Cybersecurity Governance, Risk & Compliance
Comprehensive GRC services and certification support
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DeBerry Contracts delivers trusted cybersecurity Governance, Risk, and Compliance (GRC) services to support your organization's security and regulatory objectives. We provide comprehensive solutions that help organizations establish strong governance frameworks, manage cyber risk, and meet industry standards and regulatory requirements.
Our structured and transparent approach offers clear visibility into risk posture, compliance status, and audit readiness—giving you confidence at every stage.
Why GRC Matters
In today's threat landscape, organizations face increasing regulatory scrutiny and cybersecurity risks. A robust GRC program protects your assets, ensures compliance, and builds stakeholder trust.
Our GRC Services Include:
Policy Development & Governance Frameworks
Establish clear policies and governance structures that align with your business objectives and regulatory requirements. We help you build sustainable frameworks that grow with your organization.
Cyber Risk Management & Assessments
Identify, assess, and mitigate cyber risks through comprehensive risk assessments and ongoing monitoring. We provide actionable insights to strengthen your security posture.
Compliance & Certification Support
Navigate complex compliance requirements including CMMC, FAR and DFARS clauses, SEC cybersecurity disclosure rules, SOX, PCI DSS, and other regulatory frameworks. Our experts guide you through every step of the certification process.
Incident Response Planning
Develop and test incident response plans to ensure your organization is prepared for security events. We help you minimize impact and accelerate recovery.
Audit Readiness & Support
Prepare for audits with documentation review, gap analysis, and remediation support. We ensure you're audit-ready and confident in your compliance posture.
Compliance Frameworks We Support
Ready to Strengthen Your Security Posture?
Contact us today to discuss how our GRC services can help your organization achieve compliance and reduce cyber risk.
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Contact us to discuss how our GRC services can help your organization achieve compliance and reduce cyber risk.
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The Specifics Behind Every Framework
We don't just name the regulations. Here is what each section actually requires of your systems, and the quick wins we use to get clients audit-ready faster.
SEC Cybersecurity Disclosure Rules & Regulation S-P
The SEC expects firms to detect incidents fast, decide materiality without delay, and prove that cybersecurity is governed from the board down. We build the playbooks, controls, and evidence that make those deadlines achievable.
- Determine whether an incident is material without unreasonable delay after discovery.
- File an 8-K within four business days of a materiality determination.
- Describe the nature, scope, and timing of the incident and its material or reasonably likely impact.
- Amend the filing as information that was unavailable at the time becomes known.
Stand up a disclosure committee and a pre-approved materiality worksheet so the four-day clock never starts from zero.
- Describe processes for assessing, identifying, and managing material cybersecurity risks.
- Disclose whether third-party assessors, consultants, or auditors are engaged.
- Explain how risks from third-party service providers are overseen.
- Describe board oversight and the expertise of management responsible for cybersecurity.
Map your security program to NIST CSF 2.0 and document board briefings quarterly so the annual narrative writes itself.
- Maintain a written incident response program to detect, respond to, and recover from unauthorized access to customer information.
- Notify affected individuals as soon as practicable, and no later than 30 days after becoming aware of a breach of sensitive customer information.
- Oversee service providers, including requiring them to notify you within 72 hours of a breach.
- Keep records demonstrating compliance with safeguards and disposal requirements.
Add a 72-hour breach notice clause to every vendor contract and keep a ready-to-send customer notification template.
Sarbanes-Oxley IT Security Requirements by Section
Sarbanes-Oxley is a financial reporting law, but nearly every section depends on IT controls. Here is what each section means for your systems, and the fastest way to get audit-ready.
- Access controls so only authorized personnel can modify financial data.
- Logging and monitoring to track changes to financial reports and data.
- Data integrity checks such as checksums or hashing to prove data has not been altered.
Enable Microsoft Purview audit logging and restrict finance system admin rights to named individuals.
- Encrypted transmission for financial data shared with external parties.
- Data classification policies that identify and protect sensitive financial information.
- Regular review of security policies to keep pace with disclosure requirements.
Apply sensitivity labels to financial workbooks so encryption follows the file wherever it goes.
- Regular risk assessments of IT systems that handle financial data.
