Build Your First Controls Library: Why a Spreadsheet is Best

You've just joined a company with immature GRC practices. The policies exist somewhere. The standards are documented... somewhere else. Compliance requirements are scattered across various documents, and when your executive team asks for a status update on NIST CSF 2.0 implementation, you feel that familiar knot in your stomach. Sound familiar?

"We have policies and we have standards... but we have no central library. I want an easier way to find them rather than trawling through loads of different standards docs." — This sentiment, expressed by a GRC professional on Reddit, captures the frustration many face in developing programs.

If you're nodding along, you're not alone. The good news is that there's a straightforward solution that doesn't require a six-figure investment or months of implementation: a simple spreadsheet.

In this guide, we'll walk through why a spreadsheet is the perfect starting point for your controls library and how to build one that delivers immediate value while setting you up for future success.

What is a Controls Library and Why Do You Need One?

A controls library is a centralized repository that documents all the security and compliance controls your organization has implemented. Think of it as the single source of truth that answers the question: "What are we doing to manage our risks and meet our compliance obligations?"

Without a central controls library, your GRC program will struggle with:

• Redundant efforts: Teams implementing the same controls multiple times because they don't know what already exists
• Compliance gaps: Missing controls that should be in place for frameworks like ISO 27001 or NIST CSF
• Audit nightmares: Scrambling to locate evidence during assessments
• Stakeholder confusion: Different answers depending on who you ask

As one Reddit user aptly put it: "Our policies reference the implemented controls of the standards, so we have no central library." This approach inevitably leads to inconsistencies, inefficiencies, and missed compliance requirements.

A well-structured controls library solves these problems by:

1. Creating consistency across your organization
2. Reducing duplicate work by making existing controls visible
3. Simplifying compliance mapping across multiple frameworks
4. Streamlining risk assessments by connecting controls to risks
5. Providing clear accountability for control implementation and maintenance

The "Low-Tech" Advantage: Why a Spreadsheet Beats a GRC Tool (For Now)

When building your first controls library, you might be tempted to immediately invest in a dedicated GRC platform like ServiceNow. While these tools offer robust capabilities, they often present significant challenges for immature programs:

• They're expensive (often $50,000+ annually)
• They require substantial configuration
• They demand specialized expertise to implement and maintain
• They can take months to deploy effectively

As one GRC professional noted: "ServiceNow is technically capable of serving as a control library, but realistically, it's probably out of reach for your current program."

This is where the humble spreadsheet shines as your low-hanging fruit solution. Here's why:

1. Simplicity and Accessibility

Everyone in your organization already knows how to use a spreadsheet. There's no learning curve, special training, or technical expertise required. This means you can start populating your library immediately without waiting for IT resources or specialized knowledge.

2. Cost-Effectiveness

Spreadsheets are essentially free, requiring no additional budget approval or procurement process. This allows you to demonstrate value before requesting investment in more sophisticated tools.

3. Flexibility and Customization

You can easily adapt your spreadsheet to fit your organization's specific needs, adding or modifying fields as your program matures without being constrained by a vendor's data model.

4. Immediate Value

Perhaps most importantly, you can create a functional controls library in a spreadsheet in a single afternoon and start reaping the benefits immediately. This rapid time-to-value is crucial for building momentum in an immature program.

As one Reddit user wisely advised: "You're better off starting light: define your core controls in a clear, scalable spreadsheet."

Action Plan: A Step-by-Step Guide to Building Your Controls Library Spreadsheet

Now let's get practical. Here's how to build an effective controls library using a spreadsheet in four straightforward steps:

Step 1: Don't Start from Scratch - Leverage Existing Frameworks

The most common mistake when building a controls library is trying to reinvent the wheel. Fortunately, recognized authorities have already done much of the heavy lifting for you.

"I would recommend starting with downloading the NIST CSF requirements (i.e., controls) spreadsheet and leveraging that as your starting point," advised one GRC practitioner on Reddit.

Here's where to find ready-made control templates:

• NIST CSF 2.0: The latest Cybersecurity Framework provides an excellent baseline for organizations of all types.
• NIST 800-53: For more comprehensive security controls, especially if you work with government clients.
• ISO 27001: If your organization needs to align with international standards.

