Governance · Risk · Compliance

Compliance & GRC Program

We help organizations establish and mature security governance—aligning policy, risk, and controls to business objectives, regulatory obligations, and insurer expectations. [oai_citation:1‡The Solutioners GRC Program.pdf](sediment://file_0000000061a061f7ad8ed0204a7f9539)

Cyber Security & Its Importance

The primary function of cyber security is to protect confidentiality, integrity, and availability across business operations against increasingly sophisticated attacks.

Monetary and reputational risks from breaches are at an all-time high.

Board-level scrutiny is intensifying because cyber incidents disrupt operations and financial performance.

Legal and regulatory mandates now require demonstrable cyber resilience.

Threat actors continually evolve tactics, tools, and procedures.

Cyber crime has professionalized into a global business model.

Year-over-year growth in attacks spans systems, applications, networks, and data stores.

Cyber Security Risk Management

We align ISO 27005 practices with your business context to generate actionable, prioritized treatment plans.

  1. 01 · Identify Assets

    Inventory physical and logical assets across business units; map ownership, classification, and dependencies.

  2. 02 · Identify Threats

    Analyze tactics, techniques, and procedures relevant to the organization’s industry, geography, and partners.

  3. 03 · Analyze Risk

    Evaluate likelihood and impact using discoverability, exploitability, and reproducibility instead of historical bias.

  4. 04 · Determine & Prioritize

    Apply a risk matrix (likelihood × impact) to prioritize scenarios and select the right treatment options.

  5. 05 · Develop Treatment Plan

    Mitigate, transfer, avoid, or accept risks while tracking ownership, budget, and milestones in the register.

Treatment Considerations

  • Avoid the risk when exposure outweighs business value.
  • Transfer residual exposure through insurance or partner agreements.
  • Mitigate by applying layered controls until risk falls within tolerance.
  • Accept when residual risk aligns with agreed appetite and monitoring exists.

GRC Role in Cyber Security

The Solutioners GRC program evaluates cyber maturity and designs security architecture tuned to the organization’s risk acceptance level.

People

Empower stakeholders through defined roles, training, and accountability.

Regulations

Map controls to legal, industry, and regional mandates.

Technology

Integrate security tooling, telemetry, and automation into governance.

Business Processes

Embed controls into operational workflows and decisioning.

Customer Requirements

Align delivery promises with security assurances for clients and partners.

Organizational Needs

Balance risk appetite with transformation and growth goals.

Why GRC with The Solutioners

Cybersecurity is a board-level, business-risk issue. Our program protects confidentiality, integrity, and availability while improving transparency, efficiency, and accountability. [oai_citation:2‡The Solutioners GRC Program.pdf](sediment://file_0000000061a061f7ad8ed0204a7f9539)

Transparency & Accountability

Improve oversight with defensible evidence trails and policy alignment.

Improved Security

Fortify controls to reduce the likelihood and impact of cyber incidents.

Core Focus

Your Business

GRC orchestrates people, processes, and technology so the business can move with confidence.

Better Data Management

Consolidate risk, control, and evidence data for faster reporting.

Minimized Loss

Contain financial, legal, and reputational exposure through proactive governance.

Maintained Trust

Demonstrate compliance for customers, investors, and regulators.

Increased Control

Standardize policies, processes, and tooling across business units.

Standards & Framework Alignment

We implement and assess against leading standards and frameworks to match your regulatory and insurer controls landscape.

ISO 27001

Information Security Management

ISO 22301

Business Continuity Management

ISO 31000

Risk Management

ISO 9001

Quality Management

NIST CSF

Cybersecurity Framework

SOC 2

Trust Services Criteria

PIPEDA

Canadian Privacy Law

GDPR

EU Data Protection

HIPAA

US Health Data Security

Alignment does not imply certification; formal certification remains with accredited bodies.

ISO & International Standards

  • ISO 27001:2013Build and maintain an information security management system to address cyber risks.
  • ISO 9001:2015Implement a quality management system that aligns with customer satisfaction metrics.
  • ISO 22301:2019Safeguard business operations against disruption with continuity controls.
  • ISO 31000:2018Guide enterprise risk management and effective mitigation decisions.

Cyber Security Frameworks & Laws

SOC 2

Assure customers of secure data handling across service providers.

PIPEDA

Comply with Canadian privacy law for collection, use, and disclosure of personal data.

NDMO

Align with Saudi data management and personal data protection mandates.

NIST 2.0 CSF

Adopt a scalable framework to identify, protect, detect, respond, and recover.

CCCS Guidance

Follow Canadian Centre for Cyber Security recommendations for threat protection.

NINT / Sector Standards

Address specialized requirements, including nano-technology environments.

CASL

Respect anti-spam legislation and consent-driven communications.

