform needs to be replaced.

The organization may need to rationalize the controls, identify the authoritative control set, clean up mappings and clarify ownership.

The technology may still be appropriate once the underlying control model is redesigned.

See what to do when a GRC platform is not working as expected.

How Does a Common Control Framework Fit Into the Cyber GRC Operating Model?

The common control framework is one part of the operating model.

Governance defines how controls are created and changed.

Control owners operate them.

Risk helps prioritize them.

Evidence demonstrates performance.

Technology supports management and reporting.

Assessments and audits provide assurance.

Without an operating model around it, the common control framework can become another static library of documentation.

See how to build a Cyber GRC operating model.

How Does Hotman Group Help Organizations Build Common Control Frameworks?

Hotman Group helps organizations determine whether a common control framework is actually appropriate for the complexity of their environment.

When it is, HG can help inventory existing requirements and controls, identify overlaps, rationalize controls, design the common control structure, establish ownership, map framework requirements, define evidence expectations and connect the framework to GRC technology and ongoing program operations.

The work is based on the organization's cybersecurity practices and risk environment rather than simply copying a control library from one framework.

The objective is a control structure that reduces unnecessary complexity while supporting cybersecurity, risk management and compliance.

What If We Know We Have Duplicate Controls but Do Not Know Whether We Need a Common Control Framework?

You do not need to choose the solution before diagnosing the problem.

The organization may need a common control framework, basic control rationalization, better governance, technology cleanup or a broader Cyber GRC redesign.

If the environment is difficult to untangle, 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.