Pro Tip: NIST provides their entire security and privacy control catalog for SP 800-53 and control baselines for SP 800-53B in spreadsheet format, available directly from their website. This gives you a massive head start.

Step 2: Structure Your Spreadsheet - The Four Essential Columns

Your controls library spreadsheet needs four fundamental columns to be effective:

Column A: Control ID

This is a unique identifier for each control. Use standard naming conventions where applicable (e.g., AC-01 from NIST 800-53) or create your own consistent system (e.g., IAM-001 for Identity and Access Management controls).

The Control ID serves as the primary key for your library and enables clear communication about specific controls across your organization.

Column B: Description

Provide a clear, concise explanation of what the control entails. Importantly, write this for humans, not just auditors. Use plain language that system owners and implementers can understand.

For example, instead of just writing "MFA," describe it as: "All administrative access to critical systems must be protected by Multi-Factor Authentication (MFA)."

Remember what one practitioner noted: "At the end of the day, the controls should be defined in a way that the system owners can actually implement them."

Column C: Framework Mapping

This column connects each control to all relevant compliance frameworks. This is where the real magic happens in terms of efficiency.

For example, a password control might be mapped to:

• NIST CSF 2.0 (PR.AC-1)
• ISO 27001 (A.9.4.3)
• PSPF (Policy 11)
• ISM (Guidelines 0417, 1173)

This mapping allows you to quickly generate framework-specific control lists when needed for compliance reporting or gap analysis.

Column D: Evidence Link

This critical column provides a direct link to where the evidence for each control is stored. This might be:

• A link to a SharePoint document
• A path to a network folder
• A reference to a specific tool or dashboard
• A Confluence page URL

As one GRC professional emphasized: "I would definitely recommend adding to your spreadsheet from the start: a column for evidence tracking... If you can show where the evidence lives for each control, it makes assessments (and tool migrations) way smoother later on."

This simple addition will save you countless hours during audits and assessments by eliminating the "evidence scavenger hunt."

Step 3: Populate Your Library

With your structure in place, it's time to populate your library:

1. Start by importing the controls from your chosen baseline framework (e.g., NIST CSF 2.0)
2. Review your existing policies and standards to identify controls already documented
3. Add organization-specific controls that may not be in standard frameworks
4. Begin mapping your controls to additional frameworks your organization must comply with
5. Document the location of existing evidence for each control

Remember, this is an iterative process. Start with the basics and expand over time.

Step 4: Review and Iterate

Once you have your initial library, schedule regular reviews to:

1. Update controls based on new compliance requirements
2. Add newly implemented controls
3. Refine control descriptions based on feedback
4. Improve framework mappings as your understanding deepens
5. Update evidence links as your documentation evolves

A quarterly review cycle is typically sufficient for most organizations, though you may need more frequent updates during periods of significant change.

Avoiding the Pitfalls: Pro-Tips for Managing Your Spreadsheet Library

While spreadsheets are an excellent starting point, they do come with potential challenges. Let's address these head-on and provide practical solutions to ensure your spreadsheet-based controls library remains effective.

The Human Error Challenge

Studies show that nearly 90% of spreadsheets contain errors, often due to manual data entry. When managing compliance, these errors can lead to serious gaps.

Solution: Implement strict access controls and data validation. Limit editing rights to a select few team members and use dropdown menus for status fields and predefined values wherever possible. This dramatically reduces the risk of inconsistent or incorrect data entry.

The Version Control Nightmare

Without proper management, you might end up with multiple versions of your controls library floating around the organization, leading to confusion about which is authoritative.

Solution: Establish a clear naming convention (e.g., Controls_Library_v1.2_2023-10-15.xlsx) and store the master file in a centralized, access-controlled location. Consider using platforms with version history like SharePoint or Google Sheets to track changes automatically.

The Collaboration Challenge

Multiple team members may need to update the library simultaneously, creating potential conflicts.

Solution: Use cloud-based spreadsheet solutions like Google Sheets or Office 365 that support real-time collaboration. Establish clear roles and responsibilities for who can edit which sections of the spreadsheet.

The Static Data Problem

Unlike dedicated GRC tools, spreadsheets don't automatically update or provide real-time compliance posture.

