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The Role of Governance, Risk Management &
Compliance in Organizations
Study of GRC practitioners
Ponemon Institute© Research Report
Sponsored by RSA, The Security Division of EMC
Independently conducted by Ponemon InstituteLLC
Publication Date: May 2011
Ponemon Institute© Research Report Page 1
The Role of Governance, Risk Management
& Compliance in Organizations
Ponemon Institute, May 2011
Part 1. Introduction
Ponemon Institute is pleased to present the results of The Role of Governance, Risk
Management & Compliance in Organizations, sponsored by RSA, The Security Division of EMC.
The focus of this research is to examine the challenges global organizations face in meeting
escalating enterprise Governance, Risk and Compliance (eGRC) objectives. Respondents
representing global financial services, technology, healthcare and pharmaceutical industries
identified the largest barriers to achieving their GRC goals as lack of a defined GRC strategy and
lack of enterprise cooperation and collaboration.
GRC stands for “Governance, Risk and Compliance”. Organizations leveraging GRC processes
desire to establish a regulatory or internal framework for satisfying governance requirements,
evaluate risk across their enterprise and track how the organization complies with the established
governance requirements. GRC processes typically fall within one of four key domains: IT,
operations, finance and legal. Domain specific needs include:	
  
	
  
 IT GRC: Includes the management of IT-related controls. These may include security
controls such as firewalls and or security information management system, system controls
automation and vulnerability monitoring tools, identity and access management system or
disaster planning and recovery systems.
 Operations GRC: Includes the management of core operations of the organization. For
example, organizations must ensure that there is support to manage processes from
manufacturing systems, HR systems, procurement, purchase order systems, power
generation monitoring and many more depending on the industry.
 Finance GRC: Includes the management of financial controls. For example, organizations
may wish to review segregation of duties to manage conflicting permissions, process-related
business rules such as the signature requirements for expenses above a certain amount or
auditing inspections.
 Legal GRC: Includes managing controls for regulatory compliance and contractual
requirements including the organization’s communication with government supervisory
entities. For example, an organization must assure proper management of corporate
governance reporting, anti-fraud, anti-bribery and anti-corruption, and privacy and consumer
protection management.	
  
In this inaugural study, we independently surveyed 190 individuals in one of the largest eGRC
practitioner communities at the RSA Archer eGRC Summit about privacy and data protection
activities and how they relate to business objectives or mission. These participants are known to
be involved in their organization’s GRC initiatives. The majority of respondents are at or above
the manager level, and more than half work for large-sized organizations. Our survey topics
focused on the following key issues:
 Where most GRC activities take place in an organization
 Collaboration and cooperation across GRC functional areas
 GRC strategies in organizations
 Barriers to implementing and achieving GRC objectives
 Compliance challenges with privacy and data security regulations
Ponemon Institute© Research Report Page 2
Part 2. Key findings
IT represents the largest area of GRC-related activities and is where the majority of
respondents say their GRC program started. Pie Chart 1 shows 44 percent of respondents
who state their GRC activities are primarily contained within the IT function – followed by 20
percent in operations, 19 percentage in finance and 17 percent in legal.
Bar Chart 1 shows the origins of GRC among respondents’ organizations. An overwhelming
majority of respondents (63 percent) say their organization’s GRC activities started within the IT
function. Only thirteen percent say GRC started in legal or finance, and 12 percent say it started
in operations.
Pie Chart 1. How much of your organization’s
GRC activities fall into each one of four GRC
domains?
Bar Chart 1. Where did your organizations GRC
program or initiatives start?
Very important response
Bar Chart 2 reports the relative importance of privacy within four GRC domains. As shown, 76
percent of respondents say privacy is a very important part of IT GRC activities and 71 percent
say it is very important to legal GRC.
Bar Chart 2: How important are privacy-related issues for each one of the four GRC domains?
Very important response
44%
20%
19%
17%
IT Operations Finance Legal
12%
13%
13%
63%
0% 20% 40% 60% 80%
Operations
Finance
Legal
IT
76%
71%
46%
37%
0%
10%
20%
30%
40%
50%
60%
70%
80%
IT GRC Legal GRC Operations GRC Finance GRC
Ponemon Institute© Research Report Page 3
A major barrier to tackling risk and privacy challenges is a lack of enterprise collaboration.
Bar Chart 3 shows 28 percent of respondents say there is frequent collaboration or cooperation
among GRC areas and 56 percent say they sometimes collaborate. Finally, as an indication that
silos are breaking down, only 12 percent of respondents say they operate in silos with little or no
collaboration.
Bar Chart 3: What best describes the working relationships among finance, IT, operations and legal
GRC functions in your organization today?
According to Bar Chart 4, the lack of resources (52 percent) and the lack of cooperation and
collaboration (44 percent) are the two most salient barriers to successfully achieving GRC-related
goals. The complexity of existing technologies (31 percent) and the lack of clear leadership (20
percent) are the third and fourth most salient barriers to a success according to respondents.
Bar Chart 4: What are the top two barriers to achieving your organization’s GRC-related goals?
1%
3%
12%
28%
56%
0% 10% 20% 30% 40% 50% 60%
Cannot determine
Full integration
Operate in silos
Frequent collaboration
Some collaboration
2%
3%
3%
4%
11%
15%
19%
19%
20%
31%
44%
52%
0% 10% 20% 30% 40% 50% 60%
Lack of organizational maturity
Complexity of the program
Inadequacy of existing technologies
Inability to get started (inertia)
Difficulty in hiring skilled personnel
Lack of C-level support
Inability to set priorities
Organizational change
Lack of clear leadership
Complexity of existing technologies
Lack of cooperation and collaboration
Lack of resources
Ponemon Institute© Research Report Page 4
Risk management is and will continue to be the biggest focus for organizations. Risk
management is top of mind for GRC professionals. Organizations are finding that the cost of
complying with a myriad of regulations is very expensive. Taking a risk-based approach toward
compliance requirements enables them to focus resources on the most significant regulatory or
legal issues facing their organizations.
Today, the largest percent of respondents (32 percent) believe risk management is considered
the most important element within their organization’s GRC program. When asked to forecast
priorities three years into the future, 33 percent of respondents state risk management is most
important. Compliance declines slightly from 27 percent to 24 percent of respondents who say it
will be most important. Governance and privacy increase slightly in three years.
Bar Chart 5: How important are the following four GRC focus areas to your job function today and
three years from now?
Response required the allocation of 100 points
The next four charts show where GRC-related activities reside in respondents’ organizations. Bar
Chart 6 suggests governance activities are mostly likely to reside within in the corporate IT
function according to 18 percent of respondents, followed by 17 percent who say it resides within
the enterprise risk management function. Bar Chart 7 shows risk management activities are most
likely to be located within enterprise risk management according to 39 percent of respondents,
and corporate IT according to 14 percent of respondents.
Bar Chart 6: Where governance GRC
activities reside
Bar Chart 7: Where risk management GRC
activities reside
32%
27%
22%
20%
33%
24% 23%
21%
0%
5%
10%
15%
20%
25%
30%
35%
Risk management Compliance Governance Privacy & data
protection
Today Three years from now (projection)
1%
4%
5%
6%
7%
8%
13%
17%
17%
18%
0% 5% 10% 15% 20%
Ethics
LOB
Board
Security
Legal
Spread out
Compliance
CEO
Risk mgmt
IT
3%
4%
4%
5%
5%
6%
8%
14%
39%
0% 10% 20% 30% 40% 50%
Board
CEO
Security
Finance
Spread out
LOB
Compliance
IT
Risk mgmt
Ponemon Institute© Research Report Page 5
Bar Chart 8 shows compliance activities are most likely to be located in corporate compliance (43
percent) followed by corporate IT (16 percent). Privacy program management activities are
located in legal, according to 28 percent of respondents followed by IT, according to 20 percent.
Bar Chart 8: Where compliance GRC
activities reside
Bar Chart 9: Where privacy program
management activities reside
As shown in Bar Chart 10, assessing risk (83 percent), monitoring compliance (63 percent) and
developing strategies (61 percent) are considered the most essential activities in order to meet
GRC objectives or goals. GRC-related activities considered less essential include advising the
organization’s management (40 percent), responding to incidents (42 percent) and training or
raising awareness (43 percent).
1
Bar Chart 10: Activities believed to be essential in order to meet GRC objectives or goals
1
Even if an activity is considered less essential, it does not mean it is not considered important or very
important to meeting GRC objectives.
