How Do You Build a Cyber GRC Operating Model That Actually Works?

A Cyber GRC operating model defines how an organization actually governs, manages and operates cybersecurity risk, governance and compliance across the business.

It answers practical questions that frameworks and policies alone do not answer: Who owns the program? Who owns cyber risk? Who operates controls? How are decisions made? How do requirements become work? Where does evidence come from? How are issues escalated? What does leadership need to know?

Without a clear operating model, organizations can have strong people, good technology, multiple frameworks and extensive documentation while still struggling to operate cybersecurity and GRC as one coherent program.

Hotman Group helps organizations design, build, implement and mature Cyber GRC operating models that connect cybersecurity strategy, governance, risk, requirements, controls, ownership, processes, evidence, technology and assurance.

The objective is not to create more governance. It is to make the cybersecurity program work.

What Is a Cyber GRC Operating Model?

A Cyber GRC operating model describes how the cybersecurity and GRC program functions in practice.

It defines how people, responsibilities, processes, controls, risk, requirements, technology and information work together.

A useful operating model should establish:

• Program accountability.
• Cyber risk ownership.
• Control ownership.
• Roles and responsibilities.
• Decision rights.
• Governance and oversight.
• How cybersecurity requirements are evaluated.
• How controls are designed and maintained.
• How evidence is generated and managed.
• How issues and remediation are managed.
• How GRC technology supports the program.
• How cybersecurity information reaches leadership.
• How the program changes as the organization changes.

The operating model turns cybersecurity and GRC from a collection of activities into a repeatable organizational capability.

Why Do Organizations Need a Cyber GRC Operating Model?

Cybersecurity crosses organizational boundaries.

IT may operate technical controls.

Human resources may operate personnel-related controls.

Legal may manage contractual and regulatory requirements.

Procurement may participate in third-party risk.

Finance may operate controls relevant to financial systems.

Privacy may have overlapping requirements.

Business leaders own risks created by business decisions.

Cybersecurity and GRC teams may coordinate, advise, assess and monitor many of these activities without directly operating all of them.

Without an operating model connecting these responsibilities, work becomes fragmented and accountability becomes unclear.

How Do We Know Our Cyber GRC Operating Model Is Not Working?

Common signs include:

• No one can clearly explain who owns the cybersecurity program.
• Cyber risk is treated as something the cybersecurity team owns alone.
• Control ownership changes depending on who is asking.
• Different frameworks have different owners for the same underlying security activity.
• Policies assign responsibilities that do not match actual operations.
• Audit preparation depends on chasing people for evidence.
• Cybersecurity findings remain open because remediation ownership is unclear.
• GRC technology contains data that does not reflect how the program actually operates.
• Different teams maintain separate risk, control or compliance information.
• Leadership receives compliance status but little useful information about cyber risk.
• New requirements are added without evaluating how they fit the existing program.
• The program depends heavily on institutional knowledge held by a few people.
• Cybersecurity work is consistently reactive.

If several of these are present, the problem may not be a particular framework, audit or tool. The operating model itself may need attention.

See how to fix a fragmented cybersecurity and GRC program.

Should Cybersecurity and GRC Be Centralized?

Not completely.

Governance and coordination may benefit from clear central accountability, but cybersecurity controls are naturally distributed throughout the organization.

The cybersecurity team should not perform every cybersecurity-related activity simply because the activity supports a security requirement.

For example, human resources may own employee onboarding and termination processes. IT may provision and remove access. Procurement may own parts of vendor onboarding. Business leaders may accept risks within their authority.

A strong operating model distinguishes between centralized governance and distributed execution.

The goal is not to put everything under GRC. It is to make sure distributed responsibilities operate as one program.

Who Should Own the Cybersecurity Program?

The organization should establish clear accountability for the overall cybersecurity program.

The appropriate role depends on the organization's structure, size, risk and available leadership.

That accountability may sit with a CISO, security leader, technology executive or another appropriately empowered leader.

Smaller or developing organizations may use fractional leadership while internal ownership matures.

What matters is that someone has sufficient authority, visibility and responsibility to coordinate the program and escalate issues.

If the organization is uncertain about the leadership model, see whether a vCISO, vGRC, Cyber GRC consultant or full-time hire is appropriate.

Who Should Own Cyber Risk?

Cybersecurity professionals help identify, assess, communicate and manage cyber risk, but they should not automatically own every business risk created by cybersecurity conditions.

Risk ownership should generally sit with people who have authority over the business objectives, processes, systems or decisions affected by the risk.

Cybersecurity can advise the risk owner, recommend treatment, monitor the risk and provide information for decision-making.

But accepting a material business risk should not become the responsibility of an analyst simply because the risk is cyber-related.