Solution: Schedule regular (monthly or quarterly) reviews of your controls library. Create calendar reminders and assign clear ownership for these reviews to ensure they actually happen. During these reviews, update control statuses, evidence links, and framework mappings.

The Scalability Concern

As your program matures and the number of controls grows, a simple spreadsheet may become unwieldy.

Solution: Use tabs to organize controls by domain (e.g., Access Control, Risk Management, etc.) and leverage features like filtering, sorting, and pivot tables to maintain usability even as your library expands.

Your Spreadsheet as a Launchpad: Planning for Future GRC Maturity

Your spreadsheet-based controls library isn't just a temporary solution—it's a strategic asset that will facilitate your journey toward GRC maturity.

The Foundation for Tool Migration

When you eventually implement a dedicated GRC tool like ServiceNow, your well-structured spreadsheet will serve as the perfect data source for migration.

As one Reddit user noted: "Once your company gets ServiceNow implemented, you can use your spreadsheet as a baseline to upload into ServiceNow as the controls repository."

The time you invest now in creating clean, well-organized control data will pay enormous dividends during the migration process.

Streamlining Risk Assessments

Your controls library will serve as the foundation for more sophisticated risk assessments. By having a clear inventory of existing controls, you can:

1. Identify gaps relative to your risk profile
2. Prioritize control implementations based on risk exposure
3. Track the effectiveness of controls in mitigating specific risks

Accelerating Compliance Mapping

As regulatory requirements evolve and your organization faces new compliance obligations, your framework mapping column will allow you to quickly identify:

1. Which existing controls satisfy new requirements
2. What gaps exist that require new controls
3. How changes to one control might impact multiple compliance frameworks

This capability is particularly valuable for organizations navigating complex regulatory landscapes where frameworks like NIST CSF 2.0, ISO 27001, PSPF, and ISM overlap.

Building the Business Case for Advanced GRC Tools

When the time comes to invest in a dedicated GRC platform, your spreadsheet will provide concrete evidence of:

1. The volume of controls you're managing
2. The complexity of your compliance mapping requirements
3. The limitations you've encountered with the spreadsheet approach

This data will help you build a compelling business case for investment in tools like ServiceNow, Centraleyes, or CyberSaint by demonstrating clear ROI potential.

Implementation Example: A Sample Controls Library Spreadsheet

To make this concrete, let's look at how a simple controls library spreadsheet might be structured. This example focuses on access control requirements across multiple frameworks:

Control ID	Description	Framework Mapping	Evidence Link
AC-01	Access Control Policy: The organization must develop, document, and disseminate an access control policy that addresses purpose, scope, roles, responsibilities, and compliance.	NIST CSF 2.0 (PR.AC-1)<br>ISO 27001 (A.5.1.1)<br>ISM (0389)	Link to Policy Document
AC-02	Account Management: The organization must manage system accounts, including establishing, activating, modifying, disabling, and removing accounts.	NIST CSF 2.0 (PR.AC-4)<br>ISO 27001 (A.9.2.1)<br>PSPF (Policy 11)	Link to Account Management Procedure
AC-03	Multi-Factor Authentication (MFA): All administrative access to critical systems and applications must be protected by multi-factor authentication.	NIST CSF 2.0 (PR.AC-7)<br>ISO 27001 (A.9.4.2)<br>ISM (0974, 1173)	Link to MFA Configuration Standards
AC-04	Least Privilege: Access permissions to systems and data must be limited to only those required for users to perform their job functions.	NIST CSF 2.0 (PR.AC-4)<br>ISO 27001 (A.9.2.3)<br>ISM (1175)	Link to Role Definition Document
AC-05	Session Timeout: The system must automatically terminate a user session after 15 minutes of inactivity.	NIST CSF 2.0 (PR.AC-7)<br>ISO 27001 (A.9.4.2)<br>PSPF (Policy 11)	Link to Configuration Standards

This simple structure provides a clear, accessible way to document your controls while enabling easy filtering and sorting by framework, control domain, or other criteria.