2%
3%
4%
5%
6%
6%
10%
16%
43%
0% 10% 20% 30% 40% 50%
CEO
Finance
Risk mgmt
Security
LOB
Spread out
Legal
IT
Compliance
2%
2%
3%
3%
4%
7%
12%
14%
20%
28%
0% 10% 20% 30%
CEO
LOB
HR
Privacy office
Spread out
Security
Risk mgmt
Compliance
IT
Legal
40%
42%
43%
44%
45%
50%
60%
61%
63%
83%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90%
Advising the organization
Responding to incidents
Training and awareness
Administering program
Analyzing regulations
Creating and implementing policies
Reporting to senior management
Developing strategies
Monitoring compliance
Assessing risk
Ponemon Institute© Research Report Page 6
Bar Chart 11 shows only 20 percent of respondents say their organizations have a clearly defined
GRC strategy that pertains to the entire enterprise. Forty-seven percent say their organizations
have a clearly defined GRC strategy, but it does not pertain to entire enterprise. Third-three
percent admit their organizations do not have a GRC strategy.
2
Bar Chart 11: What best describes the respondent organization’s GRC strategy
To help achieve and support their GRC strategy, according to Bar Chart 12, many respondents’
organizations have a Chief Information Security Officer (81 percent) followed by a Chief Privacy
Officer (67 percent). Sixty-three percent of respondents say their organizations have a Chief
Compliance Officer and 60 percent have a Chief Risk Officer.
Bar Chart 12: Does your organization have the following leaders (or approximate titles)?
2
While not tested in our survey, it is possible that respondents’ companies that do not have a clearly defined
GRC strategy do have an informal strategy or tactical plan in place.
20%
33%
47%
0% 5% 10% 15% 20% 25% 30% 35% 40% 45% 50%
Clearly defined GRC strategy for the entire
enterprise
No clearly defined GRC strategy
Clearly defined GRC strategy that does not
pertain to the entire enterprise
14%
25%
49%
60%
63%
67%
81%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90%
Chief governance officer
Chief ethics officer
Chief security officer
Chief risk officer
Chief compliance officer
Chief privacy officer
Chief information security officer
Ponemon Institute© Research Report Page 7
Bar Chart 13 shows the degree to which GRC activities are centralized or decentralized. As can
be seen, all four GRC activities are more likely to be centralized than decentralized. GRC
activities relating to governance and privacy tend to be more centralized than activities relating to
compliance and risk management tend to be decentralized.
Bar Chart 13: Are GRC activities centralized or decentralized?
Response measured using a five-point scale from 1+2 = centralized to 4+5 = decentralized
Technology is important for GRC-related activities. As shown in Bar Chart 14, the primary
technology solutions used to support GRC-related activities are risk assessment (81 percent),
policy management (75 percent) and controls assessment (73 percent).
Bar Chart 14: Has your organization implemented technology solutions to accomplish GRC-related
activities?
The percentage rate of technology deployment
46% 45%
54%
52%
31%
26% 27%
35%
23%
28%
19%
13%
0%
10%
20%
30%
40%
50%
60%
Governance Risk mgmt Compliance Privacy
Centralized Combination Decentralized
16%
20%
25%
29%
35%
41%
42%
42%
53%
63%
68%
73%
75%
81%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90%
Data mapping
Business process analysis
Business process mapping
Data inventory
E-Discovery
Regulatory monitoring
Document management
Records management (archive)
Training & awareness
Compliance monitoring
Incident response & management
Controls assessment
Policy management
Risk assessment
Ponemon Institute© Research Report Page 8
With respect to the GRC technology solutions shown above, Bar Chart 15 reports that 88 percent
of respondents believe these solutions are essential (49 percent) or very important (39 percent).
No respondent believes these technology solutions are not important or are irrelevant.
Bar Chart 15: How important are the above-mentioned technologies for achieving GRC-related
objectives and goals in your organization?
Organizations are struggling to manage privacy regulations and ensure data sharing
practices are secure. According to Bar Chart 16, the top two privacy-related challenges or
issues facing respondents are ensuring that data shared with third parties (including cloud
providers) will remain safe and secure (51 percent) followed by complying with all appropriate
regulations (41 percent). Thirty-seven percent of respondents say education is most important,
while 31 percent say curtailing data loss is the most salient challenge to privacy.
Bar Chart 16: What are your organization’s most salient privacy-related challenges or issues?
Top two choices
49%
39%
11%
0% 0%
0%
10%
20%
30%
40%
50%
60%
Essential Very important Important Not important Irrelevant
8%
15%
26%
31%
37%
41%
51%
0% 10% 20% 30% 40% 50% 60%
Curtailing the use of insecure data-bearing
devices
Maintaining customer trust
Ensuring that policies will be strictly enforced
Curtailing data loss and theft
Educating all personnel
Complying with all appropriate regulations
Ensuring that data shared with third parties will
remain safe and secure
Ponemon Institute© Research Report Page 9
Bar Chart 17 lists the regulations that respondents perceive as most difficult to implement
effectively. According to respondents, the most difficult regulations to comply with are PCI DSS,
various US state privacy and data protection laws, GLBA, and HIPAA.
3
Bar Chart 17: What privacy or data protection regulations are most difficult to comply with?
Top three choices
3
Please note that our final sample of GRC practitioners was heavily skewed to individuals in the financial
services industry (51 percent). This may explain why GLBA was rated more frequently than other sector
regulations.
1%
1%
1%
3%
4%
4%
6%
8%
8%
11%
17%
21%
21%
26%
32%
35%
47%
0% 5% 10% 15% 20% 25% 30% 35% 40% 45% 50%
FIPS (FTC)
FFIEC
Basil II
COPPA
NERC CIP
FTC Fair Information Practices
Federal Privacy Act
Fair Credit Reporting Act (FCRA)
Other (please specify)
FISMA
International data protection laws
Sarbanes-Oxley
EU Data Protection Directive
HIPAA (including HITECH)
Gramm-Leach-Bliley (GLBA)
US State privacy & data protection law
PCI DSS
Ponemon Institute© Research Report Page 10
Part 3. Methods
Table 1 reports the sample response realized in this study. Our sampling frame consisted of a
known community of 1,240 GRC practitioners invited to attend an annual conference on eGRC
sponsored by RSA Archer. All individuals were invited to participate in a web-based survey. Of
these individuals, 206 returned survey responses. Sixteen surveys were rejected because of
reliability issues, resulting in a final sample of 190 respondents (15 percent response rate).
Table 1: Sample response Freq. Pct%
Total sample frame 1,240 100%
Total returns 206 17%
Rejected surveys 16 1%
Final sample 190 15%
Pie Chart 2 provides the percentage frequency of respondents according to the organization’s
primary industry sector. As can be seen, more than half of respondents are employed by
financial service organizations (including retail banks, insurance, investment management,
brokerage, and payment processing (credit card)).
Pie Chart 2: Industry distribution of respondents
Table 2 reports the approximate position level of respondents. As reported, more than 62 percent
of respondents state they are at or above the manager level within their organizations.
Table 2: Respondents’ approximate position levels Pct%
Senior Executive 3%
Vice President 12%
Director 19%
Manager 28%
Associate/Staff 26%
Technician 4%
Consultant 2%
Other (please specify) 6%
Total 100%
51%
15%
13%
4%
3%
2%
2%
2%
2%
6%
Financial services
Technology & software
Healthcare
Communications
Retail
Defense contractor
Industrial
Professional services
Services
Other
Ponemon Institute© Research Report Page 11
Table 3 lists the primary reporting channel of respondents. The most frequently cited reporting
channels include the CRO (20 percent), CISO (19 percent) and CIO (14 percent).
Table 3: Respondents’ reporting channel within their organization Pct%
Chief Risk Officer (CRO) 20%
Chief Information Security Officer (CISO) 19%
Chief Information Officer (CIO) 14%
Chief Security Officer (CSO) 13%
Compliance/Ethics Officer 9%
Director, Internal Audit 6%
All other titles 6%
Chief Technology Officer (CTO) 5%
Chief Financial Officer (CFO) 3%
General Counsel (GC) 2%
GRC Leader 2%
Chief Privacy Officer (CPO) 1%
Total 100%
Table 4 lists the worldwide headcount of organizations represented by respondents. As can be
seen, the majority of organizations (57 percent) are larger-sized entities with more than 25,000
full time equivalent employees.
