The HITRUST CSF is a risk-based framework. To understand why, one must understand the intent of selecting and implementing any specified set of controls, whether it is a custom set developed from a traditional risk analysis or one tailored from a pre-defined control baseline developed from such a risk analysis (e.g., ISO/IEC 27001 or NIST SP 800- 53, both of which HITRUST leverages in the CSF). Regardless of the method used, an organization must implement all the selected controls to manage risk at a level deemed acceptable by its leadership. Failure to fully implement all the specified controls necessarily results in excessive residual risk, which then implies that an organization would take a compliance-oriented approach to implementing and maintaining the selected controls, which were of course selected based on an analysis of risk.


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