Prove your client is in control

Your clients are asked to run a governance, risk and compliance program, and most can’t staff one. Predictive GRC builds it from what the fabric already sees and runs it month after month. When something happens that could affect your client, it proposes the risk before it turns into an incident. Trust Center, built on it, shows your client’s customers what it can prove.

Your vCISO and your client’s owner approve what it drafts, so governance becomes a service you can run across your whole book.

Module 1 of 2

Predictive GRC

Predictive GRC starts from what the fabric already knows about your client, asks only for what it can’t see, and keeps the program current as the evidence changes. Your vCISO and your client’s owner make every decision.

Covers
Governance, risk and compliance
Needs
Your client confirms its suppliers and approves changes
Lands in
Your client’s registers, evidence packs and board report

Follow one client through Predictive GRC

Harbor Lending, a fictional 60-person mortgage broker, is protected by Northgate IT, a fictional MSSP. This is its program from the first day. The fabric does the reading, and a person makes every decision.

  1. 01Observe

    The day you add Harbor Lending, Predictive GRC drafts its supplier register from what the fabric already holds.

    Six suppliers, four of them never listed. Your client only has to confirm them.

  2. 02Map

    Each rule that applies is mapped once, to one set of controls.

    One test of MFA answers the FTC Safeguards Rule, the insurer’s form and a lender’s questionnaire.

  3. 03Test

    Every control is tested against evidence, not answered yes or no.

    MFA fails: registered by 41 of 60 staff and required of nobody, while the access policy says everyone. An amendment is drafted.

  4. 04Predict

    At 06:12 the payroll provider files a breach notice. By 07:34 Harbor has a proposed risk.

    It comes with the evidence and the reason it applies: the provider’s app can read every staff profile.

  5. 05Approve

    Your vCISO accepts it, and Harbor’s owner approves the treatment.

    The supplier register, the policies and the board report follow. Nothing changes without a named person.

  6. 06Prove

    Harbor’s customers see what it can prove, on a Trust Center under your brand.

    Every statement is dated and tied to evidence. MFA stays held back until practice matches policy.

Two ways to run a risk and compliance program

The usual way starts from a questionnaire and a library of templates, and records what your client says.

The usual wayPredictive GRC
Starts fromWhat your client remembers to sayWhat the fabric already observes, before anyone types a word
SuppliersA spreadsheet your client fills in onceFound from evidence, confirmed by your client, and watched for as long as the relationship lasts
Risk registerWritten for the annual reviewProposed as things happen, each risk with its evidence and the reason it applies
ControlsAnswered yes or noTested against evidence: met, not met or can’t be evaluated, with a date
PoliciesTemplatesYour client’s own policies, tested against what actually happens
When something changesNobody knows until the next reviewThe register and policies follow within hours, and a Trust Center statement comes down as soon as its evidence lapses
Who does the workYour vCISO writes itYour vCISO and your client’s owner approve it

From an event in the fabric to a proposed risk

Something happensa breach, an outage,an insolvency, a newexploited flawRecorded onceon the company ithappened to, datedAlong the fabricto everyone whodepends on it orruns the same thingDoes it apply?rules decideProposed riskwith its evidenceand the reasonit appliesA person decidesyour vCISO accepts,edits or rejects itEverything followsregister, policies,Trust Center,your viewKept under watchre-tested as theevidence changesif it applies, worked out for that client aloneif not, nothing is proposed
How an event at one company becomes a proposed risk for every client it touches
  1. Something happensA breach, an outage, an insolvency or a newly exploited flaw
  2. Recorded onceOn the company it happened to, and dated
  3. Along the fabricTo everyone who depends on it or runs the same thing
  4. Does it apply?Tested rules decide, worked out for your client alone. If not, nothing is proposed
  5. Proposed riskWith its evidence and the reason it applies
  6. A person decidesYour vCISO accepts, edits or rejects it
  7. Everything followsThe register, the policies, the Trust Center and your view
  8. Kept under watchRe-tested as the evidence changes

When something happens at one point in the fabric, such as a breach at a supplier your client depends on, a newly exploited flaw in software it runs, enforcement against a firm like it or a new rule that will apply to it, it becomes a proposed risk with its evidence and the reason it applies. Each warning comes from a tested rule, worked out for your client alone, so you can see exactly why it applies.