Table 4: The worldwide headcount of respondents’ organizations Pct%
Less than 500 people 4%
500 to 1,000 people 1%
1,001 to 5,000 people 12%
5,001 to 25,000 people 26%
25,001 to 75,000 people 34%
More than 75,000 people 23%
Total 100%
Table 5 provides the global footprint of respondents’ organizations. As shown, the vast majority
of respondents work for organizations that are located in the United States. Many organizations
have operations in Europe (55 percent), Canada (42 percent), the Asia-Pacific region (46
percent) and Latin America (37 percent).
Table 5. The global footprint of participating organizations Pct%
United States 97%
Canada 42%
Europe 55%
Middle East & Africa 31%
Asia-Pacific 46%
Latin America (including Mexico) 37%
Ponemon Institute© Research Report Page 12
Part 4. Conclusion
Caveats
There are inherent limitations to survey research that need to be carefully considered before
drawing inferences from findings. The following items are specific limitations that are germane to
most web-based surveys.
 Non-response bias: The current findings are based on a sample of survey returns. We sent
surveys to a representative sample of GRC practitioners in various business organizations,
resulting in a large number of usable returned responses. Despite non-response tests, it is
always possible that auditors who did not participate are substantially different in terms of
underlying beliefs from those who completed the survey.
 Sampling-frame bias: The accuracy is based on contact information and the degree to which
the list is representative of individuals who are members of the emerging GRC community.
We also acknowledge that responses from paper, interviews or by telephone might result in a
different pattern of findings.
 0BSelf-reported results: The quality of survey research is based on the integrity of confidential
responses received from respondents. While certain checks and balances were incorporated
into our survey evaluation process, there is always the possibility that certain respondents did
not provide responses that reflect their true opinions.
Concluding Thoughts
We believe this study reveals the importance of an enterprise-wide strategy and increased
collaboration among domains to meeting eGRC objectives. Currently, only 20 percent have an
enterprise-wide strategy and collaboration among GRC areas is far from perfect. Only 28 percent
of respondents say their organizations enjoy frequent collaboration or cooperation among GRC
areas. However, the good news is that only 12 percent say GRC areas operate in silos in their
organizations.
The study also demonstrates that privacy is an eGRC collaboration flashpoint. Regardless of their
industry, all organizations are struggling to manage privacy regulations that must be addressed
by geography and in accordance with country or state laws. Today privacy management
responsibilities are typically split between the legal and IT functions. While the legal department
plays a dominant privacy role overall, IT still holds accountability for implementing controls to
address privacy regulations. Respondents identified their top two privacy challenges as ensuring
data shared with third parties will remain safe and secure and complying with all appropriate
regulations.
In order to address the barriers related to collaboration, it has been recommended that
organizations make it a priority to encourage people from the various lines of business to talk
together and establish “risk ambassadors”. The need to gain visibility and control through
effective cross-enterprise eGRC collaboration is important to reducing gaps in how risk is
assessed and managed.
Finally, according to respondents, managing risk is and will continue to be the biggest eGRC
focus for their organizations. This is understandable because organizations are finding that the
cost of complying with the plethora of regulations can be daunting. Taking a risk-based approach
toward compliance requirements enables them to focus their resources on the most at-risk areas
of their business and achieve real value from their eGRC activities.
Ponemon Institute© Research Report Page 13
Appendix: Detailed Survey Findings
The following tables provide the percentage frequency of responses to all survey responses
completed on March 30, 2011.
Sample response Freq.
Total sample frame 1240
Total returns 206
Rejected surveys 16
Final sample 190
Response rate 15.3%
Q1. How much of your organization’s GRC activities fall into each one of the four GRC
domains? Please allocate 100 points to estimate the effort extended to each GRC
domain. Pct%
Finance GRC 19%
IT GRC 44%
Operations GRC 20%
Legal GRC 17%
Total 100%
Q2. How important are privacy-related issues for each one of the four GRC
domains?
Finance GRC Pct%
Very important 37%
Important 41%
Not important 18%
Irrelevant 4%
Total 100%
IT GRC Pct%
Very important 76%
Important 23%
Not important 1%
Irrelevant 0%
Total 100%
Operations GRC Pct%
Very important 46%
Important 46%
Not important 4%
Irrelevant 4%
Total 100%
Legal GRC Pct%
Very important 71%
Important 23%
Not important 2%
Irrelevant 4%
Total 100%
Ponemon Institute© Research Report Page 14
Q3. What statement best describes the working relationships among finance, IT,
operations and legal GRC functions in your organization today? Pct%
They operate in silos (little collaboration) 12%
They sometimes collaborate 56%
They frequently collaborate 28%
They are fully integrated 3%
Cannot determine 1%
Total 100%
Q4. Please answer the following four statements using the scale provided next to
each item.
Q4a. My job is primarily focused on finance. Pct%
Strongly agree 5%
Agree 14%
Unsure 4%
Disagree 35%
Strongly disagree 41%
Total 100%
Q4b. My job is primarily focused on IT. Pct%
Strongly agree 57%
Agree 20%
Unsure 1%
Disagree 16%
Strongly disagree 5%
Total 100%
Q4c. My job is primarily focused on operations. Pct%
Strongly agree 11%
Agree 41%
Unsure 9%
Disagree 22%
Strongly disagree 17%
Total 100%
Q4d. My job is primarily focused on legal and compliance issues. Pct%
Strongly agree 20%
Agree 47%
Unsure 7%
Disagree 12%
Strongly disagree 14%
Total 100%
Q4e. My job is primarily focused on privacy issues. Pct%
Strongly agree 13%
Agree 47%
Unsure 13%
Disagree 21%
Strongly disagree 7%
Total 100%
Ponemon Institute© Research Report Page 15
Q5a. How important are the following four focus areas to your job function? Please
allocate 100 points to estimate the importance of focus areas to the fulfillment of your job
function today. Pct%
Governance 22%
Risk management 32%
Compliance 27%
Privacy & data protection 20%
Total 100%
Q5b. How important are the following four focus areas to your job function? Please
allocate 100 points to estimate the importance of focus areas to the fulfillment of your job
function three years into the future. Pct%
Governance 23%
Risk management 33%
Compliance 24%
Privacy & data protection 21%
Total 100%
Q6. What job functions do you perform in your organization? Please check all that apply. Total%
Corporate ethics 8%
Corporate communications 5%
Corporate marketing 2%
E-Discovery 6%
General consulting 23%
General management 17%
Government affairs 3%
Human resources 3%
Information security 71%
Information technology 52%
Internal audit 17%
Legal department 6%
Public relations 2%
Privacy management 27%
Risk management 77%
Regulatory compliance 46%
Records management 11%
Total 377%
Q7a. Where are governance activities located within your organization? Pct%
Board of directors 5%
CEO/Executive committee 17%
Finance 0%
Legal 7%
Corporate compliance 13%
Information technology (IT) 18%
Public relations 0%
Security & information security 6%
Ethics & compliance 1%
Enterprise risk management 17%
Operational risk management 2%
Business units 4%
Human resources 0%
Spread among several units 8%
Other (please specify) 2%
Total 100%
Ponemon Institute© Research Report Page 16
Q7b. Where are risk management activities located within your organization? Pct%
Board of directors 3%
CEO/Executive committee 4%
Finance 5%
Legal 0%
Corporate compliance 8%
Information technology (IT) 14%
Public relations 0%
Security & information security 4%
Insurance 0%
Enterprise risk management 39%
Operational risk management 6%
Business units 6%
Human resources 0%
Spread among several units 5%
Other (please specify) 5%
Total 100%
Q7c. Where are compliance activities located within your organization? Pct%
Board of directors 0%
CEO/Executive committee 2%
Finance 3%
Legal 10%
Corporate compliance 43%
Information technology (IT) 16%
Public relations 0%
Security & information security 5%
Insurance 0%
Enterprise risk management 4%
Operational risk management 2%
Business units 6%
Human resources 0%
Spread among several units 6%
Other (please specify) 2%
Total 100%
Q7d. Where are privacy management activities located within your organization? Pct%
Board of directors 0%
CEO/Executive committee 2%
Finance 0%
Legal 28%
Corporate compliance 14%
Information technology (IT) 20%
Public relations 0%
Security & information security 7%
Insurance 0%
Enterprise risk management 12%
Operational risk management 3%
Business units 2%
Human resources 3%
Spread among several units 4%
Other (please specify) 1%
Privacy office 3%
Total 100%
Ponemon Institute© Research Report Page 17
Q8. Please rate all the activities that you pursue in order to meet GRC objectives or
goals according to the three-point scale: (1) essential, (2) important or (3) not important.
