Regulatory Compliance Register and Review Procedure
Governance Control: Strategy and Framework Reviews
1. Purpose
Establish the process for maintaining a comprehensive register of applicable cybersecurity regulatory and legal requirements and conducting systematic reviews of the cyber risk strategy and framework against those requirements.
2. Scope
This procedure applies to all cybersecurity, data protection, and technology-related legal and regulatory requirements applicable to [ORGANIZATION] across all jurisdictions of operation.
3. Procedure Content
3.1 Regulatory Inventory Maintenance
The [CUSTOMIZE: Legal/Compliance/Cyber Risk] team shall maintain a Regulatory Compliance Register documenting all applicable laws, regulations, contractual obligations, and industry standards that impose cybersecurity-related requirements on [ORGANIZATION].
The register shall include, at minimum: regulation/law name, jurisdiction, effective date, applicable business units, mapped framework components, compliance owner, last assessment date, and compliance status.
The register shall be reviewed for completeness no less than [CUSTOMIZE: quarterly] and updated within [CUSTOMIZE: 30 days] of the identification of any new or amended regulatory requirement.
Sources monitored for regulatory changes include: [CUSTOMIZE: e.g., regulatory agency publications, legal counsel updates, industry association alerts, subscription services].
3.2 Strategy and Framework Review Schedule
Comprehensive reviews of the Cyber Risk Strategy and Cyber Risk Framework against the Regulatory Compliance Register shall be conducted at least [CUSTOMIZE: annually].
Triggered reviews shall occur within [CUSTOMIZE: 60 days] of any of the following events: enactment of new cybersecurity legislation in applicable jurisdictions, issuance of new regulatory guidance, receipt of regulatory examination findings, material organizational changes, or significant changes to the threat landscape.
Reviews shall be led by [CUSTOMIZE: CISO/Head of Cyber Risk] in collaboration with [CUSTOMIZE: Legal, Compliance, Internal Audit, and affected business units].
3.3 Gap Analysis Process
Each review shall include a formal gap analysis comparing current strategy and framework elements against applicable regulatory requirements.
Gaps shall be classified by severity: Critical (non-compliance with binding regulatory requirement with enforcement risk), High (non-compliance with regulatory expectation or best practice), Medium (partial compliance requiring enhancement), Low (minor improvement opportunity).
For each identified gap, the following shall be documented: gap description, applicable regulation(s), affected framework component(s), risk rating, remediation owner, target remediation date, and interim compensating controls (if any).
Gap analysis findings shall be reported to [CUSTOMIZE: Executive Risk Committee/Board Audit Committee] within [CUSTOMIZE: 30 days] of review completion.
3.4 Remediation Tracking
All identified gaps shall be tracked in [CUSTOMIZE: GRC tool/remediation tracking system] with regular progress reporting.
Critical and High gaps shall be reported to [CUSTOMIZE: CISO/Executive Committee] at least [CUSTOMIZE: monthly] until resolved.
Remediation target dates shall be risk-based: Critical gaps within [CUSTOMIZE: 30 days], High within [CUSTOMIZE: 90 days], Medium within [CUSTOMIZE: 180 days], Low within [CUSTOMIZE: 365 days].
Extensions to remediation timelines require approval from [CUSTOMIZE: CISO/Executive Risk Committee] with documented justification.
3.5 Records and Evidence
The following records shall be maintained as evidence of compliance with this procedure:
Current Regulatory Compliance Register with all required fields populated
Review meeting agendas, minutes, and attendance records
Gap analysis reports with findings and remediation plans
Remediation tracking reports showing progress and closure evidence
Updated strategy and framework documents with version control showing regulatory-driven revisions
All records shall be retained for a minimum of [CUSTOMIZE: 7 years] per the records retention schedule.
4. Compliance
Compliance with this procedure is mandatory for all personnel and functions within its scope. Compliance will be monitored through periodic audits, management review, and second line of defence oversight.
Exceptions to this procedure must be documented with a business justification, approved by [CUSTOMIZE: CISO/Executive Risk Committee], and reviewed at least annually.
5. Review and Revision
This procedure shall be reviewed at least annually by [CUSTOMIZE: CISO/Document Owner] and updated as necessary to reflect changes in the threat landscape, regulatory requirements, organizational structure, or risk appetite.
All revisions shall be documented with version number, date, author, and description of changes.
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