HIPAA

Safeguard electronic protected health information.

GDPR

Meet EU privacy expectations for data minimization and subject rights.

What the Program Covers

Module

Cyber Security Audits

  • Documentation review of policies, standards, and registers.
  • Security control validation and effectiveness testing.
  • Risk assessment quality review and traceability checks.
  • Gap analysis with prioritized remediation actions.
  • Draft and final audit reporting with executive insights.
  • Remediation support and control re-testing.
  • External audit preparation and evidence packaging.

Module

Business Continuity & Disaster Recovery

  • BCP and DR strategy development tailored to impact tolerances.
  • Threat risk assessments and business impact analyses.
  • Security control risk assessments supporting resilience.
  • Training, tabletop, and technical exercise orchestration.
  • Implementation support plus maintenance runbooks.

Module

Data Protection & Privacy Assessment

  • Data security posture assessments across repositories.
  • Gap analysis for privacy controls and data subject rights.
  • End-to-end data flow and process mapping.
  • Security improvement and remediation reporting.

Module

Security Standards & Frameworks

  • Establish organizational context using SWOT and PEST inputs.
  • Clarify strategic objectives and stakeholder expectations.
  • Map business processes to control catalogues.
  • Deliver implementation plans aligned to selected frameworks.

Module

Cyber Security Risk Management

  • Asset-based risk assessments combining physical and logical inventories.
  • Process-centric evaluations of cyber controls and dependencies.
  • Security control risk assessments covering people, tech, and third parties.
  • Proactive incident response planning and playbook activation.

Module

Education, Awareness & Training

  • Program deployment and onboarding enablement.
  • Role-based and strategic cyber security education.
  • Standards and framework familiarization workshops.
  • Continuous awareness campaigns and executive briefings.

Program Implementation Lifecycle

  1. 01 · Review Current State

    Analyze the existing GRC framework, controls, and tooling to benchmark maturity.

  2. 02 · Assess Business Value

    Validate stakeholder objectives and quantify benefits of modernizing the GRC platform.

  3. 03 · Select Standards & Frameworks

    Align on the right mix of ISO, NIST, NCA, or sector mandates to satisfy obligations.

  4. 04 · Choose GRC Solution

    Recommend technology platforms and integrations to automate evidence and reporting.

  5. 05 · Develop Project Plan

    Define timeline, resourcing, and milestones covering policy, technology, and people.

  6. 06 · Implement & Operationalize

    Deploy controls, migrate data, onboard teams, and embed new workflows.

  7. 07 · Monitor & Improve

    Establish continuous monitoring, metrics, and iterative enhancements.

We start with a gap analysis to surface strategic, operational, and regulatory requirements early. [oai_citation:11‡The Solutioners GRC Program.pdf](sediment://file_0000000061a061f7ad8ed0204a7f9539)

Operational Focus Areas

  • IT Risk Management

    Track technology, cloud, and application risks with aligned treatment plans.

  • Operational Risk Management

    Coordinate process, supplier, and human-factor risks for resilience.

  • Compliance Management

    Maintain policies and procedures with evidence linked to controls.

  • Policy Management

    Govern document lifecycles, approvals, and distribution.

  • Internal Audit

    Plan, execute, and document internal audit activities with risk linkage.

  • External Audit Support

    Package evidence, coordinate responses, and liaise with third parties.

Security Audit Lifecycle

  1. 01 · Audit Notification

    Alert stakeholders, define scope, and schedule the opening briefing.

  2. 02 · Planning

    Review prior assessments, prioritize focus areas, and finalize logistics.

  3. 03 · Fieldwork / Visits

    Test controls, validate evidence, and interview process owners on site or remotely.

  4. 04 · Management Response

    Deliver draft findings and capture remediation ownership with action plans.

  5. 05 · Audit Report

    Publish the final report and track follow-up activities through closure.

CIRO Compliance Focus

The Canadian Investment Regulatory Organization (CIRO) unifies IIROC and MFDA mandates to safeguard investors, uphold market integrity, and harmonize dealer oversight nationwide. Financial institutions need a coordinated response that links governance, risk management, cybersecurity, and privacy disciplines to these obligations.

Mandate & Regulatory Scope

  • Rulemaking & Policy DevelopmentMaintains national rules across proficiency, business conduct, financial operations, and trading for dealers and registrants.
  • Oversight & EnforcementSurveils marketplaces, conducts compliance audits, and exercises quasi-judicial powers including suspensions, fines, and expulsions.
  • Investor Protection & EducationAdvances financial literacy, issues guidance for order-execution-only channels, and strengthens safeguards for self-directed investors.
  • Proficiency StandardsSets ongoing education requirements and assessment-based proficiency for approved persons, including new rules effective 2026.
  • Delegated Authority & National ReachOperates under CSA recognition orders while coordinating with provincial regulators and integrating delegated registration functions.

