Risk Control Measures

If every risk ends up as “mitigate,” you don’t have a strategy; you have a habit. 5 Risk Response Strategies — what good looks like in TPRM 1) AVOID - Use when: Risk > appetite, remediation is impractical, or exposure is structural (e.g., vendor’s data residency can’t meet policy). - Playbook: Stop onboarding / exit the relationship, pivot to an approved provider, document rationale to the Risk Committee. - Contract levers: Termination for regulatory non-compliance, unacceptable subcontractors, data location violations. - Signals you’re right: Critical requirement cannot be satisfied within policy; switching cost < risk cost. 2) REDUCE - Use when: Risk > appetite but can be lowered to acceptable levels with controls. - Playbook: Define a remediation plan with dates/owners; add Compensating Controls (e.g., data minimization, tokenization). - Contract levers: Security addendum, specific control obligations (SOC 2 Type II, encryption key ownership), right to retest. - Measure: Residual risk score drops below threshold; mean time to remediate (MTTR) < agreed SLA. 3) TRANSFER - Use when: Risk is insurable or contractually allocable (but not eliminable). - Playbook: Shift financial impact via cyber insurance, liability caps carved out for confidentiality, strong indemnities; require vendor’s insurance limits to match your exposure. - Contract levers: Indemnity for data breach/IP infringement, carve-outs to caps for willful misconduct/PII, subprocessor “flow-down” obligations. - Measure: Coverage adequacy vs. modeled loss; vendor provides current COI; claim scenarios tested in a tabletop. 4) ACCEPT - Use when: Residual risk ≤ appetite, cost to treat > benefit, and there’s a clear owner. - Playbook: Record decision, name the accountable exec, set review cadence, add telemetry to catch drift. - Guardrails: Time-boxed acceptance, no-go zones (e.g., customer PII, critical ops), exit triggers. - Measure: Risk register entry with next review date; monitoring shows no adverse trend. 5) PURSUE - Use when: There’s upside to taking managed risk (speed, cost, innovation) and controls are in place. - Playbook: Pilot with scoped data, staged gates, and success metrics; expand only if KPIs and control tests pass. - Contract levers: Safe-harbor pilots, performance credits, step-up controls at each phase. - Measure: Benefit realized vs. risk taken (e.g., cycle-time reduction, detection coverage). If your team picks “mitigate” by default, try this framework for one vendor this week and compare outcomes. The quality of your decision, not the length of your questionnaire, drives resilience. #ThirdPartyRisk #VendorRisk #OperationalResilience #RiskManagement #CyberSecurity #AI #ModelRisk #Governance #Contracts #TPRM #3prm

𝗛𝗶𝗲𝗿𝗮𝗿𝗰𝗵𝘆 𝗼𝗳 𝗖𝗼𝗻𝘁𝗿𝗼𝗹𝘀 𝗳𝗼𝗿 𝗛𝗮𝘇𝗮𝗿𝗱𝗼𝘂𝘀 𝗦𝘂𝗯𝘀𝘁𝗮𝗻𝗰𝗲𝘀 Managing hazardous substances in the workplace is critical to safeguarding employees' health and safety. The hierarchy of controls is a structured framework that prioritises strategies to mitigate risks. This approach ensures that the most effective measures are implemented first, offering a robust defence against workplace hazards. Here's how it applies to hazardous substances: 𝟭. 𝗘𝗹𝗶𝗺𝗶𝗻𝗮𝘁𝗶𝗼𝗻 The most effective control measure is to completely remove the hazardous substance. For example, substituting a toxic cleaning solvent with a safer alternative eliminates the risk entirely. 𝟮. 𝗦𝘂𝗯𝘀𝘁𝗶𝘁𝘂𝘁𝗶𝗼𝗻 Replace the hazardous substance with a less harmful one. A practical example is using water-based paints instead of solvent-based paints, which reduces the exposure to harmful fumes. 𝟯. 𝗘𝗻𝗴𝗶𝗻𝗲𝗲𝗿𝗶𝗻𝗴 𝗖𝗼𝗻𝘁𝗿𝗼𝗹𝘀 Implement physical changes to the workplace to minimise exposure. Examples include: Installing local exhaust ventilation systems to capture fumes and dust at the source. Designing enclosed processes to limit direct contact with hazardous substances. 𝟰. 𝗔𝗱𝗺𝗶𝗻𝗶𝘀𝘁𝗿𝗮𝘁𝗶𝘃𝗲 𝗖𝗼𝗻𝘁𝗿𝗼𝗹𝘀 Focus on changing work practices and procedures to reduce exposure. Key measures include: Implementing safe handling protocols. Providing comprehensive training to employees on risks and preventive measures. Rotating tasks to limit individual exposure duration. 𝟱. 𝗣𝗲𝗿𝘀𝗼𝗻𝗮𝗹 𝗣𝗿𝗼𝘁𝗲𝗰𝘁𝗶𝘃𝗲 𝗘𝗾𝘂𝗶𝗽𝗺𝗲𝗻𝘁 (𝗣𝗣𝗘) As a last line of defence, use PPE to protect workers when other measures are not feasible. This includes respirators, gloves, goggles, and protective clothing suited to the specific substance. 𝗪𝗵𝘆 𝗣𝗿𝗶𝗼𝗿𝗶𝘁𝗶𝘀𝗲 𝘁𝗵𝗲 𝗛𝗶𝗲𝗿𝗮𝗿𝗰𝗵𝘆? The hierarchy ensures proactive risk management, focusing on prevention rather than merely reacting to incidents. While PPE is vital, it should never be the sole reliance, as its effectiveness depends on proper usage and maintenance.

