Continuous compliance monitoring

1) What is continuous compliance monitoring

• Reduce manual checks and the human factor.
• Reduce TTD/MTTR violations.
• Provide "audit-ready" state at any time.
• Accelerate change through policy-as-code.

2) Scope of CCM

Accesses and Identities (IAM/IGA): SoDs, redundant roles, "owner-less accesses."

Data and privacy: retention/TTL, masking, Legal Hold, DSAR-SLA.
Infrastructure/cloud/IaC: configuration drift, encryption, segmentation.
Product/code/CI-CD: secrets in repositories, SCA/SAST/DAST, OSS licenses.
Transactions/AML: sanction/PEP screening, anomaly rules, STR/SAR.
Operations: audit logs, backup and recovery, vulnerabilities.

3) CCM Reference Architecture

1. Signal collection: agents and connectors (cloud, database, logs, SIEM, IAM, CI/CD, DLP, mail/chat archives).

2. Normalization and enrichment: event bus (Kafka/Bus) + ETL/ELT in Compliance showcases.

3. Policies-as-code (CaC): YAML/Rego repository of policies with versions, tests, and reviews.

4. Rules engine (stream/batch): calculates violations, priority and risk rate.

5. Orchestration: ticketing/SOAR + RACI escalation, auto-remediation, SLA exposure.

6. Evidence/WORM: immutable artifacts (logs, config shots, reports).

7. Dashboards and reporting: heatmap, KPI/SLO, regulatory uploads.

4) Policies-as-code: mini-diagrams

yaml id: IAM-SOD-007 title: "Prohibition of toxic combination of roles: finance_approver + vendor_onboarder"
scope: ["iam:"]
detect:
query: iam_sod_violations_last_1h. sql severity: high notify: ["GRC","SecOps"]
remediate:
playbook: revoke_extra_role sla:
detect_minutes: 15 remediate_hours: 24 evidence:
sink: s3://evidence/iam-sod/dt={{ts}}
owners: ["IGA","FinanceOps"]

yaml id: GDPR-RET-001 title: "TTL 24м для PI; LegalHold priority"
rule: "object. age_months <= 24          object. legal_hold == true"
detect:
job: retention_scan_daily sla: { detect_minutes: 60, remediate_days: 7 }

5) Standard controls by standards

6) Metrics and SLO

Coverage:% of systems/data under monitoring (target ≥ 90%).
MTTD/MTTR controls: mean time to detection/elimination.

Drift Rate: drift configurations/month

False Positive Rate: The rate of false positives by rules.
Audit Readiness Time: evidence preparation time (target - hours).
DSAR SLA:% closed on time; median response.
Access Hygiene: share of obsolete rights; closing SoD violations.

7) CCM Processes (SOPs)

1. Identification of requirements → matrix "standard → control → metric."

2. Rule design → policy-as-code, tests, PR/review, versioning.
3. Deployment → staging validation, then prod with feature flag.
4. Monitoring and alerts → prioritization (sev/impact), noise cancellation, deduplication.
5. Remediation → auto-playbooks + tickets to owners; SLA escalations.
6. Evidence → periodic images; WORM/immutability; hash summaries.
7. Revaluation → quarterly tuning of rules, analysis of FPR/TPR, A/B comparisons.
8. Training → onboarding of control owners, instructions and waivers.

8) Alert life cycle

Detect → Triage → Assign → Remediate → Verify → Close → Learn.
For each step are recorded: owner, deadline, measures taken, artifacts of evidence.

9) Integrations

GRC - requirements, risks, controls, review campaigns, artifact storage.
SIEM/SOAR - event correlation, automatic playbooks.
IAM/IGA - appraisals, SoD, RBAC/ABAC, access life cycle.
CI/CD/DevSecOps - compliance gates, SAST/DAST/SCA, secret scan.
Data Platform - "Compliance" showcases, catalog/lineage, masking.
DLP/EDRM - sensitivity labels, exfiltration inhibition, logs.
Ticketing/ITSM - SLAs, escalations, owner and team reports.

10) Dashboards (minimum set)

Compliance Heatmap (systems × regulations × status).
SLA Center (DSAR/AML/PCI/SOC2 deadlines, delays).
Access & SoD (toxic roles, "forgotten" access).
Retention & Deletion (TTL violations, Legal Hold locks).
Infra/Cloud Drift.
Incidents & Findings (repetition trends, remediation efficiency).

11) Example rules (SQL/pseudo)

sql
SELECT user_id, dataset, created_at
FROM pi_objects
WHERE age_months(created_at) > 24
AND legal_hold = false;

sql
SELECT u. id, r1. role, r2. role
FROM user_roles r1
JOIN user_roles r2 ON r1. user_id = r2. user_id
JOIN users u ON u. id = r1. user_id
WHERE r1. role = 'finance_approver' AND r2. role = 'vendor_onboarder';

12) Roles and RACI

13) Exception management (waivers)

Formal request with justification and expiry date.
Risk assessment and compensatory controls.
Auto reminder of revision.
Reporting (transparency for the auditor).

14) Privacy and security in CCM

Minimizing data in storefronts and logs (PII edition).
Separation of duties, least privileges.
Immutability (WORM/S3 Object Lock) для evidence.
Cryptographic fixation of reports (hash chains).
Access control and logging to artifacts.

15) Checklists

Start CCM

• Matrix "standard → control → metric" is agreed.
• Key signal sources are connected.
• Policies are described by code, covered by tests and reviews.
• Dashboards and alerts included; SLO/SLA defined.
• The evidence (immutability) archive is configured.
• Trained owners; waivers process defined.

Before Audit

• Updated versions of policies and changes.
• A dry-run of the evidence selection was run.
• Remediation and exception delinquencies are closed.
• Coverage/MTTD/MTTR/Drift metrics are reconciled.

16) Antipatterns

"Audits to audit" instead of permanent controls.
Noisy rules without prioritization and deduplication.
Policies without versioning and tests.
Monitoring without owners and SLAs.
Evidence in changeable places/without hash fixation.

17) CCM Maturity Model (M0-M4)

M0 Manual: sporadic checks, reports in Excel.
M1 Instrumental: partial telemetry, one-time rules.
M2 Autodetect: continuous checks, basic SLOs and alerts.
M3 Orchestrated: SOAR, auto-remediation, "audit-ready" any day.
M4 Continuous Assurance: Checks in SDLC/Sales + Auditor Self-Service.

18) Related wiki articles

Compliance and reporting automation

Legal Hold and Data Freeze

Privacy by Design and Data Minimization

Data Retention and Deletion Schedules

PCI DSS/SOC 2 Control and Certification

Incident management and forensics

Total

CCM is the "pulse of conformity" of an organization: policies are expressed by code, signals flow continuously, violations are visible instantly, evidence is collected automatically, and auditing turns into an operational routine, not a fire.