Compliance, Security, and the relations therein

Last week, Anton Chuvakin shared his latest in the "compliance is not security" discussion:

Blabbing "compliance does not equal security" is a secret rite of passage into the League of High Priests of the Arcane Art of Security today. Still, it is often quietly assumed that a well-managed, mature security program, backed up by astute technology purchases and their solid implementation will render compliance "easy" or at least "easier." One of my colleagues also calls it "compliance as a byproduct." So, I was shocked to find out that not everyone agrees...

I think there are two separate issues that Anton is exploring.

The first is that a well-designed security control should aid in compliance. As one of his commenters notes, a good security program considers the regulatory issues; or, more plainly, a good security control considers the compliance auditor as an adversary. If you do not design controls to be auditable, you are building risk into your system (sidebar: what security risks are worse than failing an audit?).

But the second point is more interesting. Most compliance frameworks are written to target the industry standard architectures and designs. What if you are doing something so different that a given control has no parallel in your environment? Example: You have no password authentication in your environment; what do you do about controls that require certain password settings? What if your auditor insists on viewing inapplicable settings?

Then, you have three options:

  1. Convince your auditor of the inapplicability of the controls.
  2. Create sham controls to satisfy the auditor.
  3. Find another auditor.