Key Compliance Obligations

  • Business Conduct & Client ProtectionClient Focused Reforms covering conflicts, KYC, KYP, suitability reviews, continuing education, and truthful communications.
  • Financial & Operational ComplianceClear definitions for cybersecurity incident reporting, T+1 settlement discipline, capital requirements, and monthly asset reconciliation.
  • Trading ActivityUMIR expectations for best execution, abuse prevention, exposure controls, and client identifiers on applicable listed orders.
  • Proficiency & RegistrationCIRO CE programs for mutual fund and investment dealers, supervisory experience thresholds, and alignment with NI 31-103 categories.
  • Reporting & Record-KeepingMandatory incident reporting, FINTRAC collaboration, and secure retention of digital communications across jurisdictions.
  • Enforcement & PenaltiesSanctions up to $5M per contravention (with proposals for $10M), disgorgement, permanent bans, and aggravating factors for concealment or investor harm.

Regulatory Risk in Global Financial Institutions

Global footprints magnify CIRO compliance challenges through overlapping statutes, cross-border data flows, third-party ecosystems, and increased scrutiny from Canadian and foreign regulators.

Compliance Risk

Holistic exposure to legal, regulatory, financial, or reputational harm from failing to honour obligations.

  • Regulatory Risk: Changing statutes and rules (Basel III, ESG, GDPR, AML/CFT) shift capital, reporting, and control requirements.
  • Legal Risk: Non-compliance with legal statutes or disputes that frequently compound reputational fallout.

Operational Risk

Losses stemming from process, people, technology, or external events.

  • Human Error & Misconduct: Policy breaches, poor decisions, insider or external fraud.
  • System & Technology Failures: ICT outages, application breakdowns, and data breaches.
  • Cybersecurity Risk: Phishing, ransomware, and advanced data exfiltration campaigns.
  • Third-Party Risk: Vendor failures introducing control gaps; OSFI mandates comprehensive life-cycle oversight.
  • Process Failures: Weak reporting, finance, or sales workflows increasing regulatory exposure.
  • Business Continuity: Disruptions that interrupt critical operations and recovery timelines.

Reputational Risk

Erosion of stakeholder trust following compliance breaches, operational failures, or unethical conduct with cascading financial impact.

Strategic Risk

Misalignment between business strategy and risk management amid regulatory evolution, geopolitical change, and new competitors.

Global Operations Impact

  • Navigating diverging national regulations, extraterritorial statutes, and contractual jurisdiction clauses.
  • Reconciling cross-border data privacy, cybersecurity expectations, and larger attack surfaces created by global platforms.
  • Tracking rapid regulatory change while allocating skilled people, technology, and capital across regions.
  • Managing multilingual, cultural, and digital-channel nuances that complicate supervision and detection of misconduct.
  • Absorbing higher AML/CTF costs, stricter due diligence (PEP focus), and OSFI operational resilience expectations.

CIRO Compliance Risk Register Template

A structured risk register keeps CIRO-driven obligations visible, measurable, and actionable across regions. Use it as a living artefact integrated with enterprise risk, audit, and resiliency programs.

Risk ID

Unique identifier aligned to enterprise taxonomy (e.g., REG-CIRO-001).

Risk Name / Title

Concise descriptor of the compliance exposure.

Risk Description

Clear narrative of causes, obligations, and potential consequences.

CIRO Rule / Obligation

Specific reference to IDPC, MFD, UMIR, or By-Law requirements.

Risk Category

Primary classification such as Operational, Legal, Reputational, Strategic, or Cybersecurity.

Date Identified

Formal logging date to anchor governance cadence.

Risk Owner

Accountable leader or function overseeing the risk.

Inherent Likelihood

Probability score prior to controls using agreed scale.

Inherent Impact

Severity assessment pre-controls considering penalties up to $10M, remediation cost, and brand harm.

Inherent Risk Rating

Combined scoring or heat-map placement to aid prioritization.

Existing Controls

Documented policies, monitoring, technology safeguards, and assurance activities.

Residual Likelihood

Probability after evaluating control effectiveness.

Residual Impact

Post-control severity outlook.

Residual Risk Rating

Current exposure guiding further treatment decisions.

Mitigation Actions / Treatment Plan

Planned initiatives to reduce, avoid, transfer, or accept the risk.

Action Owner

Responsible party delivering mitigation work.

Target Completion Date

Deadline for mitigation milestones.

Status

Progress indicator such as Open, In Progress, Closed, or Overdue.

Review Date / Next Review Date

Most recent assessment and scheduled follow-up.

Escalation Level

Committee or executive trigger when thresholds are exceeded.

Notes / Comments

Context, links to evidence, incident history, or related risks.

