GRC Governance, Risk, and Compliance Implementation Checlist By InfosecTrain.pdf

In today’s business landscape, growth, cybersecurity threats, and regulatory obligations are tightly interconnected. To remain resilient and trusted, organizations need more than isolated controls — they need a structured framework that brings Governance, Risk Management, and Compliance (GRC) together.

🔹 Governance – setting direction, accountability, and ethical decision-making
🔹 Risk Management – identifying and mitigating threats that could disrupt business objectives
🔹 Compliance – ensuring adherence to regulations and standards (ISO 27001, NIST, SOX, GDPR, COBIT, etc.)

1. GRC
(Governance, Risk, and Compliance)
Implementation Checklist
Checklist

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Introduction
Organizations today operate in an environment where business
growth, cybersecurity threats, and regulatory obligations are tightly
interconnected. To stay resilient and trustworthy, companies need a
structured way to align strategic goals with operational safeguards
and legal requirements. This is where Governance, Risk Management,
and Compliance (GRC) comes in.
•Governance ensures leadership sets direction, defines accountability,
and drives ethical decision-making.
•Risk Management identifies and mitigates threats or uncertainties
that could disrupt objectives, from cyberattacks to operational
failures.
•Compliance ensures adherence to laws, regulations, and
frameworks such as ISO 27001, NIST, SOX, GDPR, and COBIT.
A well-designed GRC program not only prevents penalties and
reputational damage but also:
•Strengthens stakeholder confidence
•Embeds a risk-aware culture
•Improves transparency and decision-making
•Aligns IT, business operations, and strategic objectives

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Checklist Item
Define GRC objectives
and scope
Explanation
Notes / Evidence
Governance
•Establish a clear GRC framework aligned
with business objectives and regulatory
obligations.
•Define the scope of your GRC program
(which business units, IT systems, and
regulations are in scope) and set specific
goals for governance, risk, and
compliance activities
Executive Sponsorship
and Oversight
•Secure top management support and
board-level oversight for GRC initiatives.
•Assign executive accountability (e.g. a
CISO, CRO, or compliance officer) and
form a cross-functional GRC steering
committee to evaluate, direct, and
monitor GRC efforts.
Roles and
Responsibilities
•Define and document GRC roles across
the organization to ensure accountability.
•Designate key personnel such as a Chief
Information Security Officer (CISO) for
security, a Data Protection Officer (DPO)
if handling EU personal data, and
compliance officers for SOX/financial
controls where applicable.
•Clearly allocate responsibilities to IT,
security, legal, finance, and operational
teams for managing risks and compliance
in their domains
Governance Policies
and Frameworks
•Develop a suite of governance policies,
procedures, and standards that guide
organizational behavior and align with
industry frameworks.
•This includes an Information Security
Policy (per ISO 27001) supported by
topic-specific policies (access control,
incident response, acceptable use, etc.), a
Code of Conduct/Ethics policy, data
privacy policies, and IT governance
policies (as advocated by COBIT).
Strategic Alignment
and Risk Appetite
•Align IT governance and security strategy
with the enterprise’s business strategy
and risk appetite. Use frameworks like
COBIT to ensure IT projects and controls
deliver value and support business goals.
•The board and executives should define a
risk appetite; the level and types of risk
the organization is willing to accept, and
governance processes must ensure that
risk-taking remains within these bounds.