See who should own cyber risk in an organization.

Who Should Own Cybersecurity Controls?

Control ownership should reflect who has the authority and responsibility to ensure the control operates effectively.

That person may not be in cybersecurity.

For example, controls may be owned or operated by IT, human resources, procurement, legal, finance, privacy, facilities or individual business functions.

The Cyber GRC function can establish expectations, coordinate control activities, maintain the control environment and monitor performance without pretending it operates every control.

See how to establish clear cybersecurity control ownership.

What Is the Difference Between Accountability and Control Operation?

These responsibilities should not be confused.

A control owner may be accountable for ensuring a control works.

Another person or team may perform the actual activity.

Cyber GRC may monitor the control.

An auditor or assessor may independently test it.

Leadership may receive information about its effectiveness.

Separating these roles helps prevent situations in which everyone participates in a process but no one is clearly accountable for the outcome.

How Should Cybersecurity Requirements Enter the Operating Model?

New requirements should enter through a defined process rather than automatically becoming separate compliance projects.

The organization should determine:

• Why the requirement applies.
• What is in scope.
• What existing controls already support it.
• What genuinely new work is required.
• Who should own that work.
• What evidence will demonstrate performance.
• How the requirement affects risk.
• Whether technology or reporting needs to change.

This prevents every new customer, contract or framework from creating another silo.

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

How Should Multiple Frameworks Fit Into the Operating Model?

Frameworks should connect to the cybersecurity program rather than operate as independent programs wherever possible.

The organization can identify common security objectives, rationalize controls and map multiple requirements to the same organizational controls where appropriate.

Unique requirements remain visible, but common activities do not need to be recreated unnecessarily.

See how to build one cybersecurity program across multiple frameworks, how to reduce duplicate cybersecurity and compliance work, and whether a common control framework makes sense.

How Should Cyber Risk Management Fit Into the Operating Model?

Risk management should connect cybersecurity activity to business decisions.

The operating model should define how risks are identified, assessed, documented, prioritized, treated, accepted, monitored and escalated.

It should also define who can accept risk and what information that person needs to make the decision.

Risk should not exist as a spreadsheet updated only before an audit.

It should help determine where the organization directs attention and resources.

See what a cybersecurity risk assessment should actually tell leadership and how to build a cyber risk register leadership can use.

How Should Remediation Work in a Cyber GRC Operating Model?

Findings need clear ownership, prioritization, due dates, decision processes and closure criteria.

Not every finding has the same risk or urgency.

The operating model should establish how findings from assessments, audits, vulnerabilities, incidents, risk assessments and other sources are evaluated together.

It should also prevent remediation from becoming a collection of disconnected spreadsheets maintained by different teams.

See who can help remediate cybersecurity findings and what should happen after a cybersecurity assessment.

How Should Cybersecurity Evidence Fit Into the Operating Model?

Evidence should be a product of operating controls, not an activity invented immediately before an audit.

The operating model should define:

• What evidence demonstrates each control is operating.
• Who produces it.
• How frequently it is generated.
• Where it is maintained.
• Who reviews it.
• Which requirements it can support.
• How long it should be retained.

This can reduce repeated evidence collection and make assessments more predictable.

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

What Role Should GRC Technology Play?

GRC technology should support the operating model, not define it.

A platform can help manage requirements, controls, risks, evidence, findings, workflows, policies, vendors and reporting.

But software cannot independently determine who should own a risk, how governance should work or whether two controls should be consolidated.

Those are program-design decisions.

Organizations should determine whether they actually need a GRC platform before selecting one.

When technology is appropriate, see how to choose the right GRC platform and how to implement a GRC platform effectively.

What If Our Existing GRC Platform Is Driving the Process?

That can be a warning sign.

Technology naturally imposes workflows, data structures and terminology. If the organization allows those defaults to define the operating model, the program may end up organized around what the software does easily rather than what the business needs.

The platform should be configured to support the program where practical.

If the existing implementation has become a problem, see what to do when a GRC platform is not working.

How Should Cyber GRC Work With IT and Security Operations?

Cyber GRC and technical security should be connected without being confused.

Technical teams may operate controls involving identity, endpoints, networks, cloud environments, vulnerabilities, logging, configuration and incident response.

Cyber GRC helps connect those activities to risk, governance, requirements, control expectations, evidence and assurance.

Neither function should operate as though the other is merely providing information for an audit.

The operating model should establish how technical security information becomes useful risk and assurance information and how GRC requirements translate into practical security activities.

How Should Cyber GRC Work With the Rest of the Business?

Cybersecurity is not solely a cybersecurity-department responsibility.

The operating model should identify where business functions participate and make those responsibilities explicit.