Are you struggling to select the right controls for your AI risks? I've built a framework that maps 160+ controls to the kinds of risks that many AI systems face. If you found my previous controls mega-map useful, then I think you'll find this even more valuable. In my most recent article, I'm now sharing this systematic approach to selecting effective controls for the most common AI risks you'll face. This isn't theoretical guidance—this is a thorough catalogue and checklist you can use. It lists proven controls for preventive, detective, and response measures both for design-time and during system operation. I break down eight critical AI risks including: 📉 Model drift and data distribution shift 💭 Hallucinations in generative models ⚖️ Bias and fairness issues 🛡️ Adversarial attacks ⚠️ Harmful content generation 🔒 Privacy and confidentiality breaches 🔄 Feedback loops and behaviour amplification ⚙️ Overreliance and erosion of human oversight For each risk, I provide specific control recommendations based on real-world implementation experience. One clear insight? Effective AI risk controls are not primarily technical—they require thoughtful human judgment and oversight at every stage, with 80+ of the specific, relevant controls I identify requiring human participation. If your implementation plan is dominated by purely technical controls with minimal human involvement, that's a red flag. This article was perhaps the most challenging I've written so far on AI governance, drawing from both my hands-on governance experience and extensive research into emerging best practices. I hope you enjoy. Check it out here: https://lnkd.in/gD8zEuHC Stay tuned—my next piece will provide a complete AI risk management policy template you can adapt for your organisation. #AIGovernance #AIRisk #AIEthics #MachineLearning #ResponsibleAI #AIRegulation #RiskManagement

🔒 CONTROL TESTING: Turning Assumptions into Evidence Designing internal controls is essential—but proving they work is where real assurance lies. Control testing is the bridge between theory and reality, showing whether detective, preventive, and corrective measures actually protect your organization. 1️⃣ Why it Matters • Detective controls (e.g., reconciliations) must flag anomalies. • Preventive controls (e.g., approvals) should stop errors before they occur. • Corrective controls (e.g., backups) need to restore operations swiftly. If these fail under scrutiny, risk hides in plain sight. 2️⃣ Essential Control Testing Cycle 1. Define Control Objective – What risk does the control tackle? 2. Test Design – Does the control, in theory, cover the risk? 3. Test Operating Effectiveness – Does it work in real life? Sample transactions, observe processes, interview owners. 4. Document Results – Evidence speaks louder than opinions. 5. Report & Remediate – Highlight gaps, assign fixes, and track closure. 6. Retest & Improve – Controls evolve as processes and threats change. 3️⃣ Real-World Example Imagine a monthly vendor payment review meant to prevent duplicate payments. Testing uncovers that the reviewer only checks high-value invoices, leaving small duplicates undetected. Insight gained? Adjust the review scope and automate a report for all invoices. 4️⃣ Tips for Effective Testing • Risk-Based Prioritization: Focus on controls guarding material risks first. • Cross-Functional Teams: Auditors, process owners, and IT build a fuller picture. • Continuous Testing: Embed into workflows—don’t wait for year-end audits. Remember: good controls are useless if unproven. Test them early, test them often, and turn risk management into actionable evidence. 🔖 #ControlTesting #InternalControls #RiskManagement #Audit #GRC #Compliance #OperationalRisk #ProcessImprovement #Governance #Assurance #ISO31000 #SOX