- Multi-factor authentication on every system that accesses financial data.
- Documented IT controls, including formal change management.
- Periodic testing of control effectiveness with documented results.
Enforce MFA through Entra ID Conditional Access and keep a single control matrix your auditor can test against.
- Real-time monitoring to detect unauthorized access or changes to financial data.
- Secure, redundant disclosure systems that prevent downtime.
- Secure communication channels for urgent disclosures.
Route finance-system alerts into a monitored queue with a defined escalation owner.
- Data retention policies that define how long financial records are kept.
- Data loss prevention to stop unauthorized deletion or alteration.
- Backups that can recover from accidental or malicious deletion.
Configure Microsoft 365 retention policies and immutable backups for finance mailboxes and SharePoint sites.
- Secure, anonymous reporting channels that protect the reporter’s identity.
- Access to whistleblower reports restricted to authorized personnel.
- Regular audits of the reporting process for effectiveness and security.
Use a dedicated third-party hotline and lock its admin access to the audit committee.
- Controls that prevent unauthorized access to audit data and documents.
- Secure audit trails tracking access and changes to financial records.
- Secure, read-only auditor access that preserves data integrity.
Provision auditors as time-limited guest accounts with read-only access to a dedicated evidence site.
- Controls ensuring the accuracy and completeness of financial reports.
- Encryption of sensitive financial data at rest and in transit.
- Security policies updated as reporting requirements change.
Pair BitLocker device encryption with TLS-only mail flow to cover data at rest and in transit.
SOX Internal Control Maturity Model (ICMM) IT Security Measures
The ICMM organizes SOX IT controls into domains you can measure and mature over time. These are the controls auditors look for first.
- Role-based access control restricting financial systems by job role.
- Strong authentication such as MFA to verify identities.
Run quarterly access reviews with Entra ID Access Reviews and keep the sign-offs.
- Encrypt sensitive financial data at rest and in transit.
- Use secure protocols such as HTTPS and TLS for all transmission.
Turn on device encryption policies in Intune and block legacy, unencrypted protocols.
- Formal process ensuring changes are authorized, tested, and documented.
- Logs of all changes made to financial systems and data.
Require a ticket number on every production change and keep approvals in one system.
- A plan addressing breaches that could impact financial reporting.
- Procedures for identifying, reporting, and mitigating incidents.
Run one tabletop exercise per year and file the after-action report as audit evidence.
- Track access to financial systems and detect unauthorized activity.
- Review logs regularly for suspicious activity and anomalies.
Centralize logs in Microsoft Sentinel or Defender and schedule a weekly review.
- Regular backups so financial data can be restored after loss or corruption.
- Periodic testing of backup and recovery processes.
Document one successful restore test per quarter. Auditors want proof, not policy.
- Regular assessments of IT systems that handle financial data.
- Evaluation of how cyber threats could affect financial reporting.
Maintain a living risk register tied directly to your control matrix.
- Ongoing training on IT security and safeguarding financial data.
- A culture of security awareness across the organization.
Run monthly phishing simulations with finance-specific lures like invoice and wire fraud.
- Protect infrastructure and data centers hosting financial systems.
- Control physical access to sensitive areas and equipment.
Collect SOC 2 reports from your hosting providers to cover data center controls.
- Assess the security of vendors with access to financial data or systems.
- Include security requirements and compliance obligations in vendor contracts.
Tier vendors by data access and request SOC 1 or SOC 2 reports from the top tier annually.
- Thorough documentation of IT security policies, procedures, and controls.
- Regular updates reflecting regulatory changes and best practices.
Version every policy with an owner and annual review date.
- Regular internal and external audits of financial reporting IT controls.
- Timely remediation of identified deficiencies.
Track every audit finding to closure with an owner and due date.
Federal Acquisition Regulation Security Requirements
Under the Revolutionary FAR Overhaul, cybersecurity and supply chain requirements are consolidated into dedicated parts. Here is where the rules live and what they require of you.
- Broad security requirements for acquisitions, including information and supply chain security for ICT products and services.
- Processing of supply chain risk information.
- Consolidates controlled unclassified information (CUI) safeguarding and incident reporting requirements.
