#2. Designing a Continuous Controls Monitoring Program

Implementing Continuous Controls Monitoring (CCM) isn’t as simple as flipping a switch. It requires careful planning and design up front. In Part 1, we established why CCM is critical. Now in Part 2, we tackle how to start: How do you design a CCM program that fits your organisation’s needs and aligns with compliance frameworks? The key is to start with a clear strategy – identifying which controls to monitor continuously, mapping those to requirements like ISO 27001 or APRA CPS 234, and setting up the processes and technology needed. A thoughtful design prevents “random acts of monitoring” and ensures your CCM efforts deliver value (and don’t overwhelm your team with noise). Let’s break down the steps to lay a solid foundation for CCM.

A smart CCM program begins by determining what to monitor. There could be hundreds of controls in your environment, but trying to monitor everything at once is a recipe for failure. Instead, focus on critical controls guided by industry frameworks and your own risk assessments.

• Start by reviewing the control objectives from relevant frameworks: for example, ISO 27001’s Annex A, the ASD Essential Eight strategies, the NIST Cybersecurity Framework, or sector-specific ones like AESCSF. Identify which controls are most crucial for your business and where continuous monitoring would mitigate significant risk. As recommended in my ISACA paper, it helps to use established frameworks (COSO, COBIT, ITIL, etc.) to enumerate potential controls and then narrow scope based on risk ratings.
• Perform a risk assessment: which processes or assets pose the highest risk if controls fail? Prioritize those for continuous monitoring. For instance, if you’re in finance, continuous monitoring around access control and transaction integrity might be top priority; in healthcare, continuous monitoring of patient data access and encryption controls might rank high.

By aligning CCM scope to both compliance obligations and your unique risk profile, you ensure the program is both comprehensive and relevant.

Once you’ve identified candidate controls to monitor, define clear control objectives and metrics for each. A control objective is a statement of the desired state or outcome (e.g., “All critical servers are patched within 14 days of patch release”). For each objective, determine how you will measure success or failure – these become your continuous monitoring metrics. My ISACA paper’s guidance on CCM suggests formalising “key assurance assertions” for each control objective and then defining automated tests to evaluate those assertions​. For example, if the objective is up-to-date patches, the assertion might be “No critical patches older than 30 days are missing on any server.” The metric could be “percentage of servers with missing critical patches older than 30 days” (which ideally should be zero). Similarly, for a control objective like “Only authorized devices on network,” a metric could be “percentage of detected devices in asset inventory.” Make sure these metrics are specific, measurable, and tied to the control’s effectiveness. Also define thresholds or criteria for alerting – at what point does a metric indicate a control failure that needs intervention? In some cases, any deviation is critical (e.g., an unauthorized admin account creation). In others, you might set a percentage threshold (e.g., alert if <95% of endpoints have antivirus up to date). Clear definitions now will translate into meaningful alerts later.

With metrics defined, consider how you will collect and analyze the data for those metrics. This often means selecting tools or technologies. Here are some common components:

• Security Information and Event Management (SIEM): If you already have a SIEM for log management, it can often be leveraged for certain CCM metrics (like correlating events to detect policy violations).
• Governance, Risk & Compliance (GRC) Platforms: Some GRC or Integrated Risk Management tools (e.g. MyRISK) now have CCM modules or can be configured to track control indicators and automate testing.
• Cloud Security Posture Management (CSPM): For cloud environments, CSPM tools (like AWS Config, Azure Policy, or third-party ones) continuously scan cloud resources for compliance with security policies – ideal for monitoring cloud configuration controls.
• Custom Scripts/Automation: Sometimes simple scripts that query systems (via APIs or command-line tools) on a schedule can feed data into your CCM dashboards. For example, a script to dump a list of users from an Active Directory group every night to ensure no unauthorized changes.
• Endpoint Management Tools: Solutions that manage endpoint configuration (SCCM, Intune, Tanium, etc.) can often report on patch levels, installed software, AV status – feeding metrics for those controls. In fact, organizations are using tools like Tanium’s platform to continuously assess endpoints against Essential Eight controls.

