ACR 2 Basic

Automated Compliance Reporting 2

Automated Compliance Reporting 2 (ACR2) is a family of interrelated software packages that allow automated updating of mandatory compliance reports for the twenty million organizations regulated under any combination of the below four regulations:

  1. Gramm Leach Bliley Act (GLBA) of 1999
  2. Health Insurance Portability and Accountability Act (HIPAA) of 1996
  3. Payment Card Industry Data Security Standard (PCI) of 2006
  4. The Federal Information Security Management Act (FISMA) of 2002

There is significant confusion about the dividing line between compliance and security. They are related but distinct. Compliance involves meeting the "standard of care" set by whatever regulatory authority oversees an organization. Security is keeping unauthorized persons away from accessing, corrupting or destroying sensitive data. Figure 1

What are Organizations Legally Required to Do About Information Security?

More than 20 million organizations worldwide are regulated under GLBA, HIPAA or PCI information security requirements. None of these regulations require organizations to be perfectly secure. All of these regulations require organizations to be compliant with similar, specific rules and regulations. There are penalties for non-compliant purchase card (PCI) vendors can be penalized or disqualified from handling credit cards. Enforcement of information security regulations is increasing, driven by significant political pressure and epidemic of identity theft.

For Any Security Compliance Program, Risk Assessment is the Beginning

GLBA, HIPAA and PCI all require regulated companies to perform a risk assessment and then take "appropriate" precautions against "reasonably foreseeable" risks. For example quoting from the Gramm Leach Bliley Act (GLBA):

"Information security program.. You shall develop, implement and maintain a comprehensive information security program ... Appropriate to your size... Identify reasonably foreseeable> internal and external risks... and assess the sufficiency of any safeguards in place... At a minimum, such a risk assessment should include... (1) Employee training and management; (2) Information systems, including.. (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures... Design and implement information safeguards to control the risks you identify through risk assessment, and regularly test.." (emphasis added)
Figure 2

In the case of HIPAA, GLBA and PCI, there are five common compliance requirements. These regulations require organizations to:

  1. perform a risk assessment
  2. setup an information security plan
  3. install and test the installed safeguards
  4. revise the risk assessment accordingly
  5. report the test results

This process is shown graphically below.

Figure 3

The next step in compliance is to determine how to perform the necessary steps. The National Institute of Standards and Technology (NIST) has published a series of protocols that govern risk assessments and minimum precautions for government systems. These protocols are mandatory for use by the FDIC and other Federal regulators, and recommended for financial and medical companies by such regulators as FFIEC and CMS. The protocols are also long, complex and confusing. For example more than 90 NIST protocols relate to minimum safeguards under FISMA.

The ACR2 Solution

ACR 2 Solutions, Inc. has created a product that does to compliance regulations what tax programs do to Federal and State tax law. We have converted complex regulations into a straightforward fill-in-the-blank software package. These programs meet the risk assessment and updating tasks required under GLBA, HIAA, and PCI DSS and similar regulations (see items 1, 4, and 5 in the diagram above). Step 2, setting up security programs based on the risk assessment. This is where our included gap report and supplemental guidance can help your IT staff or MSP prioritize. Step 3. Installing and testing safeguards A key element in using ACR2 solutions is that all the safeguards and protocols used by the ACR2 progams are based on Federal recommendations and requirements. The programs reporters have been audited and accepted by the OCC and the FFIEC.

Getting Started

To use ACR2Basic just browse to our website and enter your user-id and password and start answering the questions. When you complete the questionnaire press the finalize button. Your encrypted pdf reports are emailed to you. It couldn't be faster or easier!

Figure 4
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