4. •Establish a clear GRC framework aligned
with business objectives and regulatory
obligations.
•Define the scope of your GRC program
(which business units, IT systems, and
regulations are in scope) and set specific
goals for governance, risk, and
compliance activities
•Secure top management support and
board-level oversight for GRC initiatives.
•Assign executive accountability (e.g. a
CISO, CRO, or compliance officer) and
form a cross-functional GRC steering
committee to evaluate, direct, and
monitor GRC efforts.
•Define and document GRC roles across
the organization to ensure accountability.
•Designate key personnel such as a Chief
Information Security Officer (CISO) for
security, a Data Protection Officer (DPO)
if handling EU personal data, and
compliance officers for SOX/financial
controls where applicable.
•Clearly allocate responsibilities to IT,
security, legal, finance, and operational
teams for managing risks and compliance
in their domains
•Develop a suite of governance policies,
procedures, and standards that guide
organizational behavior and align with
industry frameworks.
•This includes an Information Security
Policy (per ISO 27001) supported by
topic-specific policies (access control,
incident response, acceptable use, etc.), a
Code of Conduct/Ethics policy, data
privacy policies, and IT governance
policies (as advocated by COBIT).
•Align IT governance and security strategy
with the enterprise’s business strategy
and risk appetite. Use frameworks like
COBIT to ensure IT projects and controls
deliver value and support business goals.
•The board and executives should define a
risk appetite; the level and types of risk
the organization is willing to accept, and
governance processes must ensure that
risk-taking remains within these bounds.
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Checklist Item
Training and
Awareness
Explanation
Notes / Evidence
Governance
•Implement a comprehensive GRC training
and awareness program. Conduct regular
training for all staff on security policies,
data protection (privacy requirements),
and corporate ethics/compliance obliga-
tions.
•Tailor training to roles (e.g. developers
get secure coding training, finance team
gets SOX/internal controls training, all
employees receive privacy and
anti-phishing training).
Ethical Standards
and Culture
•Establish and enforce ethical standards as
part of governance. Publish a Code of
Ethics/Conduct and require annual
attestation from employees.
•Set up mechanisms for reporting unethical
behavior or compliance concerns (e.g. an
anonymous whistleblower hotline or
ethics line, as mandated by SOX) without
fear of retaliation.
Performance Monitoring
and Reporting
•Define key metrics and indicators for
governance (e.g. policy compliance rates,
training completion, number of ethics
reports), risk (risk heat maps, incidents,
audit findings), and compliance
(compliance scorecards, regulatory
issues).
•Use GRC tools or dashboards to track
these metrics and provide timely reports
to senior management and the board. For
example, NIST’s GRC guidance
emphasizes continuous oversight and
improvement based on data-driven
insights.
Communication and
Transparency
•Foster open communication about
governance and compliance matters
internally and (when appropriate)
externally.
•Internally, encourage teams to raise risk
concerns or compliance questions
promptly.
•Provide updates to employees about
major policy changes, incident learnings,
and improvements.
•Externally, be transparent with
stakeholders (investors, regulators,
customers) about the organization’s
GRC posture; e.g. publish security
certifications or audit compliance letters,
and disclose significant incidents as
required by law.

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Checklist Item Explanation Notes / Evidence
Governance
Checklist Item
Continuous
Improvement and
Governance Review
Explanation
Notes / Evidence
•Treat GRC as a continuous, iterative
process.
•Conduct periodic governance reviews and
maturity assessments to identify areas for
improvement in your GRC framework.
(For example, ISO 27001 requires
organizations to perform regular internal
audits and management reviews of the
ISMS, ensuring that leadership evaluates
the effectiveness of policies, controls, and
risk treatments and drives
improvements.)

