1. Code Review: The Backbone of Compliance & Security
As organisations face an increasing number of regulations to secure their data and systems, compliance has become a fundamental part of software development. Various frameworks, such as NIS2, GDPR, HIPAA, and PCI-DSS, require organisations to implement secure coding practices.
NIS2 Directive: Article 21 obliges essential and important entities to implement appropriate cybersecurity risk management measures, which include ensuring security in the development, acquisition and maintenance of network and information systems. This includes vulnerability management and secure development practices, such as conducting code reviews.
GDPR: Article 32 of the GDPR requires both data controllers and processors to implement technical and organisational measures to protect personal data. This includes security practices such as pseudonymisation, encryption and ensuring the confidentiality, integrity and availability of processing systems. Secure coding practices as part of these measures help mitigate risks such as unauthorised access, data breaches or accidental loss, and therefore play a critical role in the GDPR’s compliance requirements.
HIPAA: US healthcare organisations are required to comply with the Health Insurance Portability and Accountability Act (HIPAA), which includes strict safeguards for electronic protected health information (ePHI). Under § 164.308(a), the Security Rule mandates that covered entities and business associates implement a security management process to prevent, detect, and address security breaches. A thorough code review helps meet these requirements by identifying potential vulnerabilities in software. It also helps organisations comply with key provisions such as risk analysis, risk management, and periodic reviews of system activity.
PCI-DSS 4.0: For organisations handling payment card data, the Payment Card Industry Data Security Standard now emphasises the importance of secure software development in accordance with Requirement 6.2.1. This includes the secure coding practices required to mitigate vulnerabilities. Code reviews – whether automated or manual – are critical to meeting these standards as they verify compliance with secure coding practices and identify any vulnerabilities prior to product release, which helps organisations comply with industry requirements. In addition, requirement 6.2.3 of the standard emphasises the testing of specialised and custom software prior to release. Also, applications intended for public access should be subject to additional controls in accordance with Requirement 6.4 to address current threats.
The Role of Code Review in Compliance: Systematic code review ensures that the coding conforms to the security requirements defined by these frameworks. Code review verifies that vulnerabilities such as weak authentication or insecure data handling are addressed before deployment, ensuring compliance with mandatory security requirements.
2. Mapping Code Review to Security Standards
Security by Design: Security frameworks such as ISO/IEC 27001 emphasize the integration of security controls throughout the software development lifecycle. In particular, ISO/IEC 27001:2013, Annex A.14 highlights the importance of security in development and support processes. Code reviews act as a critical checkpoint to validate these security controls at the code level, and to ensure that security-by-design principles are consistently applied and maintained.
Addressing Misconfigurations and Gaps: Key security controls – such as authentication, encryption, and access management – are fundamental to robust cybersecurity, but they are sometimes implemented with minor bugs or misconfigurations that leave them vulnerable to exploitation. During a code review, security specialists meticulously examine these elements to identify weaknesses and ensure they meet required standards. This proactive identification and remediation process reduces the risk of compliance violations and helps prevent security breaches. In the context of regulatory compliance, NIST SP 800-53, Revision 5, Control CA-7 underscores the need for continuous monitoring and assessment, which code review supports by verifying the proper implementation of controls at the code level.
3. Key Compliance Challenges Addressed by Code Review
Meeting Regulatory Deadlines: Compliance frameworks often come with tight deadlines for updates and patches. By automating parts of the code review process with tools such as Static Application Security Testing (SAST), organisations can streamline code validation and efficiently meet regulatory deadlines.
Auditable Security: For compliance audits, organisations need to demonstrate that security measures have been implemented correctly. A well-documented code review process serves as proof of due diligence. For instance, during a GDPR audit, code review logs can show how security controls were integrated to protect personal data.
4. Code review reduces legal and financial risk
The Cost of Non-Compliance: Failure to comply with cybersecurity standards can result in severe financial and legal consequences.. Under the GDPR, organisations face fines of up to €20 million or 4% of their worldwide annual turnover (Article 83). The implementation of a thorough code review process helps mitigate these risks by identifying and addressing potential vulnerabilities in line with security standards before they lead to costly breaches.
Real-Life Consequences: The 2017 Equifax data breach, one of the most notorious in history, exposed the sensitive data of 147 million people. This breach occurred because Equifax failed to patch a known vulnerability in the Apache Struts web application framework, despite being aware of it for months. The company likely could have identified and addressed this issue before the breach occurred if it had conducted regular, comprehensive code reviews. As a result of this oversight, Equifax faced a $575 million settlement with the Federal Trade Commission (FTC) and other agencies, not to mention severe reputational damage. Additionally, Equifax has had to allocate funds for ongoing security improvements and compensation to affected consumers.
5. Harmonisation of Code Review with Compliance Tools
Compliance Tools in Practice: Advanced tools such as Static Application Security Testing (SAST) and Dynamic Application Security Testing (DAST) can be integrated into code review processes. These tools scan source code for vulnerabilities and provide developers with immediate insight to help them comply with standards such as PCI-DSS.
Maintaining Continuous Compliance: As software evolves, continuous code review combined with automated tools ensures that every update or patch meets compliance requirements. This approach is particularly suited to Agile and DevOps methodologies that involve frequent code changes.
6. Bridge the Gap Between Developers and Compliance Teams
In order to create secure, compliant software, it is essential to bridge the gap between developers and compliance teams. When both teams collaborate early, they can identify potential compliance issues from the outset, saving time and resources. With clear communication tools and regular training, developers can better understand regulatory requirements, while compliance teams gain insight into development needs. By integrating compliance checks into the development process, teams can continuously monitor for issues and address them quickly. This approach fosters a collaborative environment that ensures software is both innovative and fully compliant.
7. Code Review in Action: Real-World Impact on Security Standards
Case Study: Consider a company that develops a marketplace for electronic commerce. During a code review, the team discovered a critical vulnerability that would have allowed unauthorised access to customer accounts. The remediation of this issue prior to the release of the software not only ensured PCI-DSS compliance, but also prevented a potential data breach.
Outcome and Benefits: The company not only avoided penalties for non-compliance, but also improved the overall security and reliability of its marketplace. As a result, it gained the trust of its user base.
Organisations can meet today’s compliance requirements and prepare for future challenges by integrating a robust code review process into their software development. It also ensures that code is secure from the beginning, so that organisations can avoid the costly consequences of non-compliance, while building trust with users and stakeholders.