Excavation work can be hazardous if not properly managed. Here are some common hazards associated with excavation and a list of control measures to mitigate them: Cave-Ins: Control Measures: Use sloping, benching, or shoring to support the sides of the excavation. Regularly inspect and maintain protective systems. Ensure workers are trained in safe excavation practices. Falls and Trips: Control Measures: Provide guardrails, barricades, or covers for open excavations. Use warning signs and barricades to mark excavation areas. Keep the excavation site well-lit and free of debris. Falling Objects: Control Measures: Use toe boards, screens, or barricades to prevent objects from falling into the excavation. Ensure tools and equipment are properly stored and secured when not in use. Use hard hats and personal protective equipment (PPE). Engulfment and Suffocation: Control Measures: Implement procedures for working near hazardous atmospheres, like confined spaces. Provide adequate ventilation and atmospheric testing. Have a rescue plan in place with trained personnel. Hazardous Atmospheres: Control Measures: Test the air in excavations for harmful gases, like methane or hydrogen sulfide. Ventilate or use appropriate respiratory protection when needed. Monitor and control exposure to hazardous materials. Utility Strikes: Control Measures: Call utility companies to locate and mark underground utilities before digging. Hand dig within 18 inches of marked utilities to avoid damage. Use safe digging practices and equipment. Mobile Equipment Accidents: Control Measures: Establish clear traffic control procedures around excavation sites. Ensure equipment operators are trained and certified. Use spotters to guide equipment operators when necessary. Trench and Excavation Collapse: Control Measures: Conduct regular inspections of trenches and excavations. Keep heavy equipment away from the edges. Install protective systems based on soil conditions. Inadequate Emergency Response: Control Measures: Develop and communicate an emergency response plan. Provide first aid and rescue equipment on-site. Train workers on emergency procedures. Lack of Training and Awareness: Control Measures: Ensure all workers are trained in excavation safety. Conduct regular safety meetings and toolbox talks. Promote a culture of safety awareness among employees. Remember that excavation safety should always be a top priority on the job site, and it's crucial to follow relevant regulations and standards to protect workers and prevent accidents.

You designed the RCM. Great. But did you verify it? Too often, risk control measures are treated as static entries in a risk file. But design is only the first step. To comply with ISO 14971, you must also:  → Confirm the control was implemented → Demonstrate it is effective Implementation isn't assumed. You need documented evidence the RCM is present in the final product. Effectiveness can’t be theoretical. It must be supported by testing, simulation, or actual user validation. And yes, this includes “Information for Safety” in your IFU. If you rely on "Information of safety" (instructions, warnings, or labeling...) to reduce risk:  → They must be usability tested → Not just reviewed internally, but evaluated with real users → Criteria like visibility, clarity, comprehension... are essential There’s another step that strengthens the whole system: RCMs should be linked to product requirements. This enables:  → Traceability across the development lifecycle → Inclusion in verification activities → Change control triggers if the RCM is modified Risk control isn’t an isolated activity.↴ It’s a structured process that spans D&D requirements outlined in ISO 13485 §7.3 Need more for your medical device risk management ? Using our risk management template & methodology as a guide, you will be able to: → Use compliant process with ISO 14971 and MDR/IVDR → Use a clear ISO 14971 methodology → Present your data clearly → Use tools; plan & reports proven in audits (our Hazard Traceability Matrix, RMP, and RMR). → Save time; no need to create templates from scratch. Our Risk Management bundle: https://lnkd.in/eTw2VVXp