Getting Started Today

Ready to build your first controls library? Here's a simple checklist to get you started:

1. Download a baseline framework spreadsheet:
   • NIST CSF 2.0 controls (available from NIST)
   • NIST 800-53 controls (available as spreadsheets)
   • ISO 27001 Annex A controls (available from various sources)
2. Set up your spreadsheet structure:
   • Create the four essential columns (ID, Description, Framework Mapping, Evidence Link)
   • Add optional columns as needed (Owner, Implementation Status, Review Date, etc.)
   • Consider using tabs to organize by control family or domain
3. Begin populating with your existing controls:
   • Review your current policies and standards
   • Document controls that are already implemented
   • Note gaps where controls should exist but don't yet
4. Establish a maintenance process:
   • Determine who will own the controls library
   • Set a regular review schedule
   • Create a process for adding new controls
5. Share with stakeholders:
   • Introduce the central controls library to your team
   • Educate on how to use it for compliance activities
   • Gather feedback for improvements

Conclusion: Take Control of Your Controls

As GRC professionals in immature programs, we're often caught in a frustrating position: executives demanding compliance with frameworks like NIST CSF 2.0 or ISO 27001, while we lack the basic infrastructure to deliver effectively.

A spreadsheet-based controls library isn't just a stopgap—it's the most pragmatic first step toward building a mature GRC program. It provides immediate value, requires minimal investment, and creates a foundation for future growth.

As one Reddit user put it: "I think that sounds like a perfect plan."

By creating a simple, centralized library of your controls, you'll:

• Stop "trawling through loads of different standards docs"
• Create a single source of truth for compliance activities
• Simplify evidence collection during assessments
• Build a valuable asset for your eventual migration to dedicated GRC tools

So, resist the urge to immediately jump into complex GRC platforms. Instead, start with the low-hanging fruit: a well-structured controls library spreadsheet that delivers immediate value while setting you up for future success.

Your first controls library doesn't need to be perfect—it just needs to exist. The sooner you start, the sooner you'll begin bringing order to your organization's GRC chaos.

Frequently Asked Questions (FAQ)

What is a GRC controls library?

A GRC controls library is a centralized, organized repository of all the security and compliance controls your organization uses to manage risk and meet regulatory requirements. It acts as the single source of truth for your security measures, documenting what each control is, mapping it to relevant frameworks like NIST CSF 2.0 or ISO 27001, and linking to evidence of its implementation. This prevents redundant work, simplifies audits, and ensures consistency.

Why use a spreadsheet for a controls library instead of a dedicated GRC tool?

For organizations with new or immature GRC programs, a spreadsheet is the ideal starting point because it is simple, cost-effective, flexible, and delivers immediate value without a steep learning curve. While powerful GRC platforms are beneficial for mature programs, they are often expensive and complex to set up. A spreadsheet allows you to build a functional library quickly and create a clean data set that can be easily migrated to an advanced tool later.

How do I start building a controls library?

The best way to start is by leveraging an existing, recognized framework, such as the NIST Cybersecurity Framework (CSF) 2.0, as your foundation. Download a pre-existing control set from a reputable source like NIST, then structure your spreadsheet with four essential columns: a unique Control ID, a clear Description, Framework Mapping to connect it to compliance requirements, and an Evidence Link.

What are the most essential pieces of information to include in my controls library?

Every control in your library should have at least four key components: a unique Control ID, a clear Description in plain language, Framework Mapping to all relevant compliance standards (e.g., NIST, ISO, PSPF), and a direct Evidence Link. This last column is crucial, as it provides a direct path to the documentation or reports that prove a control is in place, saving countless hours during audits.

How do I keep my controls library spreadsheet from becoming a mess?

To maintain an effective spreadsheet library, you should implement strict access controls, use data validation, establish clear version control, and schedule regular reviews. Use a cloud-based tool like Google Sheets or Office 365 for collaboration and version history. Limit editing rights to a core team and use dropdown menus for standardized fields to minimize human error. Finally, assign ownership and conduct quarterly reviews to keep the data accurate and current.

When should our organization move from a spreadsheet to a dedicated GRC tool?

You should consider moving to a dedicated GRC tool when your spreadsheet becomes too unwieldy to manage, your team needs real-time automation and reporting, or the complexity of your compliance requirements exceeds what a static spreadsheet can handle. The spreadsheet serves as your launchpad; once you have a mature set of controls, its limitations will become clear, and you will have a strong business case and a clean dataset ready for migration to a more powerful platform.

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Have you built a controls library using a spreadsheet? What challenges did you face? Share your experiences in the comments below!