This may include:

• Human resources.
• Legal.
• Privacy.
• Procurement.
• Finance.
• Facilities.
• Internal audit.
• Technology teams.
• Product teams.
• Business leadership.

Cyber GRC should provide enough structure for these groups to understand what is expected without turning every employee into a compliance specialist.

How Should Leadership Participate in the Operating Model?

Leadership should receive information that supports decisions, not simply large volumes of cybersecurity data.

The operating model should define what gets escalated, who receives it, how frequently leadership reviews cyber risk and what decisions require executive involvement.

Useful reporting may include material risks, significant control issues, remediation status, emerging requirements, major program dependencies and decisions requiring leadership action.

See how to explain cyber risk to executives and the board.

Does a Cyber GRC Operating Model Need Committees?

Not necessarily.

Governance should be appropriate to the organization.

A large organization may need formal committees, defined charters and multiple levels of oversight.

A smaller organization may need a much simpler structure.

The question is whether the organization has reliable mechanisms for making decisions, assigning accountability, escalating issues and maintaining visibility.

Adding meetings does not automatically improve governance.

How Do We Avoid Creating Too Much Governance?

Every governance activity should have a purpose.

Committees, approvals, reports, workflows and documentation should support decisions, accountability, risk management or assurance.

If an activity exists only because "GRC requires it" and no one can explain the value, it should be reconsidered.

A mature operating model does not necessarily have more process. It has the right process.

Can Automation Improve the Cyber GRC Operating Model?

Yes, after the process is understood.

Automation can help with evidence collection, notifications, workflow routing, control monitoring, assessments and reporting.

But automating an unnecessary or poorly designed process does not make the program mature.

See how to automate compliance without automating bad processes.

What If the Cybersecurity and GRC Team Is Overwhelmed?

An overwhelmed team can indicate a capacity problem, but it can also indicate an operating-model problem.

The team may be performing work that belongs elsewhere, maintaining duplicate frameworks, manually collecting evidence or operating inefficient processes.

Redesigning responsibilities and processes may reduce workload before additional resources are added.

If capacity is still insufficient, the organization can then make a more informed sourcing decision.

See what cybersecurity and GRC work should be outsourced.

How Does the Operating Model Change as a Company Grows?

It should evolve with the organization.

Informal processes that work in a smaller company may become unreliable as the organization adds employees, systems, business units, locations, customers, frameworks and technologies.

Governance may need to become more formal.

Ownership may need to become more explicit.

Risk management may need to support more complex decisions.

Technology may become necessary to manage scale.

The resource model may need to change.

See what to do when a company has outgrown its cybersecurity program.

How Do We Build a Cyber GRC Operating Model?

Start with the current environment rather than an idealized organizational chart.

Understand:

• Business objectives.
• Cybersecurity risks.
• Applicable requirements.
• Existing governance.
• Current roles and responsibilities.
• Controls and control owners.
• Risk owners.
• Current processes.
• Evidence practices.
• Technology.
• Assessments and assurance.
• Leadership reporting.
• Resource constraints.
• Known pain points.

Then design the future model around what the organization actually needs.

Define accountability, decision rights, processes, ownership, information flows and technology support.

Implement the model in a practical sequence rather than attempting to redesign everything at once.

How Do We Know Whether the New Operating Model Is Working?

The program should become easier to understand and operate.

Ownership should be clearer.

Leadership should receive more useful risk information.

Frameworks should create less duplicate work.

Evidence should be easier to obtain.

Remediation should have clear accountability.

New requirements should integrate into the existing program more predictably.

Technology should support rather than dictate the work.

Audits should create fewer surprises.

And the cybersecurity program should be better able to adapt as the business changes.

How Does Hotman Group Help Organizations Build Cyber GRC Operating Models?

Hotman Group helps organizations understand how cybersecurity and GRC currently operate, identify where responsibilities, processes, controls, risk, requirements and technology are disconnected, and design a practical operating model around the organization.

The work may include cybersecurity governance, program design, risk management, control ownership, framework rationalization, common controls, evidence strategy, remediation processes, GRC technology, leadership reporting and resource-model design.

HG can help design the model, implement it and provide ongoing vCISO, vGRC or Cyber GRC support where additional expertise or operating capacity is needed.

The objective is not a theoretical governance structure.

The objective is a cybersecurity and Cyber GRC program that people can actually operate and leadership can actually use.

What If We Know Our Cyber GRC Program Is Not Working but Do Not Know Whether the Operating Model Is the Problem?

You do not need to diagnose the solution before asking for help.

The underlying problem may involve governance, ownership, frameworks, controls, risk, technology, resources or several of these at once.

If the organization knows something needs to change but cannot identify exactly what kind of intervention is needed, 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.