#Risk & #Reward 🤑 some risks you have to take (to get a view like this), some others (like third party IT risks), you should simply avoid. 💡 Cyber threats are evolving, and NIS2 places cybersecurity risk management at the heart of compliance. Organizations must take proactive steps to identify, assess, and mitigate cyber risks before they become costly incidents. Key Cybersecurity Risk Management Requirements Under #NIS2: 1️⃣ Risk-Based Approach – Companies must implement security measures proportional to their risk exposure and the criticality of their services. 2️⃣ Incident Detection & Response – Strong detection, response, and recovery plans are mandatory to minimize the impact of cyberattacks. 3️⃣ Third-Party & Supply Chain Security – NIS2 expands the focus beyond internal security, requiring businesses to ensure their suppliers and partners meet security standards. 4️⃣ Continuous Monitoring & Threat Intelligence – Regular vulnerability assessments, real-time monitoring, and intelligence sharing are key to staying ahead of cyber threats. 5️⃣ Business Continuity & Disaster Recovery – Organizations must have resilient backup strategies and emergency response plans to minimize downtime in case of cyber incidents. So NIS2 isn’t just about compliance - it’s about building a resilient cybersecurity culture.

𝐔𝐧𝐝𝐞𝐫𝐬𝐭𝐚𝐧𝐝𝐢𝐧𝐠 𝐈𝐓 𝐑𝐢𝐬𝐤 𝐌𝐚𝐧𝐚𝐠𝐞𝐦𝐞𝐧𝐭 Key Components of IT Risk Management 1. 𝐂𝐨𝐧𝐭𝐞𝐱𝐭 𝐄𝐬𝐭𝐚𝐛𝐥𝐢𝐬𝐡𝐦𝐞𝐧𝐭 🔹 Understanding the internal and external environment is foundational for successful risk management. 🔹 This phase defines the organization's objectives, identifies key stakeholders, and evaluates regulatory or compliance requirements that shape risk-related decisions. 🔹 A clear context ensures all subsequent risk management steps are relevant and aligned with organizational priorities. 2. 𝐑𝐢𝐬𝐤 𝐀𝐬𝐬𝐞𝐬𝐬𝐦𝐞𝐧𝐭 Risk assessment is subdivided into several crucial phases: Risk Identification: 🔹 Pinpointing potential threats—such as cyberattacks, hardware failures, or regulatory breaches—that could disrupt IT services, processes, or systems. 🔹 Risk Analysis: Assessing the nature of these risks by analyzing vulnerabilities (e.g., outdated software) and threats (e.g., hackers) to gauge the severity and types of potential impact. 🔹 Risk Estimation: Evaluating each risk’s likelihood and potential impact, typically using quantitative or qualitative methods, to rank and prioritize risks for management focus. 3. 𝐑𝐢𝐬𝐤 𝐄𝐯𝐚𝐥𝐮𝐚𝐭𝐢𝐨𝐧 🔹 Comparison of estimated risks against predefined criteria, such as risk appetite or tolerance levels. 🔹 Determines which risks require action and which can be accepted without intervention. 🔹 Facilitates informed decision-making on where to allocate resources for maximum protection. 4. 𝐑𝐢𝐬𝐤 𝐓𝐫𝐞𝐚𝐭𝐦𝐞𝐧𝐭 Organisations can manage risks using one or more treatment strategies: 🔹 Reduction: Implementing controls or safeguards (e.g., firewalls, security policies) to minimize risk likelihood or impact. 🔹 Avoidance: Altering plans or ceasing activities to entirely bypass certain risks. 🔹 Retention: Accepting a risk when the potential benefits outweigh possible downsides; suitable for low-level risks. 🔹 Transfer: Shifting the risk to a third party, commonly through insurance or contractual arrangements. 5. 𝐑𝐢𝐬𝐤 𝐀𝐜𝐜𝐞𝐩𝐭𝐚𝐧𝐜𝐞 🔹 Organisations formally acknowledge and accept certain risks after due consideration. 🔹 Acceptance reflects the organization’s risk appetite and ensures decision-makers are aware of and prepared for potential consequences. 6. 𝐑𝐢𝐬𝐤 𝐌𝐨𝐧𝐢𝐭𝐨𝐫𝐢𝐧𝐠 𝐚𝐧𝐝 𝐑𝐞𝐯𝐢𝐞𝐰 🔹 Ongoing surveillance of the risk environment and the effectiveness of risk management measures. 🔹 Regular reviews help adapt strategies to new threats, changes in technology, or shifts in organizational goals. Maintains an agile and current risk posture. 7. 𝐑𝐢𝐬𝐤 𝐂𝐨𝐦𝐦𝐮𝐧𝐢𝐜𝐚𝐭𝐢𝐨𝐧 𝐚𝐧𝐝 𝐂𝐨𝐧𝐬𝐮𝐥𝐭𝐚𝐭𝐢𝐨𝐧 🔹 Transparent dialogue with stakeholders about identified risks, responses, and rationales behind risk management choices. 🔹 Fosters trust, ensures shared understanding, and supports collaborative risk management efforts throughout the organization. #technology #learning #cybersecurity #ciso