Build a supply chain risk register covering every hardware, software, and cloud vendor in your contract environment.
- Implements prohibitions on procuring specific products and services, including the Section 889 telecommunications ban.
- Covers FASCSA exclusion orders and other national-security-based prohibitions.
- Requires representations and timely reporting when covered equipment is discovered.
Inventory network gear and cameras for prohibited manufacturers before you sign your next representation.
- Security and privacy policies specific to acquiring information and communication technology.
- Security and privacy requirements for computer systems.
- Telecommunications security requirements.
Document the security and privacy controls for every system you deliver or operate on contract.
- Procedures for safeguarding classified information within industry.
- Security safeguards required in contracts that may involve access to classified information.
Confirm your facility clearance status and DD Form 254 requirements early in capture.
- Fifteen basic safeguarding controls for systems that process federal contract information (FCI).
- Covers access limits, authentication, media sanitization, physical access, malware protection, and patching.
These controls map directly to CMMC Level 1. Do them once and reuse the evidence.
Defense FAR Supplement Cybersecurity Clauses
DoD contracts carry specific cyber clauses that flow down to every subcontractor. These are the clauses that decide whether you can bid.
- Applies when contractors handle unclassified covered defense information (CDI), including controlled technical information.
- Covers protection of unclassified contractor information systems and cyber incident reporting.
Draw a clear boundary around where CDI lives. A smaller enclave means a smaller assessment.
- Implement NIST SP 800-171 on systems that process, store, or transmit CDI.
- Report cyber incidents to DoD within 72 hours of discovery.
- Preserve images of affected systems for at least 90 days and submit malicious software when found.
- Cloud service providers must meet security requirements equivalent to the FedRAMP Moderate baseline.
Get your DIBNet reporting access (medium assurance certificate) before you need it, not during an incident.
- Maintain a current NIST SP 800-171 assessment score in SPRS.
- Basic self-assessments must be no more than three years old.
- Provide DoD access for Medium or High assessments when requested.
Keep a System Security Plan and POA&M that justify every point in your SPRS score.
- Hold the CMMC level specified in the contract at the time of award.
- Level 1 covers FCI, Level 2 covers CUI using NIST SP 800-171, Level 3 adds NIST SP 800-172.
- Requirements flow down to subcontractors at the appropriate level.
Microsoft 365 GCC High or a scoped GCC enclave can cover a large share of Level 2 controls.
- Applies when contractors provide cloud computing services to DoD.
- Requires a provisional authorization at the appropriate DoD Cloud Computing SRG impact level.
- Includes incident reporting and data location requirements.
Confirm your cloud provider’s FedRAMP and DoD impact level authorizations before architecture is finalized.
PCI DSS for Merchants, POS & Card Payments
If you take card payments, your merchant agreement requires PCI DSS compliance. Most small merchants can dramatically shrink their scope with the right POS setup.
- Identify the correct Self-Assessment Questionnaire for how you accept cards.
- Complete it annually and submit it to your acquiring bank or processor.
Validated P2PE terminals can qualify you for the shortest questionnaire.
- Keep POS systems on a network separate from guest and staff Wi-Fi.
- Restrict traffic into and out of the payment environment.
A properly configured business firewall with a separate guest Wi-Fi network is the single biggest risk reducer for hospitality.
- Change all vendor default passwords on POS systems and routers.
- Give every employee a unique login and remove access when they leave.
No shared “manager” logins. Unique PINs make every refund and void traceable.
- Never store full card numbers, CVV codes, or magnetic stripe data.
- Encrypt cardholder data whenever it travels across networks.
Use tokenization from your processor so card numbers never touch your systems.
- Keep an inventory of card readers and terminals.
- Inspect devices regularly for skimmers and tampering, and train staff to spot them.
Add a 30-second terminal check to your opening checklist.
- Run quarterly external vulnerability scans by an Approved Scanning Vendor when required.
- Remediate findings and rescan until passing.
Many processors include ASV scanning at no extra cost. Make sure it is turned on.
Don't Wait Until It's Too Late
Proactive GRC measures protect your organization from costly breaches and compliance penalties. Let's build your defense strategy today.
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