6. •Treat GRC as a continuous, iterative
process.
•Conduct periodic governance reviews and
maturity assessments to identify areas for
improvement in your GRC framework.
(For example, ISO 27001 requires
organizations to perform regular internal
audits and management reviews of the
ISMS, ensuring that leadership evaluates
the effectiveness of policies, controls, and
risk treatments and drives
improvements.)
Checklist Item
Asset Inventory
and Classification
Explanation
Notes / Evidence
Risk Management
•Identify and catalog critical assets
(information, software, hardware,
processes, and third-party services) and
assign owners to each.
•Classify assets based on sensitivity and
importance (e.g. public vs. confidential
data, mission-critical systems vs.
low-impact systems).
Risk Assessment
Process
•Conduct thorough risk assessments on a
regular schedule (at least annually, and
for major changes) to identify threats,
vulnerabilities, and potential impacts to
the organization.
•Use a structured methodology (e.g.
ISO 27005, NIST SP 800-30, or COSO
ERM) to evaluate the likelihood and
impact of identified risks, including
cybersecurity risks, operational
disruptions, and compliance risks.
Document the results in a risk register.
•Develop and implement risk treatment
plans for identified risks, choosing one or
more strategies: mitigate (apply security
controls or process changes), transfer
(insurance or outsourcing), accept, or
avoid the risk.
•Prioritize risk mitigation based on the
risk’s severity and the organization’s risk
appetite.
•For significant risks, assign clear action
items and owners with target dates.
Implement appropriate controls drawn
from frameworks like ISO 27001 Annex A
controls or NIST SP 800-53 to reduce risk
to acceptable level.
Risk Treatment and
Mitigation
Security Controls and
Framework Alignment
•Ensure a baseline of security and
internal controls is in place and mapped
to industry frameworks including
technical controls (firewalls, encryption,
multi-factor authentication, intrusion
detection, regular patching) and
organizational controls (segregation of
duties, change management,
background checks) that collectively
address known risk areas.
•Utilize overlapping controls from
multiple standards; for example,
requirements for access control, incident
response, and data backup appear in
ISO 27001, NIST, COBIT, and SOX IT
controls.
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Checklist Item
Continuous Monitoring
and Vulnerability
Management
Explanation
Notes / Evidence
Risk Management
•Implement continuous risk monitoring
processes like ongoing vulnerability
scanning, penetration testing, system
configuration monitoring, and
logging/alerting on security events to
promptly detect changes in the threat
landscape or control effectiveness.
•Patch critical vulnerabilities and update
systems in a timely manner to address
known issues (many compliance
frameworks require a formal patch
management program).
Incident Response
Preparedness
•Develop an Incident Response Plan
detailing how to handle security
breaches, outages, data leaks, or other
crises. The plan should define incident
roles (e.g. incident manager,
communications lead), escalation paths,
and procedures for triage, containment,
eradication, recovery, and post-incident
analysis.
•Test the incident response plan regularly
through drills or tabletop exercises to
ensure it remains effective.
Business Continuity
and Disaster Recovery
•Implement Business Continuity Plans
(BCP) and Disaster Recovery Plans (DRP)
to maintain or quickly restore critical
operations in the event of a major
disruption (e.g. natural disaster, cyber-at-
tack, pandemic).
•Identify key business processes and
resources required to keep them running,
and develop workarounds or recovery
solutions for different outage scenarios.
•Test BCP/DR plans periodically (at least
annually) through simulations or failover
tests, and address any gaps. Effective
continuity planning is mandated by
ISO 27001 (Annex A.17) to preserve
information security during adverse
events.