Control Testing in the Context of Risk Management A control is something an organization is currently doing to ‘modify’ a risk. Modify usually means you’re trying to reduce or manage a risk. The purpose of a control is to reduce one or both of the following : - likelihood of a risk occurring - Impact of the risk. Controls take many forms, including policies, procedures, practices, processes, technology, techniques, methods or devices that reduce a risk. They may be manual (requiring human intervention) or automated (technology based). A control typically works in one of three ways: - Preventative – controls that reduce the likelihood of a situation occurring, such as policies & procedures, approvals, technical security solutions built into a system, authorizations and training - Detective – controls that identify failures in the control environment, such as reviews of performance, reconciliations, exception reporting, staff culture surveys, IT security event logs and investigations (internal or via a third party) - Corrective – controls that reduce the consequence and/or rectify a failure after it has been discovered, such as continuous improvement actions, crisis management, business continuity and/or disaster recovery plans or insurance. Controls are tested via two core criteria, i.e 1) Control Design and 2) Control Effectiveness What is Control Design? The test of design of an internal control would validate that the control that is stated to be in place by an organization has indeed been established & put in place. An example test of design would be that an organization notes that they have controls around the hiring process, one control being that background checks are conducted on all new hires. In order for risk mngt staff to test the design of this particular control, they would look to see that a background check was conducted on one example recently hired employee. This information will confirm that: Yes, the organization has a process in place to perform background checks for new hires. What is Control Effectiveness ? The test of effectiveness of a particular internal control is whether or not the control operated consistently over a period of time in the past (typically 12 months). Going back to the background check example control, we can look at how one would test the operating effectiveness of that same control. To test the operating effectiveness, one would need to look at a sample of new hires (more than one) across that last 12 months. The staff member will then confirm that a background check had been conducted for each sampled new hire (vs just looking at one example, as is the case with testing the design of the control). By looking back in time, and testing a sample of new hires that were hired in the last 12 months, one can test the operation of the control. Hence, this sample testing method can identify whether the control ‘operated effectively’ & consistently over that period of time. #riskmanagement

“Mapping Cybersecurity Threats to Defenses: A Strategic Approach to Risk Mitigation” Most of the time we talk about reducing risk by implementing controls, but we don’t talk about if the implemented controls will reduce the Probability or Impact of the Risk. The below matrix helps organizations build a robust, prioritized, and strategic cybersecurity posture while ensuring risks are managed comprehensively by implementing controls that reduces the probability while minimising the impact. Key Takeaways from the Matrix 1. Multi-layered Security: Many controls address multiple attack types, emphasizing the importance of defense in depth. 2. Balance Between Probability and Impact: Controls like patch management and EDR reduce both the likelihood of attacks (probability) and the harm they can cause (impact). 3. Tailored Controls: Some attacks (e.g., DDoS) require specific solutions like DDoS protection, while broader threats (e.g., phishing) are countered by multiple layers like email security, IAM, and training. 4. Holistic Approach: Combining technical measures (e.g., WAF) with process controls (e.g., training, third-party risk management) creates a comprehensive security posture. This matrix can be a powerful tool for understanding how individual security controls align with specific threats, helping organizations prioritize investments and optimize their cybersecurity strategy. Cyber Security News ®The Cyber Security Hub™