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Above and Beyond: Organizational Efforts to Complement U.S. Digital Security Compliance Mandates

—Organizations that provide essential services such as electricity, healthcare, and secure ﬁnancial transactions are required to use digital-security compliance programs to establish a baseline of minimum security. Unfortunately, these compliance programs are known to suffer from a multitude of issues (both in how they are written and in how organizations implement them), resulting in organizations implementing their own security measures to ﬁll actual or perceived compliance gaps. In this study, we survey 40 security professionals from six U.S. essential- service sectors to gain insight into how organizations complement compliance to ﬁx perceived security gaps, which measures worked particularly well, and how their organizations prioritize and evaluate the measures they adopt. We ﬁnd that organizations complement compliance programs often, with 37 of 40 participants conﬁrming that their organizations have gone beyond what they perceive as mandated compliance measures to mitigate otherwise unaddressed risks. While participants were generally positive about these perceived complementary measures, they also reported challenges related to poor management, information saturation, and difﬁculty keeping complementary measures up-to-date and relevant. Based on these results, we recommend that compliance standards directly integrate guidance for carefully managing and auditing any perceived complementary measures that an organization chooses to implement and that organizations carefully plan end-to-end deployment and operation before implementing these measures.