8. •Implement continuous risk monitoring
processes like ongoing vulnerability
scanning, penetration testing, system
configuration monitoring, and
logging/alerting on security events to
promptly detect changes in the threat
landscape or control effectiveness.
•Patch critical vulnerabilities and update
systems in a timely manner to address
known issues (many compliance
frameworks require a formal patch
management program).
•Develop an Incident Response Plan
detailing how to handle security
breaches, outages, data leaks, or other
crises. The plan should define incident
roles (e.g. incident manager,
communications lead), escalation paths,
and procedures for triage, containment,
eradication, recovery, and post-incident
analysis.
•Test the incident response plan regularly
through drills or tabletop exercises to
ensure it remains effective.
•Implement Business Continuity Plans
(BCP) and Disaster Recovery Plans (DRP)
to maintain or quickly restore critical
operations in the event of a major
disruption (e.g. natural disaster, cyber-at-
tack, pandemic).
•Identify key business processes and
resources required to keep them running,
and develop workarounds or recovery
solutions for different outage scenarios.
•Test BCP/DR plans periodically (at least
annually) through simulations or failover
tests, and address any gaps. Effective
continuity planning is mandated by
ISO 27001 (Annex A.17) to preserve
information security during adverse
events.
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Checklist Item
Third-Party and
Supply Chain Risk
Explanation
Notes / Evidence
Risk Management
•Catalog all third parties that handle your
critical systems or sensitive data and
assess their security posture and
compliance status (e.g. through vendor
risk assessments or requiring SOC
2/ISO 27001 certifications).
•Establish contractual requirements for
security and privacy (for instance, Data
Processing Agreements under GDPR
with any data processors) and ensure
third parties are aware of their
obligations.
Risk Communication
and Escalation
•Integrate risk management into
organizational decision-making by
establishing clear reporting and
escalation processes.
•Use risk committees or working groups to
review risk assessment results and
decide on risk responses.
•Ensure that there is a process to escalate
issues that exceed the organization’s risk
appetite or indicate control failures (e.g. a
major compliance violation or data breach
would trigger an immediate executive
review).
Periodic Risk Review
and Update
•Schedule regular reviews (e.g. quarterly
or semi-annually) of the risk landscape
and the effectiveness of risk management
initiatives.
•Update risk assessments to account for
changes such as new business lines,
emerging threats (like zero-day
vulnerabilities or new fraud schemes), or
changes in regulations.
•Adjust risk mitigation strategies and
controls based on these reviews, and
track progress on risk reduction over time.

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Checklist Item
Regulatory
Requirements
Identification
Explanation
Notes / Evidence
Compliance
•Identify all laws, regulations, standards,
and contractual obligations (ISO 27001 for
information security, NIST CSF/800-53 for
cybersecurity (especially for U.S.
government contractors), SOX for financial
reporting controls (public companies in the
U.S.), GDPR for personal data protection in
the EU, and COBIT for IT governance) that
apply to the organization across
jurisdictions (U.S., EU, and globally).
•Maintain a compliance obligations register
that documents each requirement, the
responsible owner, and how the
organization meets it.
Compliance Framework
and Control Mapping
•Establish a compliance management
framework that maps these requirements
to internal controls and policies, avoiding
duplicate efforts for overlapping
mandates.
•Utilize a unified control framework or
matrix to consolidate controls that satisfy
multiple frameworks.
Policies, Procedures
and Documentation
•Create documented procedures and
guidelines, such as SOPs for GDPR data
subject requests or a SOX financial
controls handbook, to effectively
operationalize compliance obligations.
•Ensure that all compliance-related
activities are well documented; “if it is not
documented, it did not happen.”
•Maintain evidence of control
performance, such as access logs, change
management tickets, training attendance
records, audit trail logs, etc.
Data Protection and
Privacy Compliance
•Implement robust data privacy measures
in line with GDPR and other privacy laws
(such as CCPA in California).
•Maintain an inventory of personal data
processed and document the lawful basis
for processing each category of data
(consent, legitimate interest, etc.).
•Enforce data minimization and retention
limits (collect only what is needed and
retain data only as long as required).
•Ensure individuals’ rights under GDPR
are supported: have processes for
fulfilling data subject access or deletion
requests, rectifying data on request, and
handling objections/restrictions.
•Embed “privacy by design” into projects;
perform Data Protection Impact Assess-
ments (DPIAs) for high-risk personal data
projects and incorporate privacy controls
from the start."