Q8a. Developing strategies Pct%
Essential to GRC objectives 61%
Important to GRC objectives 36%
Not important to GRC objectives 3%
Total 100%
Q8b. Analyzing regulations Pct%
Essential to GRC objectives 45%
Important to GRC objectives 51%
Not important to GRC objectives 4%
Total 100%
Q8c. Assessing risk Pct%
Essential to GRC objectives 83%
Important to GRC objectives 16%
Not important to GRC objectives 1%
Total 100%
Q8d. Creating and implementing policies Pct%
Essential to GRC objectives 50%
Important to GRC objectives 47%
Not important to GRC objectives 3%
Total 100%
Q8e. Training and awareness Pct%
Essential to GRC objectives 43%
Important to GRC objectives 49%
Not important to GRC objectives 7%
Total 100%
Q8f. Monitoring compliance Pct%
Essential to GRC objectives 63%
Important to GRC objectives 38%
Not important to GRC objectives 0%
Total 100%
Q8g. Reporting to senior management Pct%
Essential to GRC objectives 60%
Important to GRC objectives 36%
Not important to GRC objectives 4%
Total 100%
Q8h. Administering program Pct%
Essential to GRC objectives 44%
Important to GRC objectives 52%
Not important to GRC objectives 4%
Total 100%
Q8j. Advising or consulting within the organization Pct%
Essential to GRC objectives 40%
Important to GRC objectives 55%
Not important to GRC objectives 5%
Total 100%
Ponemon Institute© Research Report Page 18
Q8k. Responding to incidents Pct%
Essential to GRC objectives 42%
Important to GRC objectives 47%
Not important to GRC objectives 11%
Total 100%
Q9. What statement best describes your organization’s GRC strategy? Pct%
Our organization has a clearly defined GRC strategy and pertains to the entire
enterprise. 20%
Our organization has a clearly defined GRC strategy, but it is not applicable to the entire
enterprise. 47%
Our organization does not have a clearly defined GRC strategy. 33%
Total 100%
Q10. Does your organization have the following leaders (or approximate job titles)?
Please check all that apply. Pct%
Chief privacy officer 67%
Chief compliance officer 63%
Chief ethics officer 25%
Chief governance officer 14%
Chief risk officer 60%
Chief information security officer 81%
Chief security officer 49%
Total 360%
Q11. Has your organization implemented technology solutions for the following GRC-
related activities? Please check all that apply. Pct%
Policy management 75%
Risk assessment 81%
Controls assessment 73%
Business process mapping 25%
Business process analysis 20%
Data mapping 16%
Document management 42%
Data inventory 29%
Regulatory monitoring 41%
Compliance monitoring 63%
Incident response & management 68%
Training & awareness 53%
Records management (archive) 42%
E-Discovery 35%
Total 663%
Q12. In your opinion, how important are the above-mentioned technologies for achieving
GRC-related objectives and goals in your organization? Pct%
Essential 49%
Very important 39%
Important 11%
Not important 0%
Irrelevant 0%
Total 100%
Ponemon Institute© Research Report Page 19
Q13. Are your organization’s governance, risk management, compliance and
privacy/data protection functions centralized or decentralized? Please use the five-point
scale provided next to each focus area:
Centralized – the activities or function are managed by one central authority within the
enterprise.
Decentralized – the activities or function are managed across units or spread among
business segments.
Q13a. Activities relating to governance Pct%
Centralized=1 20%
2 26%
3 31%
4 13%
Decentralized=5 11%
Total 100%
Q13b. Activities relating to risk management Pct%
Centralized=1 14%
2 32%
3 26%
4 20%
Decentralized=5 8%
Total 100%
Q13c. Activities relating to compliance Pct%
Centralized=1 18%
2 36%
3 27%
4 11%
Decentralized=5 7%
Total 100%
Q13d. Activities relating to privacy Pct%
Centralized=1 22%
2 30%
3 35%
4 8%
Decentralized=5 4%
Total 100%
Q14. What are the top two barriers to achieving your organization’s GRC-related goals? Pct%
Lack of resources 52%
Lack of C-level support 15%
Lack of clear leadership 20%
Difficulty in hiring skilled personnel 11%
Inability to set priorities 19%
Inability to get started (inertia) 4%
Lack of cooperation and collaboration among the various departments involved in GRC 44%
Major organizational changes such as mergers, downsizing, financial turmoil and others 19%
Complexity of the program 3%
Complexity of existing technologies 31%
Inadequacy of existing technologies 3%
Lack of organizational maturity 2%
Other (please specify) 2%
Total 224%
Ponemon Institute© Research Report Page 20
Q15. What are your organization’s top two privacy-related challenges or issues? Pct%
Curtailing data loss and theft 31%
Curtailing the use of insecure data-bearing devices including smartphones and USB
sticks 8%
Complying with all appropriate regulations 41%
Educating all personnel 37%
Maintaining customer trust 15%
Ensuring that data shared with third parties (including cloud providers) will remain safe
and secure 51%
Ensuring that policies will be strictly enforced 26%
Total 208%
Q16. What top three privacy or data protection regulations are most difficult to comply
with? Pct%
PCI DSS 47%
HIPAA (including HITECH) 26%
Sarbanes-Oxley 21%
Gramm-Leach-Bliley (GLBA) 32%
Child Online Privacy Protection Act (COPPA) 3%
NERC CIP 4%
Fair Information Practices (FTC) 1%
Fair Credit Reporting Act (FCRA) 8%
Federal Privacy Act 6%
FTC Fair Information Practices 4%
FISMA 11%
FFIEC 1%
Basil II 1%
EU Data Protection Directive (including Safe Harbor) 21%
Various US state privacy and data protection laws 35%
Various international privacy and data protection laws 17%
Other (please specify) 8%
Total 247%
Q17. Where did your organizations GRC program or initiatives start? Pct%
Information technology 63%
Operations 12%
Finance 13%
Legal 13%
Total 100%
Ponemon Institute© Research Report Page 21
Demographics & organizational characteristics
D1. What organizational level best describes your current position? Pct%
Senior Executive 3%
Vice President 12%
Director 19%
Manager 28%
Associate/Staff 26%
Technician 4%
Consultant 2%
Other (please specify) 6%
Total 100%
D2. Select the primary person you report to within the organization. Pct%
CEO/Executive Committee 0%
Chief Financial Officer 3%
General Counsel 2%
Chief Information Officer 14%
Compliance/Ethics Officer 9%
Chief Technology Officer 5%
CSO 13%
Chief Risk Officer 20%
CISO 19%
Chief Privacy Officer 1%
Director, Internal Audit 6%
GRC Leader 2%
Other (please specify) 6%
Total 100%
D3. Select the secondary person you report to within the organization (or leave blank if
you do not have a secondary or dotted line reporting relationship). Pct%
CEO/Executive Committee 3%
Chief Financial Officer 2%
General Counsel 3%
Chief Information Officer 11%
Compliance/Ethics Officer 3%
Chief Technology Officer 3%
CSO 8%
Chief Risk Officer 7%
CISO 8%
Chief Privacy Officer 2%
Director, Internal Audit 2%
Other (please specify) 3%
Blank 43%
Total 100%
D4. Gender: Pct%
Male 70%
Female 30%
Total 100%
Ponemon Institute© Research Report Page 22
D5. What industry best describes your organization’s primary industry? Pct%
Communications 3%
Defense contractor 2%
Education & research 0%
Financial services 51%
Healthcare 13%
Hospitality 0%
Industrial 2%
Pharmaceuticals 1%
Professional services 2%
Public sector 1%
Retail 3%
Services 2%
Technology & software 15%
Transportation 1%
Utilities & energy 1%
Media 1%
Other (please specify) 1%
Total 100%
D6. Where are your employees located? Please check all regions that apply. Pct%
United States 97%
Canada 42%
Europe 55%
Middle East & Africa 31%
Asia-Pacific 46%
Latin America (including Mexico) 37%
Total 308%
D7. What is the worldwide headcount of your organization? Pct%
Less than 500 people 4%
500 to 1,000 people 1%
1,001 to 5,000 people 12%
5,001 to 25,000 people 26%
25,001 to 75,000 people 34%
More than 75,000 people 23%
Total 100%
Ponemon Institute© Research Report Page 23
Ponemon Institute
Advancing Responsible Information Management
Ponemon Institute is dedicated to independent research and education that advances responsible
information and privacy management practices within business and government. Our mission is to conduct
high quality, empirical studies on critical issues affecting the management and security of sensitive
information about people and organizations.