Global Impact Consideration

Assessment of cross-border dependencies, data residency, or international scrutiny.

Implementation Principles

  • Assign clear ownership and accountability for every risk and mitigation action.
  • Review frequently (monthly or quarterly) and whenever regulatory changes or incidents occur.
  • Integrate with enterprise risk management so compliance risk aligns with corporate appetite.
  • Keep templates scalable and adaptable to different business units, jurisdictions, and complexity levels.
  • Promote proactive identification by engaging compliance, legal, IT, business, and senior leadership stakeholders.
  • Separate inherent versus residual scoring to prioritize remediation realistically.
  • Define mitigation strategies (avoid, reduce, transfer, accept) with measurable outcomes.
  • Enable transparent reporting to committees, executives, and regulators as required.

Inadequate Cybersecurity Measures

CIRO IDPC Rule 3900 and cybersecurity guidance notes.

Breakdown in cybersecurity controls leading to data breaches, trading disruption, or supervisory failure.

  • Stand up a 24/7 security operations center and enhance monitoring analytics.
  • Schedule red-team and penetration exercises with remediation governance.
  • Expand encryption coverage for client data in transit and at rest across jurisdictions.

Inadequate AML / CTF Controls

CIRO Rules 2500 and 2600 plus FINTRAC reporting duties.

Weak client due diligence, transaction monitoring, or suspicious reporting enabling illicit flows.

  • Deploy automated monitoring with anomaly detection tuned for cross-border transactions.
  • Deepen enhanced due diligence for high-risk clients and geographies.
  • Commission independent program reviews every two years to benchmark effectiveness.

Business Continuity & Disaster Recovery

We design for resilience—keeping essential services online during disruption and restoring quickly when incidents occur. [oai_citation:13‡The Solutioners GRC Program.pdf](sediment://file_0000000061a061f7ad8ed0204a7f9539)

  • Reduce downtime with tested recovery playbooks.
  • Respond swiftly to cyber incidents and ransomware disruption.
  • Maintain data integrity through immutable backups and replay testing.
  • Limit the effects of natural disasters and supply chain interruptions.
  • Ensure kinetic and digital continuity across remote and on-site operations.

Recovery Objectives

Define business-aligned recovery time objectives (RTO) and recovery point objectives (RPO).

Risk & Impact Assessment

Perform threat risk assessments and business impact analyses to prioritize services.

Identify Critical Systems

Catalog mission-critical applications, data, and infrastructure for restoration sequencing.

Data Backup & Immutability

Select backup strategies that balance retention, security, and recovery performance.

Plan Development & Drills

Create BCP / DR plans, execute exercises, and iterate with lessons learned.

Data Protection & Privacy

We assess the nature, scope, context, and purpose of processing; identify control gaps; propose mitigations (e.g., notices, opt-outs, DSAR enablement); and deliver a final report including residual risk.

Understand Processing

  • Nature
  • Scope
  • Context
  • Purpose of processing activities.

Identify Gaps

  • Highlight deficiencies in privacy controls and data subject rights management.

Mitigate Risks

  • Establish data-sharing agreements.
  • Update privacy notices and consent flows.
  • Offer opt-outs and preference management.
  • Deploy systems enabling data subject rights execution.

Report & Assure

  • Document additional measures and residual risk levels.
  • Decide on regulator consultations (e.g., ICO) when required.

Security Awareness & Training

Perform Gap Analysis

Set up assessments to identify employee vulnerabilities.

Assess Training Needs

Align curricula to roles, threat exposure, and compliance mandates.

Set Objectives & Plan

Define outcomes and rollout cadence (monthly, quarterly, annually).

Initiate Training

Deliver personalized content, workshops, and simulations.

Measure Performance

Track engagement, completion, and knowledge retention metrics.

Phishing Simulations

Conduct periodic campaigns and retrain high-risk cohorts.

Evaluate & Revise

Continuously improve materials, policies, and enablement tactics.

Includes periodic phishing simulations, policy enablement, and continuous improvement cycles.

Why The Solutioners

Secure your business with a GRC partner that blends cyber expertise, regulatory insight, and pragmatic delivery.

  • Tailored solutions grounded in both local and international standards and frameworks.
  • Risk assessments rooted in threat modeling and full ecosystem coverage.
  • Proactive contingency planning with dedicated cyber GRC specialists.
  • Cross-industry experience delivering compliance outcomes for enterprises of all sizes.
  • Cost-effective methodologies that align with business objectives and regulatory obligations.
Start a compliance assessment

The information on this page is for general guidance and does not constitute legal advice. Formal certifications are provided by accredited bodies; we support readiness and ongoing conformity. [oai_citation:16‡The Solutioners GRC Program.pdf](sediment://file_0000000061a061f7ad8ed0204a7f9539)