Choose tools that align with your existing tech stack and expertise. If you operate heavily in cloud, native cloud monitoring tools might be a quick win. If you have a strong SIEM team, use that capability. The goal is to automate data collection as much as possible. Evaluate gaps as well: you might find you lack visibility in a certain area (e.g., you have no inventory of privileged account changes). That gap either needs a tool or a process change to fulfill your monitoring needs.

Technology alone won’t make CCM work – you need well-defined processes and people responsible. Outline who will do what when a continuous control check detects an issue. For each metric/alert, assign an owner. For example, if the continuous monitoring system flags a misconfiguration in a database, is it the DBA team’s responsibility to fix? If an unauthorized cloud instance appears, does cloud operations handle it? Define an escalation path as well, because CCM will surface issues that might need management attention if not resolved quickly. Many organizations set up a CCM dashboard review meeting or integrate CCM results into existing operational meetings. The security or risk team might triage alerts daily, and a governance committee might review overall CCM trends monthly. It’s also wise to update or create procedures for responding to common CCM alerts – akin to incident response playbooks. Treat a failed control similar to an incident: investigate cause, remediate, consider if it indicates a larger problem. Additionally, address how to handle exceptions. There will be cases where a control deviation is approved (e.g., a critical patch couldn’t be applied on a server due to a business constraint – it’s a known risk accepted temporarily). You need a way to record those so that the CCM system’s output can be contextualized (i.e., this is a known exception versus a truly unexpected issue).

When designing your program, plan for a phased rollout. It’s tempting to try to cover all domains (access, assets, etc.) at once with full automation, but that can be overwhelming. Instead, pick one or two high-value areas to begin. For instance, you might start with continuous monitoring of user access controls and basic server configuration compliance. Iron out the kinks in those processes – you will learn a lot about tuning alerts, refining metrics, and the effort involved. As you demonstrate success (e.g., catching and fixing a few issues early), you gain support to expand. Part of design is also setting success criteria and KPIs for the CCM program itself. For example, you might set a goal that within 6 months, 90% of high-risk control gaps are detected automatically rather than via manual audit. Or a KPI that time to remediate certain issues drops by X% thanks to continuous visibility. These help show value to stakeholders. Keep the design documentation living – as you add new controls to monitor, update your inventory of CCM metrics and owners. Over time, you will build a robust catalog that maps: Control Objective -> Metric -> Tool/Data Source -> Alert Criteria -> Owner/Response. That is essentially the design blueprint of your CCM program.

Since many readers are concerned with meeting compliance frameworks, ensure your CCM design explicitly ties into those requirements. Map each control you monitor to the relevant section of ISO 27001, SOCI Act rule, Essential 8 strategy, etc. This mapping not only ensures you’re covering your obligations, but it also makes reporting to auditors/regulators easier. For example, if ISO 27001 control A.12.1.1 (security backup) is in scope, your CCM might include a metric “Average age of last successful backup” across critical systems. When audit time comes, you can show a live dashboard or history that continuously tracks backups, satisfying the auditor that control A.12.1.1 is not just a document, but an active practice. In APRA terms, you are demonstrating the “systematic testing” of controls they expect​. A well-designed CCM program thus becomes a backbone of both security operations and compliance oversight.

Designing a CCM program is a crucial upfront investment. By aligning with frameworks and risk, defining solid metrics, choosing the right tools, and establishing processes, you set yourself up for success. This foundation will support the more technical work of implementation that follows. In the next parts of this series, we’ll apply this designed approach to specific control domains. Think of Part 2 as the blueprint – and in Parts 3 onward, we’ll be doing the construction in areas like asset management, access management, etc., using this blueprint. If you’ve followed along, take a moment to sketch out what your own organization’s top 5 controls to monitor might be, and what metric would prove those controls are working. That exercise alone can be illuminating.

With a clear strategy in hand, you’re now ready to start implementing CCM one control at a time. In Part 3, we’ll dive into Continuous Monitoring for Asset Management – ensuring you always know what assets you have and that they are properly accounted for (the foundation of all security). Stay tuned as we turn planning into action.

This white paper, Part 2 of our series, provides a comprehensive guide to planning a CCM program.