As a member of the Council of American Survey Research Organizations (CASRO),we uphold strict
data confidentiality, privacy and ethical research standards. We do not collect any personally identifiable
information from individuals (or company identifiable information in our business research). Furthermore, we
have strict quality standards to ensure that subjects are not asked extraneous, irrelevant or improper
questions.

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Lets understand the GRC market well with Ponemon analysis- FixNix

  • 1. The Role of Governance, Risk Management & Compliance in Organizations Study of GRC practitioners Ponemon Institute© Research Report Sponsored by RSA, The Security Division of EMC Independently conducted by Ponemon InstituteLLC Publication Date: May 2011
  • 2. Ponemon Institute© Research Report Page 1 The Role of Governance, Risk Management & Compliance in Organizations Ponemon Institute, May 2011 Part 1. Introduction Ponemon Institute is pleased to present the results of The Role of Governance, Risk Management & Compliance in Organizations, sponsored by RSA, The Security Division of EMC. The focus of this research is to examine the challenges global organizations face in meeting escalating enterprise Governance, Risk and Compliance (eGRC) objectives. Respondents representing global financial services, technology, healthcare and pharmaceutical industries identified the largest barriers to achieving their GRC goals as lack of a defined GRC strategy and lack of enterprise cooperation and collaboration. GRC stands for “Governance, Risk and Compliance”. Organizations leveraging GRC processes desire to establish a regulatory or internal framework for satisfying governance requirements, evaluate risk across their enterprise and track how the organization complies with the established governance requirements. GRC processes typically fall within one of four key domains: IT, operations, finance and legal. Domain specific needs include:      IT GRC: Includes the management of IT-related controls. These may include security controls such as firewalls and or security information management system, system controls automation and vulnerability monitoring tools, identity and access management system or disaster planning and recovery systems.  Operations GRC: Includes the management of core operations of the organization. For example, organizations must ensure that there is support to manage processes from manufacturing systems, HR systems, procurement, purchase order systems, power generation monitoring and many more depending on the industry.  Finance GRC: Includes the management of financial controls. For example, organizations may wish to review segregation of duties to manage conflicting permissions, process-related business rules such as the signature requirements for expenses above a certain amount or auditing inspections.  Legal GRC: Includes managing controls for regulatory compliance and contractual requirements including the organization’s communication with government supervisory entities. For example, an organization must assure proper management of corporate governance reporting, anti-fraud, anti-bribery and anti-corruption, and privacy and consumer protection management.   In this inaugural study, we independently surveyed 190 individuals in one of the largest eGRC practitioner communities at the RSA Archer eGRC Summit about privacy and data protection activities and how they relate to business objectives or mission. These participants are known to be involved in their organization’s GRC initiatives. The majority of respondents are at or above the manager level, and more than half work for large-sized organizations. Our survey topics focused on the following key issues:  Where most GRC activities take place in an organization  Collaboration and cooperation across GRC functional areas  GRC strategies in organizations  Barriers to implementing and achieving GRC objectives  Compliance challenges with privacy and data security regulations
  • 3. Ponemon Institute© Research Report Page 2 Part 2. Key findings IT represents the largest area of GRC-related activities and is where the majority of respondents say their GRC program started. Pie Chart 1 shows 44 percent of respondents who state their GRC activities are primarily contained within the IT function – followed by 20 percent in operations, 19 percentage in finance and 17 percent in legal. Bar Chart 1 shows the origins of GRC among respondents’ organizations. An overwhelming majority of respondents (63 percent) say their organization’s GRC activities started within the IT function. Only thirteen percent say GRC started in legal or finance, and 12 percent say it started in operations. Pie Chart 1. How much of your organization’s GRC activities fall into each one of four GRC domains? Bar Chart 1. Where did your organizations GRC program or initiatives start? Very important response Bar Chart 2 reports the relative importance of privacy within four GRC domains. As shown, 76 percent of respondents say privacy is a very important part of IT GRC activities and 71 percent say it is very important to legal GRC. Bar Chart 2: How important are privacy-related issues for each one of the four GRC domains? Very important response 44% 20% 19% 17% IT Operations Finance Legal 12% 13% 13% 63% 0% 20% 40% 60% 80% Operations Finance Legal IT 76% 71% 46% 37% 0% 10% 20% 30% 40% 50% 60% 70% 80% IT GRC Legal GRC Operations GRC Finance GRC
  • 4. Ponemon Institute© Research Report Page 3 A major barrier to tackling risk and privacy challenges is a lack of enterprise collaboration. Bar Chart 3 shows 28 percent of respondents say there is frequent collaboration or cooperation among GRC areas and 56 percent say they sometimes collaborate. Finally, as an indication that silos are breaking down, only 12 percent of respondents say they operate in silos with little or no collaboration. Bar Chart 3: What best describes the working relationships among finance, IT, operations and legal GRC functions in your organization today? According to Bar Chart 4, the lack of resources (52 percent) and the lack of cooperation and collaboration (44 percent) are the two most salient barriers to successfully achieving GRC-related goals. The complexity of existing technologies (31 percent) and the lack of clear leadership (20 percent) are the third and fourth most salient barriers to a success according to respondents. Bar Chart 4: What are the top two barriers to achieving your organization’s GRC-related goals? 1% 3% 12% 28% 56% 0% 10% 20% 30% 40% 50% 60% Cannot determine Full integration Operate in silos Frequent collaboration Some collaboration 2% 3% 3% 4% 11% 15% 19% 19% 20% 31% 44% 52% 0% 10% 20% 30% 40% 50% 60% Lack of organizational maturity Complexity of the program Inadequacy of existing technologies Inability to get started (inertia) Difficulty in hiring skilled personnel Lack of C-level support Inability to set priorities Organizational change Lack of clear leadership Complexity of existing technologies Lack of cooperation and collaboration Lack of resources
  • 5. Ponemon Institute© Research Report Page 4 Risk management is and will continue to be the biggest focus for organizations. Risk management is top of mind for GRC professionals. Organizations are finding that the cost of complying with a myriad of regulations is very expensive. Taking a risk-based approach toward compliance requirements enables them to focus resources on the most significant regulatory or legal issues facing their organizations. Today, the largest percent of respondents (32 percent) believe risk management is considered the most important element within their organization’s GRC program. When asked to forecast priorities three years into the future, 33 percent of respondents state risk management is most important. Compliance declines slightly from 27 percent to 24 percent of respondents who say it will be most important. Governance and privacy increase slightly in three years. Bar Chart 5: How important are the following four GRC focus areas to your job function today and three years from now? Response required the allocation of 100 points The next four charts show where GRC-related activities reside in respondents’ organizations. Bar Chart 6 suggests governance activities are mostly likely to reside within in the corporate IT function according to 18 percent of respondents, followed by 17 percent who say it resides within the enterprise risk management function. Bar Chart 7 shows risk management activities are most likely to be located within enterprise risk management according to 39 percent of respondents, and corporate IT according to 14 percent of respondents. Bar Chart 6: Where governance GRC activities reside Bar Chart 7: Where risk management GRC activities reside 32% 27% 22% 20% 33% 24% 23% 21% 0% 5% 10% 15% 20% 25% 30% 35% Risk management Compliance Governance Privacy & data protection Today Three years from now (projection) 1% 4% 5% 6% 7% 8% 13% 17% 17% 18% 0% 5% 10% 15% 20% Ethics LOB Board Security Legal Spread out Compliance CEO Risk mgmt IT 3% 4% 4% 5% 5% 6% 8% 14% 39% 0% 10% 20% 30% 40% 50% Board CEO Security Finance Spread out LOB Compliance IT Risk mgmt
