190 compliance, risk, and control specialists participated in our class on cyber compliance at the IE Law School. I presented good practices and tips to comply with regulations involving data security, computer crime, corporate defense, IT and compliance controls, and sectorial requirements

1. Master Class
Cyber
compliance
Prof. Hernan Huwyler, MBA CPA

2. IE, top worldwide MBAs

3. Support IT in
embedding
compliance controls
Challenge

4. There is not security
in IT security
Compliant but unprotected
No framework is 100% breach-free
Challenge

5. European
Critical
Infrastructure
Directive
Energy
Transport
New European strategy
Banking
Infrastructure
Digital
Health
Water
Waste
Space
Government
2008
2021

6. 1st Line IT
Process and Contract Mgrs
Governance
2nd Line Compliance
Privacy, risks, info sec
3rd Line IT Audit

7. Implement a mobile
and endpoint device
management
Work-from-Anywhere

8. Enhance
requirements for cloud
and eCommerce
service providers
Cloud and eCommerce

9. Audit internal and 3P
controls against
ransomware and
spearphishing
Privacy enforcement

10. Compliance register
Control matrix
Policies and procedures
IT contracts
End-to-end scope1

11. SANS policy templates
https://www.sans.org/information-
security-policy/
1

12. Create simple policies
to buy software and an
inventory of applications
to prevent shadow IT
Licensing Compliance2

13. Implement a monthly
reconciliation between
the software inventory
and the paid licenses
Licensing Compliance2

14. Implement and train
simple policies to buy
and approve software
by the CISO to prevent
shadow IT
Licensing Compliance2

15. Block accesses to
rogue or risky cloud
services sites (e.g.
Dropbox, Google Docs)
Licensing Compliance2

16. Request to use
probabilistic
methodologies to
quantify IT risks
Corporate defense3

17. Request to use
probabilistic
methodologies to
quantify IT risks
Corporate defense3

18. Strength the scientific
basis to invest (or not!) on
data security controls for
contractual, privacy and
corporate criminal laws
Corporate defense3

19. “appropriate and
proportionate technical
and organisational
measures”
Corporate defense3

20. The paucity of legal opinion addressing
Monte Carlo techniques gives one pause at
suggesting that Monte Carlo simulation will
ever be challenged, much less successfully,
on judicial review. Judges will likely be
disinclined to delve into their intricacies, likely
characterized as technical and scientific and
subject to a longstanding judicial deference.”
Susan Poulter
Corporate defense3

21. IT compliance register4
GDPR, eCommerce directive
Computer crime for corporate
criminal responsibility
IT services, licenses, and
outsourcing contracts
Sectorial regulations for
essential services

22. Dumpster diving5
Ensure physical
documents and
drives are
safely
destroyed

23. Ensure how
backups are done
and retain for data
in the cloud
Due diligence for cloud

24. Ensure who has
access to the data
in the cloud
application
Due diligence for cloud

25. Security settings in
the cloud app are
aligned to the
internal policies
Due diligence for cloud

26. Undestand the
locations of the data
in transit and at rest
for privacy
Due diligence for cloud

27. Request to separate
company data from
the cloud application
to minimize risks
Due diligence for cloud

28. Checklist model
https://www.microsoft.com/en/trust-
center/compliance/due-diligence-checklist
Due diligence for cloud

29. Due diligence for cloud

30. Operators of essential services should
have risk-based IT and
compliance controls
with international
standards
NIS Directive

31. Operators of essential services should
detect and report
securitity breaches
without undue delay
NIS Directive

32. Secure
network
NIS Directive
Secure
systems
Continuity
plans
Incident
response
Penetration
tests3rd party
management

33. Ensure clients read
and accept the privacy
policy before they
provide personal data
eCommerce compliance

34. Ensure customers are
informed about the
uses of the cookies
eCommerce compliance

35. Verify that delivery
periods, payment
methods and
cancellation options are
communicated
eCommerce compliance

36. Control that the
clients can correct
and accept the order
in local language
eCommerce compliance

37. Verify that prices
include clear
shipping costs and
taxes
eCommerce compliance

38. Monitor contracts
and license
payments for used
software
Computer crime

39. Protect the intellectual
property of 3rd parties
by employees and
contractors
Computer crime

40. Prevent and detect
installed software for
fraud and hacking
abuse
Computer crime

41. Computer crime

42. Data loss prevention
tools prevent
exfiltration with
forensic evidence
Tools

43. Secure email
gateways can filter
bulk phishing emails
Tools

44. A data classification
policy can ensure
compliance while
preventing risks
Tools

45. eDiscovery helps to
review the record of
processing activities
for GDPR compliance
Tools

46. Enhanced multi-factor
authentication
prevents security
breaches
Tools

47. Our modular program
Compliance Culture
Compliance
risks
Program
operations
Privacy
compliance
Control
assurance
Blended

48. Our

49. Case method