10. •Identify all laws, regulations, standards,
and contractual obligations (ISO 27001 for
information security, NIST CSF/800-53 for
cybersecurity (especially for U.S.
government contractors), SOX for financial
reporting controls (public companies in the
U.S.), GDPR for personal data protection in
the EU, and COBIT for IT governance) that
apply to the organization across
jurisdictions (U.S., EU, and globally).
•Maintain a compliance obligations register
that documents each requirement, the
responsible owner, and how the
organization meets it.
•Create documented procedures and
guidelines, such as SOPs for GDPR data
subject requests or a SOX financial
controls handbook, to effectively
operationalize compliance obligations.
•Ensure that all compliance-related
activities are well documented; “if it is not
documented, it did not happen.”
•Maintain evidence of control
performance, such as access logs, change
management tickets, training attendance
records, audit trail logs, etc.
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Checklist Item
Financial Controls
and SOX Compliance
Explanation
Notes / Evidence
Compliance
•For publicly traded companies (or those
pursuing IPO), maintain a strong internal
control environment over financial
reporting in line with Sarbanes-Oxley
(SOX) requirements.
•Ensure controls are in place for key
financial processes: e.g. access controls
over financial systems, segregation of
duties in accounting, controls over financial
data changes, reconciliation processes, and
anti-fraud measures.
Industry-Specific and
Regional Compliance
•Ensure adherence to all industry- and
region-specific regulations, such as
HIPAA, GLBA, FedRAMP, NIST 800-171,
DORA, and applicable Environmen-
tal/ESG requirements.
•If operating in multiple EU countries,
monitor local data protection laws that
implement GDPR (or additional
requirements like Germany’s BDSG).
Third-Party Compliance
Management
•Conduct due diligence to ensure that
vendors who process your data or
support critical operations comply with
relevant regulations and your security
requirements.
•Maintain an updated list of all such third
parties and the compliance assurances
they provide. Regulators increasingly
expect that organizations ensure their
vendors and supply chain meet
equivalent compliance standards; for
example, banking regulators require
oversight of outsourced service providers.
Awareness and
Compliance Training
•Provide recurring, role-based compliance
training—covering areas like cybersecuri-
ty hygiene, GDPR privacy, anti-money
laundering, and ethics—while tracking
staff completion to ensure awareness of
obligations.
Internal Audits and
Self-Assessments
•Conduct regular internal audits or
self-assessments; such as ISO 27001
ISMS audits and SOX control testing, to
verify compliance, ensure control
effectiveness, and provide independent
assurance as the third line of defense.
•Use internal audit or an independent
compliance team as the “third line of
defense” to provide assurance on
governance and risk management
processes.
•Document all findings and remediations.
Where issues are found (e.g. a control
failure or a policy not followed), require
corrective action plans and track them to
completion.

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Checklist Item
External Audits
and Certifications
Explanation
Notes / Evidence
Compliance
•Undergo independent audits or
certifications; such as ISO 27001, SOX
404, SOC 2 Type II, or regulatory
examinations, to validate compliance and
demonstrate adherence to industry best
practices.
Documentation of
Compliance Activities
•Thoroughly document and retain all GRC
and compliance activities; such as risk
assessments, control evidence, training
logs, audit reports, committee minutes,
incident records, and regulator
communications, as proof of due
diligence.
•Use a document management or GRC
system to keep these records up-to-date
and accessible to authorized personnel.
•Regularly review and purge documents
as per retention policies (for instance,
financial records might be kept for 7
years under SOX).
Ongoing Regulatory
Monitoring
•Stay updated on changes in the
regulatory environment and emerging
compliance risks. Assign responsibility
(e.g. to the compliance officer or legal
department) for monitoring new laws,
regulations, or standards that may impact
the organization.
•When changes occur, update your
compliance program accordingly; revise
policies, train staff on new requirements,
and implement new controls as needed.

12. •Thoroughly document and retain all GRC
and compliance activities; such as risk
assessments, control evidence, training
logs, audit reports, committee minutes,
incident records, and regulator
communications, as proof of due
diligence.
•Use a document management or GRC
system to keep these records up-to-date
and accessible to authorized personnel.
•Regularly review and purge documents
as per retention policies (for instance,
financial records might be kept for 7
years under SOX).
•Stay updated on changes in the
regulatory environment and emerging
compliance risks. Assign responsibility
(e.g. to the compliance officer or legal
department) for monitoring new laws,
regulations, or standards that may impact
the organization.
•When changes occur, update your
compliance program accordingly; revise
policies, train staff on new requirements,
and implement new controls as needed.
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