What must exist for a control to be marked as a compensating control?

For a control to be marked as a compensating control, it is essential that both a documented business constraint and a legitimate technical constraint exist. This requirement highlights the importance of understanding the context in which compensating controls are implemented.

A documented business constraint pertains to a situation where adhering to standard security controls is either impractical or impossible due to the specific needs of the business. Such constraints could relate to budget limitations, operational requirements, or the nature of the business itself that prevents the implementation of standard controls.

Conversely, a legitimate technical constraint refers to technological limitations that can hinder the application of ordinary security measures. This could include legacy systems that cannot support modern security features or unique system architectures that present challenges in deploying certain security controls.

When both types of constraints are present, they justify the necessity of implementing compensating controls. These controls serve as alternative measures that mitigate risk in place of the standard controls that cannot be used due to the identified constraints. Regular review by security personnel, while important in maintaining the effectiveness and relevance of controls, does not alone qualify a control as compensating without the foundational justification of documented constraints.