  • 6. Ponemon Institute© Research Report Page 5 Bar Chart 8 shows compliance activities are most likely to be located in corporate compliance (43 percent) followed by corporate IT (16 percent). Privacy program management activities are located in legal, according to 28 percent of respondents followed by IT, according to 20 percent. Bar Chart 8: Where compliance GRC activities reside Bar Chart 9: Where privacy program management activities reside As shown in Bar Chart 10, assessing risk (83 percent), monitoring compliance (63 percent) and developing strategies (61 percent) are considered the most essential activities in order to meet GRC objectives or goals. GRC-related activities considered less essential include advising the organization’s management (40 percent), responding to incidents (42 percent) and training or raising awareness (43 percent). 1 Bar Chart 10: Activities believed to be essential in order to meet GRC objectives or goals 1 Even if an activity is considered less essential, it does not mean it is not considered important or very important to meeting GRC objectives. 2% 3% 4% 5% 6% 6% 10% 16% 43% 0% 10% 20% 30% 40% 50% CEO Finance Risk mgmt Security LOB Spread out Legal IT Compliance 2% 2% 3% 3% 4% 7% 12% 14% 20% 28% 0% 10% 20% 30% CEO LOB HR Privacy office Spread out Security Risk mgmt Compliance IT Legal 40% 42% 43% 44% 45% 50% 60% 61% 63% 83% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% Advising the organization Responding to incidents Training and awareness Administering program Analyzing regulations Creating and implementing policies Reporting to senior management Developing strategies Monitoring compliance Assessing risk
  • 7. Ponemon Institute© Research Report Page 6 Bar Chart 11 shows only 20 percent of respondents say their organizations have a clearly defined GRC strategy that pertains to the entire enterprise. Forty-seven percent say their organizations have a clearly defined GRC strategy, but it does not pertain to entire enterprise. Third-three percent admit their organizations do not have a GRC strategy. 2 Bar Chart 11: What best describes the respondent organization’s GRC strategy To help achieve and support their GRC strategy, according to Bar Chart 12, many respondents’ organizations have a Chief Information Security Officer (81 percent) followed by a Chief Privacy Officer (67 percent). Sixty-three percent of respondents say their organizations have a Chief Compliance Officer and 60 percent have a Chief Risk Officer. Bar Chart 12: Does your organization have the following leaders (or approximate titles)? 2 While not tested in our survey, it is possible that respondents’ companies that do not have a clearly defined GRC strategy do have an informal strategy or tactical plan in place. 20% 33% 47% 0% 5% 10% 15% 20% 25% 30% 35% 40% 45% 50% Clearly defined GRC strategy for the entire enterprise No clearly defined GRC strategy Clearly defined GRC strategy that does not pertain to the entire enterprise 14% 25% 49% 60% 63% 67% 81% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% Chief governance officer Chief ethics officer Chief security officer Chief risk officer Chief compliance officer Chief privacy officer Chief information security officer
  • 8. Ponemon Institute© Research Report Page 7 Bar Chart 13 shows the degree to which GRC activities are centralized or decentralized. As can be seen, all four GRC activities are more likely to be centralized than decentralized. GRC activities relating to governance and privacy tend to be more centralized than activities relating to compliance and risk management tend to be decentralized. Bar Chart 13: Are GRC activities centralized or decentralized? Response measured using a five-point scale from 1+2 = centralized to 4+5 = decentralized Technology is important for GRC-related activities. As shown in Bar Chart 14, the primary technology solutions used to support GRC-related activities are risk assessment (81 percent), policy management (75 percent) and controls assessment (73 percent). Bar Chart 14: Has your organization implemented technology solutions to accomplish GRC-related activities? The percentage rate of technology deployment 46% 45% 54% 52% 31% 26% 27% 35% 23% 28% 19% 13% 0% 10% 20% 30% 40% 50% 60% Governance Risk mgmt Compliance Privacy Centralized Combination Decentralized 16% 20% 25% 29% 35% 41% 42% 42% 53% 63% 68% 73% 75% 81% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% Data mapping Business process analysis Business process mapping Data inventory E-Discovery Regulatory monitoring Document management Records management (archive) Training & awareness Compliance monitoring Incident response & management Controls assessment Policy management Risk assessment
  • 9. Ponemon Institute© Research Report Page 8 With respect to the GRC technology solutions shown above, Bar Chart 15 reports that 88 percent of respondents believe these solutions are essential (49 percent) or very important (39 percent). No respondent believes these technology solutions are not important or are irrelevant. Bar Chart 15: How important are the above-mentioned technologies for achieving GRC-related objectives and goals in your organization? Organizations are struggling to manage privacy regulations and ensure data sharing practices are secure. According to Bar Chart 16, the top two privacy-related challenges or issues facing respondents are ensuring that data shared with third parties (including cloud providers) will remain safe and secure (51 percent) followed by complying with all appropriate regulations (41 percent). Thirty-seven percent of respondents say education is most important, while 31 percent say curtailing data loss is the most salient challenge to privacy. Bar Chart 16: What are your organization’s most salient privacy-related challenges or issues? Top two choices 49% 39% 11% 0% 0% 0% 10% 20% 30% 40% 50% 60% Essential Very important Important Not important Irrelevant 8% 15% 26% 31% 37% 41% 51% 0% 10% 20% 30% 40% 50% 60% Curtailing the use of insecure data-bearing devices Maintaining customer trust Ensuring that policies will be strictly enforced Curtailing data loss and theft Educating all personnel Complying with all appropriate regulations Ensuring that data shared with third parties will remain safe and secure
  • 10. Ponemon Institute© Research Report Page 9 Bar Chart 17 lists the regulations that respondents perceive as most difficult to implement effectively. According to respondents, the most difficult regulations to comply with are PCI DSS, various US state privacy and data protection laws, GLBA, and HIPAA. 3 Bar Chart 17: What privacy or data protection regulations are most difficult to comply with? Top three choices 3 Please note that our final sample of GRC practitioners was heavily skewed to individuals in the financial services industry (51 percent). This may explain why GLBA was rated more frequently than other sector regulations. 1% 1% 1% 3% 4% 4% 6% 8% 8% 11% 17% 21% 21% 26% 32% 35% 47% 0% 5% 10% 15% 20% 25% 30% 35% 40% 45% 50% FIPS (FTC) FFIEC Basil II COPPA NERC CIP FTC Fair Information Practices Federal Privacy Act Fair Credit Reporting Act (FCRA) Other (please specify) FISMA International data protection laws Sarbanes-Oxley EU Data Protection Directive HIPAA (including HITECH) Gramm-Leach-Bliley (GLBA) US State privacy & data protection law PCI DSS
  • 11. Ponemon Institute© Research Report Page 10 Part 3. Methods Table 1 reports the sample response realized in this study. Our sampling frame consisted of a known community of 1,240 GRC practitioners invited to attend an annual conference on eGRC sponsored by RSA Archer. All individuals were invited to participate in a web-based survey. Of these individuals, 206 returned survey responses. Sixteen surveys were rejected because of reliability issues, resulting in a final sample of 190 respondents (15 percent response rate). Table 1: Sample response Freq. Pct% Total sample frame 1,240 100% Total returns 206 17% Rejected surveys 16 1% Final sample 190 15% Pie Chart 2 provides the percentage frequency of respondents according to the organization’s primary industry sector. As can be seen, more than half of respondents are employed by financial service organizations (including retail banks, insurance, investment management, brokerage, and payment processing (credit card)). Pie Chart 2: Industry distribution of respondents Table 2 reports the approximate position level of respondents. As reported, more than 62 percent of respondents state they are at or above the manager level within their organizations. Table 2: Respondents’ approximate position levels Pct% Senior Executive 3% Vice President 12% Director 19% Manager 28% Associate/Staff 26% Technician 4% Consultant 2% Other (please specify) 6% Total 100% 51% 15% 13% 4% 3% 2% 2% 2% 2% 6% Financial services Technology & software Healthcare Communications Retail Defense contractor Industrial Professional services Services Other