A fast-moving event, such as a supplier breach, becomes a proposed risk within hours. A new or changed regulation, within a day.

A named person approves every change

WhoWhat they doWhat they get
Your vCISOReviews proposed risks, suppliers, policy amendments and questionnaire answers, sets how each risk is treated and runs the quarterly reviewOne queue across every client, and work to bill for
Your client’s ownerConfirms suppliers and scope, approves treatment and policy changes, accepts a risk until a set date, approves anything published or sent, and signs the annual reportA register they can show a board, a regulator, an insurer or a customer
Outerwall reviewerWorks the review queue every day: uncertain supplier matches, companies with similar names, events that need a personFewer wrong matches reaching you
Outerwall curatorWrites, cites and versions the library of rules and control mappingsA named person accountable for every mapping

Nothing enters the register, changes a policy, goes on the Trust Center or is sent to a supplier without a named person approving it.

One set of controls, many rules

Every obligation maps to a control on one backbone, the 56 basic safeguards in CIS Controls IG1, so one test of MFA serves every rule that asks for it.

FrameworkWho it applies toWhat it produces
FTC Safeguards RuleMortgage brokers and lenders, tax preparers and finance companiesAn evidence pack mapped to 16 CFR 314
NYDFS Part 500Banks, insurers and other firms licensed by New York’s financial regulatorEvidence mapped to the sections of Part 500 it supports
SEC Regulation S-PInvestment advisers and broker-dealersService provider oversight and incident response evidence
HIPAA Security RuleMedical and dental practicesEvidence for the technical safeguards
NCUA Part 748Federally insured credit unionsEvidence for the information security program
State insurance data security lawsInsurers in states that adopted the NAIC Insurance Data Security Model LawEvidence for the information security program, third-party oversight and board reporting
NIS2Medium and large organizations in critical sectors in Ireland and the EU, MSPs and MSSPs among themEvidence for risk management, supply chain security, vulnerability handling and board oversight
DORABanks, insurers, investment firms and other financial entities in the EUA supplier register to start the register of information from, and testing evidence
GDPRAny organization that handles personal data in the EUEvidence that security is regularly tested, and oversight of processors
ISO 27001Organizations going for certificationA Statement of Applicability drafted from evidence, as an extra

Predictive GRC never certifies anyone and never says a client is compliant. Packs say what the evidence shows, and when.

Module 2 of 2

Trust Center

Your client’s customers, lenders and insurers see what it can prove, on a page on its own domain under your brand. It’s built on Predictive GRC, so every statement comes from a claim your client has approved.

Covers
What your client tells customers, lenders and insurers
Needs
Predictive GRC, and your client’s approval of every statement
Lands in
A page on your client’s own domain, under your brand

Every statement backed by evidence, or held back

Each statement is dated and tied to evidence, and it comes down the moment that evidence lapses. Live control states, scores and exposure findings never appear on it.

When a questionnaire arrives, the answers are drafted from the same approved claims and live evidence, for your client to approve, and each answer sent is kept with who it went to.

Why it matters: in 2022 Travelers asked a court to rescind a client’s cyber policy, because the application said MFA protected email, remote access and servers when it was only on the firewall. Source: Reed Smith, July 2022.

trust.harborlending.exampleunder your brand

  • Customer data encrypted at restEvidenced Oct 3, 2026
  • Suppliers reviewed and watchedEvidenced Oct 3, 2026
  • Annual penetration testEvidenced Sep 12, 2026, through Validate
  • MFA required for every accountHeld back until the evidence supports it

A statement whose evidence lapses comes down without waiting for anyone.

Governance your team can bill for, without writing it

Work you can bill for

  • A vCISO retainer, built around the quarterly risk review
  • A managed Trust Center and questionnaire service
  • Supplier reviews, for new critical suppliers and yearly for the rest
  • Policy review and ISO 27001 readiness
  • The annual board report and insurance renewals
  • Fixes that answer a line in your client’s own register

What it isn’t

  • An audit or a certification. The certification body audits
  • A library of template policies
  • A security operations center
  • A way to sell anything that doesn’t answer your client’s own register

What Outerwall gives an MSSPSee it on an example client

See it on your own clients.

Start with your own domain, then turn it on for one client and see the register, controls and evidence pack it builds.