  • 12. Ponemon Institute© Research Report Page 11 Table 3 lists the primary reporting channel of respondents. The most frequently cited reporting channels include the CRO (20 percent), CISO (19 percent) and CIO (14 percent). Table 3: Respondents’ reporting channel within their organization Pct% Chief Risk Officer (CRO) 20% Chief Information Security Officer (CISO) 19% Chief Information Officer (CIO) 14% Chief Security Officer (CSO) 13% Compliance/Ethics Officer 9% Director, Internal Audit 6% All other titles 6% Chief Technology Officer (CTO) 5% Chief Financial Officer (CFO) 3% General Counsel (GC) 2% GRC Leader 2% Chief Privacy Officer (CPO) 1% Total 100% Table 4 lists the worldwide headcount of organizations represented by respondents. As can be seen, the majority of organizations (57 percent) are larger-sized entities with more than 25,000 full time equivalent employees. Table 4: The worldwide headcount of respondents’ organizations Pct% Less than 500 people 4% 500 to 1,000 people 1% 1,001 to 5,000 people 12% 5,001 to 25,000 people 26% 25,001 to 75,000 people 34% More than 75,000 people 23% Total 100% Table 5 provides the global footprint of respondents’ organizations. As shown, the vast majority of respondents work for organizations that are located in the United States. Many organizations have operations in Europe (55 percent), Canada (42 percent), the Asia-Pacific region (46 percent) and Latin America (37 percent). Table 5. The global footprint of participating organizations Pct% United States 97% Canada 42% Europe 55% Middle East & Africa 31% Asia-Pacific 46% Latin America (including Mexico) 37%
  • 13. Ponemon Institute© Research Report Page 12 Part 4. Conclusion Caveats There are inherent limitations to survey research that need to be carefully considered before drawing inferences from findings. The following items are specific limitations that are germane to most web-based surveys.  Non-response bias: The current findings are based on a sample of survey returns. We sent surveys to a representative sample of GRC practitioners in various business organizations, resulting in a large number of usable returned responses. Despite non-response tests, it is always possible that auditors who did not participate are substantially different in terms of underlying beliefs from those who completed the survey.  Sampling-frame bias: The accuracy is based on contact information and the degree to which the list is representative of individuals who are members of the emerging GRC community. We also acknowledge that responses from paper, interviews or by telephone might result in a different pattern of findings.  0BSelf-reported results: The quality of survey research is based on the integrity of confidential responses received from respondents. While certain checks and balances were incorporated into our survey evaluation process, there is always the possibility that certain respondents did not provide responses that reflect their true opinions. Concluding Thoughts We believe this study reveals the importance of an enterprise-wide strategy and increased collaboration among domains to meeting eGRC objectives. Currently, only 20 percent have an enterprise-wide strategy and collaboration among GRC areas is far from perfect. Only 28 percent of respondents say their organizations enjoy frequent collaboration or cooperation among GRC areas. However, the good news is that only 12 percent say GRC areas operate in silos in their organizations. The study also demonstrates that privacy is an eGRC collaboration flashpoint. Regardless of their industry, all organizations are struggling to manage privacy regulations that must be addressed by geography and in accordance with country or state laws. Today privacy management responsibilities are typically split between the legal and IT functions. While the legal department plays a dominant privacy role overall, IT still holds accountability for implementing controls to address privacy regulations. Respondents identified their top two privacy challenges as ensuring data shared with third parties will remain safe and secure and complying with all appropriate regulations. In order to address the barriers related to collaboration, it has been recommended that organizations make it a priority to encourage people from the various lines of business to talk together and establish “risk ambassadors”. The need to gain visibility and control through effective cross-enterprise eGRC collaboration is important to reducing gaps in how risk is assessed and managed. Finally, according to respondents, managing risk is and will continue to be the biggest eGRC focus for their organizations. This is understandable because organizations are finding that the cost of complying with the plethora of regulations can be daunting. Taking a risk-based approach toward compliance requirements enables them to focus their resources on the most at-risk areas of their business and achieve real value from their eGRC activities.
  • 14. Ponemon Institute© Research Report Page 13 Appendix: Detailed Survey Findings The following tables provide the percentage frequency of responses to all survey responses completed on March 30, 2011. Sample response Freq. Total sample frame 1240 Total returns 206 Rejected surveys 16 Final sample 190 Response rate 15.3% Q1. How much of your organization’s GRC activities fall into each one of the four GRC domains? Please allocate 100 points to estimate the effort extended to each GRC domain. Pct% Finance GRC 19% IT GRC 44% Operations GRC 20% Legal GRC 17% Total 100% Q2. How important are privacy-related issues for each one of the four GRC domains? Finance GRC Pct% Very important 37% Important 41% Not important 18% Irrelevant 4% Total 100% IT GRC Pct% Very important 76% Important 23% Not important 1% Irrelevant 0% Total 100% Operations GRC Pct% Very important 46% Important 46% Not important 4% Irrelevant 4% Total 100% Legal GRC Pct% Very important 71% Important 23% Not important 2% Irrelevant 4% Total 100%
  • 15. Ponemon Institute© Research Report Page 14 Q3. What statement best describes the working relationships among finance, IT, operations and legal GRC functions in your organization today? Pct% They operate in silos (little collaboration) 12% They sometimes collaborate 56% They frequently collaborate 28% They are fully integrated 3% Cannot determine 1% Total 100% Q4. Please answer the following four statements using the scale provided next to each item. Q4a. My job is primarily focused on finance. Pct% Strongly agree 5% Agree 14% Unsure 4% Disagree 35% Strongly disagree 41% Total 100% Q4b. My job is primarily focused on IT. Pct% Strongly agree 57% Agree 20% Unsure 1% Disagree 16% Strongly disagree 5% Total 100% Q4c. My job is primarily focused on operations. Pct% Strongly agree 11% Agree 41% Unsure 9% Disagree 22% Strongly disagree 17% Total 100% Q4d. My job is primarily focused on legal and compliance issues. Pct% Strongly agree 20% Agree 47% Unsure 7% Disagree 12% Strongly disagree 14% Total 100% Q4e. My job is primarily focused on privacy issues. Pct% Strongly agree 13% Agree 47% Unsure 13% Disagree 21% Strongly disagree 7% Total 100%
  • 16. Ponemon Institute© Research Report Page 15 Q5a. How important are the following four focus areas to your job function? Please allocate 100 points to estimate the importance of focus areas to the fulfillment of your job function today. Pct% Governance 22% Risk management 32% Compliance 27% Privacy & data protection 20% Total 100% Q5b. How important are the following four focus areas to your job function? Please allocate 100 points to estimate the importance of focus areas to the fulfillment of your job function three years into the future. Pct% Governance 23% Risk management 33% Compliance 24% Privacy & data protection 21% Total 100% Q6. What job functions do you perform in your organization? Please check all that apply. Total% Corporate ethics 8% Corporate communications 5% Corporate marketing 2% E-Discovery 6% General consulting 23% General management 17% Government affairs 3% Human resources 3% Information security 71% Information technology 52% Internal audit 17% Legal department 6% Public relations 2% Privacy management 27% Risk management 77% Regulatory compliance 46% Records management 11% Total 377% Q7a. Where are governance activities located within your organization? Pct% Board of directors 5% CEO/Executive committee 17% Finance 0% Legal 7% Corporate compliance 13% Information technology (IT) 18% Public relations 0% Security & information security 6% Ethics & compliance 1% Enterprise risk management 17% Operational risk management 2% Business units 4% Human resources 0% Spread among several units 8% Other (please specify) 2% Total 100%
  • 17. Ponemon Institute© Research Report Page 16 Q7b. Where are risk management activities located within your organization? Pct% Board of directors 3% CEO/Executive committee 4% Finance 5% Legal 0% Corporate compliance 8% Information technology (IT) 14% Public relations 0% Security & information security 4% Insurance 0% Enterprise risk management 39% Operational risk management 6% Business units 6% Human resources 0% Spread among several units 5% Other (please specify) 5% Total 100% Q7c. Where are compliance activities located within your organization? Pct% Board of directors 0% CEO/Executive committee 2% Finance 3% Legal 10% Corporate compliance 43% Information technology (IT) 16% Public relations 0% Security & information security 5% Insurance 0% Enterprise risk management 4% Operational risk management 2% Business units 6% Human resources 0% Spread among several units 6% Other (please specify) 2% Total 100% Q7d. Where are privacy management activities located within your organization? Pct% Board of directors 0% CEO/Executive committee 2% Finance 0% Legal 28% Corporate compliance 14% Information technology (IT) 20% Public relations 0% Security & information security 7% Insurance 0% Enterprise risk management 12% Operational risk management 3% Business units 2% Human resources 3% Spread among several units 4% Other (please specify) 1% Privacy office 3% Total 100%
  • 18. Ponemon Institute© Research Report Page 17 Q8. Please rate all the activities that you pursue in order to meet GRC objectives or goals according to the three-point scale: (1) essential, (2) important or (3) not important. Q8a. Developing strategies Pct% Essential to GRC objectives 61% Important to GRC objectives 36% Not important to GRC objectives 3% Total 100% Q8b. Analyzing regulations Pct% Essential to GRC objectives 45% Important to GRC objectives 51% Not important to GRC objectives 4% Total 100% Q8c. Assessing risk Pct% Essential to GRC objectives 83% Important to GRC objectives 16% Not important to GRC objectives 1% Total 100% Q8d. Creating and implementing policies Pct% Essential to GRC objectives 50% Important to GRC objectives 47% Not important to GRC objectives 3% Total 100% Q8e. Training and awareness Pct% Essential to GRC objectives 43% Important to GRC objectives 49% Not important to GRC objectives 7% Total 100% Q8f. Monitoring compliance Pct% Essential to GRC objectives 63% Important to GRC objectives 38% Not important to GRC objectives 0% Total 100% Q8g. Reporting to senior management Pct% Essential to GRC objectives 60% Important to GRC objectives 36% Not important to GRC objectives 4% Total 100% Q8h. Administering program Pct% Essential to GRC objectives 44% Important to GRC objectives 52% Not important to GRC objectives 4% Total 100% Q8j. Advising or consulting within the organization Pct% Essential to GRC objectives 40% Important to GRC objectives 55% Not important to GRC objectives 5% Total 100%
  • 19. Ponemon Institute© Research Report Page 18 Q8k. Responding to incidents Pct% Essential to GRC objectives 42% Important to GRC objectives 47% Not important to GRC objectives 11% Total 100% Q9. What statement best describes your organization’s GRC strategy? Pct% Our organization has a clearly defined GRC strategy and pertains to the entire enterprise. 20% Our organization has a clearly defined GRC strategy, but it is not applicable to the entire enterprise. 47% Our organization does not have a clearly defined GRC strategy. 33% Total 100% Q10. Does your organization have the following leaders (or approximate job titles)? Please check all that apply. Pct% Chief privacy officer 67% Chief compliance officer 63% Chief ethics officer 25% Chief governance officer 14% Chief risk officer 60% Chief information security officer 81% Chief security officer 49% Total 360% Q11. Has your organization implemented technology solutions for the following GRC- related activities? Please check all that apply. Pct% Policy management 75% Risk assessment 81% Controls assessment 73% Business process mapping 25% Business process analysis 20% Data mapping 16% Document management 42% Data inventory 29% Regulatory monitoring 41% Compliance monitoring 63% Incident response & management 68% Training & awareness 53% Records management (archive) 42% E-Discovery 35% Total 663% Q12. In your opinion, how important are the above-mentioned technologies for achieving GRC-related objectives and goals in your organization? Pct% Essential 49% Very important 39% Important 11% Not important 0% Irrelevant 0% Total 100%
  • 20. Ponemon Institute© Research Report Page 19 Q13. Are your organization’s governance, risk management, compliance and privacy/data protection functions centralized or decentralized? Please use the five-point scale provided next to each focus area: Centralized – the activities or function are managed by one central authority within the enterprise. Decentralized – the activities or function are managed across units or spread among business segments. Q13a. Activities relating to governance Pct% Centralized=1 20% 2 26% 3 31% 4 13% Decentralized=5 11% Total 100% Q13b. Activities relating to risk management Pct% Centralized=1 14% 2 32% 3 26% 4 20% Decentralized=5 8% Total 100% Q13c. Activities relating to compliance Pct% Centralized=1 18% 2 36% 3 27% 4 11% Decentralized=5 7% Total 100% Q13d. Activities relating to privacy Pct% Centralized=1 22% 2 30% 3 35% 4 8% Decentralized=5 4% Total 100% Q14. What are the top two barriers to achieving your organization’s GRC-related goals? Pct% Lack of resources 52% Lack of C-level support 15% Lack of clear leadership 20% Difficulty in hiring skilled personnel 11% Inability to set priorities 19% Inability to get started (inertia) 4% Lack of cooperation and collaboration among the various departments involved in GRC 44% Major organizational changes such as mergers, downsizing, financial turmoil and others 19% Complexity of the program 3% Complexity of existing technologies 31% Inadequacy of existing technologies 3% Lack of organizational maturity 2% Other (please specify) 2% Total 224%
  • 21. Ponemon Institute© Research Report Page 20 Q15. What are your organization’s top two privacy-related challenges or issues? Pct% Curtailing data loss and theft 31% Curtailing the use of insecure data-bearing devices including smartphones and USB sticks 8% Complying with all appropriate regulations 41% Educating all personnel 37% Maintaining customer trust 15% Ensuring that data shared with third parties (including cloud providers) will remain safe and secure 51% Ensuring that policies will be strictly enforced 26% Total 208% Q16. What top three privacy or data protection regulations are most difficult to comply with? Pct% PCI DSS 47% HIPAA (including HITECH) 26% Sarbanes-Oxley 21% Gramm-Leach-Bliley (GLBA) 32% Child Online Privacy Protection Act (COPPA) 3% NERC CIP 4% Fair Information Practices (FTC) 1% Fair Credit Reporting Act (FCRA) 8% Federal Privacy Act 6% FTC Fair Information Practices 4% FISMA 11% FFIEC 1% Basil II 1% EU Data Protection Directive (including Safe Harbor) 21% Various US state privacy and data protection laws 35% Various international privacy and data protection laws 17% Other (please specify) 8% Total 247% Q17. Where did your organizations GRC program or initiatives start? Pct% Information technology 63% Operations 12% Finance 13% Legal 13% Total 100%
  • 22. Ponemon Institute© Research Report Page 21 Demographics & organizational characteristics D1. What organizational level best describes your current position? Pct% Senior Executive 3% Vice President 12% Director 19% Manager 28% Associate/Staff 26% Technician 4% Consultant 2% Other (please specify) 6% Total 100% D2. Select the primary person you report to within the organization. Pct% CEO/Executive Committee 0% Chief Financial Officer 3% General Counsel 2% Chief Information Officer 14% Compliance/Ethics Officer 9% Chief Technology Officer 5% CSO 13% Chief Risk Officer 20% CISO 19% Chief Privacy Officer 1% Director, Internal Audit 6% GRC Leader 2% Other (please specify) 6% Total 100% D3. Select the secondary person you report to within the organization (or leave blank if you do not have a secondary or dotted line reporting relationship). Pct% CEO/Executive Committee 3% Chief Financial Officer 2% General Counsel 3% Chief Information Officer 11% Compliance/Ethics Officer 3% Chief Technology Officer 3% CSO 8% Chief Risk Officer 7% CISO 8% Chief Privacy Officer 2% Director, Internal Audit 2% Other (please specify) 3% Blank 43% Total 100% D4. Gender: Pct% Male 70% Female 30% Total 100%
  • 23. Ponemon Institute© Research Report Page 22 D5. What industry best describes your organization’s primary industry? Pct% Communications 3% Defense contractor 2% Education & research 0% Financial services 51% Healthcare 13% Hospitality 0% Industrial 2% Pharmaceuticals 1% Professional services 2% Public sector 1% Retail 3% Services 2% Technology & software 15% Transportation 1% Utilities & energy 1% Media 1% Other (please specify) 1% Total 100% D6. Where are your employees located? Please check all regions that apply. Pct% United States 97% Canada 42% Europe 55% Middle East & Africa 31% Asia-Pacific 46% Latin America (including Mexico) 37% Total 308% D7. What is the worldwide headcount of your organization? Pct% Less than 500 people 4% 500 to 1,000 people 1% 1,001 to 5,000 people 12% 5,001 to 25,000 people 26% 25,001 to 75,000 people 34% More than 75,000 people 23% Total 100%
  • 24. Ponemon Institute© Research Report Page 23 Ponemon Institute Advancing Responsible Information Management Ponemon Institute is dedicated to independent research and education that advances responsible information and privacy management practices within business and government. Our mission is to conduct high quality, empirical studies on critical issues affecting the management and security of sensitive information about people and organizations. As a member of the Council of American Survey Research Organizations (CASRO),we uphold strict data confidentiality, privacy and ethical research standards. We do not collect any personally identifiable information from individuals (or company identifiable information in our business research). Furthermore, we have strict quality standards to ensure that subjects are not asked extraneous, irrelevant or improper questions.