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9 Security tips For startups
Christina Cacioppo, Co-Founder and CEO of Vanta, recently spoke at TechCrunch Sessions: SaaS 2021. In her talk, she shares nine tips for building your product with security in mind and how to engage in conversations around security from the start.
Let’s take a look at the nine best practices Christina has used for creating a secure startup:
1. You know more than you think
People often consider security and best practices for implementing security as priorities for their organization. However, most people stumble after acknowledging this need. When Christina was researching security practices for Vanta, she asked a lot of startups how they felt about security at their company. The most common response was, “I know enough to know that I should be worried and something bad could happen, but I don't know what to do or how to start.”
Not true, says Christina, because you have experience in your speciality focus area and you’ve researched, learned, and created in your space. So, in fact, you can demystify security in just the same way. “The solid engineering practices that you've learned in school or through side projects or prior companies actually get you pretty far when you think about compliance and some amount of security,” she says. Approach security with the same exploration techniques that you’re comfortable with and you’ll realize you know more than you think.
2. Communicate in English*
When people start talking about security and compliance, the lingo starts getting complicated. And, here is where the asterisk is essential to this point, it is a best practice to communicate in whatever language is natural for you. Don’t overcomplicate what you’re trying to say when you’re trying to communicate normal concepts.
“When you're talking about security, when you're talking about compliance, when you're talking about these things with your company or with your customers, you just want to be clear and communicate in words everyone understands,” Christina says. Speaking in this way makes everyone more comfortable and alleviates any pressure to have to question whether they understand overly technical terms. You can discuss security in an informal way and still get your point across.
3. Inculcate new team members
After working with hundreds of startups, Christina became increasingly aware of how important setting up culture is when onboarding new team members. As a new team member starts, it is the perfect opportunity to create a sense of importance around the objectives within the company.
You can take your early team members or new team members, tell them your best practices and then manifest that future. The new members will think this is just the way the company works and will incorporate it into daily life. “It is just easier to roll out new practices when you are smaller with fewer people on board. And so take that, and in your early days just roll out the practices that you think you want for the company over the long term,” Christina says. “It's a little bit of a magic wand thing. It seems so simple, but it ends up being pretty cool. A little bit of a way to program people in a way they don't realize.”
4. Codify in code
According to Christina: Compliance loves record keeping. This tends to be an engineering best practice, but also works well for compliance. Codifying in code acts as a single source of truth and records any changes that are made. So, if one person makes a change to the code, anyone can see who made the change.
Further, if anyone is looking for a paper trail, which is common in security compliance, the code exists. “If you're using infrastructure as code tools, you're doing code reviews, you will have whole records. If somebody comes in and asks to see these records, you can say, ‘Here we go, we’ve got them all for you,’” Christina says.
5. Review code
Review code early and often. Make this a best practice from onboarding and continue to do so throughout. “You can institute code review in your company as early as possible, even if it is non-blocking, I would recommend it,” Christina says.
Code reviews will ease the hassle of a compliance audit because there is a trail of what code has changed. This becomes especially important as a team grows and more people are committing code. You start to review if the code makes sense to system feedback, how the naming works, or if your data modeling makes sense to the larger set of users. “With code review there's the compliance benefits, there's the security benefits to see what's going on. More eyes makes bugs more shallow. And so when you're picking someone else's data model, you can understand what's going on.”
6. Build audit trails
Audit trails are a chronological set of records that provide documented evidence and basically log any events within your code in order to provide context for any changes made. Building audit trails advances forward the motion of reviewing code. Because, like reviewing code, building audit trails creates a SSoT for anyone looking to review commits. An audit trail can also be a security best practice in that there is record of every movement, both good and bad.
The caveat to this is that if you’re not communicating in English (or the language you’re most comfortable with), then the reporting may be useless. Steps might be lost, security actions might be missed, and what happened could be anything in the world if it is misunderstood. “I encourage you to think about investing in this early. This doesn't have to be fancy, this doesn't have to be human readable. Definitely doesn't have to be a UI. It's just structured data that you can query over if you ever needed to. But it's not like a human actually has to be able to read it,” Christina says.
7. Centralize tools
Centralizing your tool stack is the standard. There are thousands of different tooling options for basically anything these days. And though broader tool options are wonderful to have, using too many tools can be chaotic and wasteful. On top of that, using too many tools can be harmful to customer data because if one platform is breached, then you’re putting all your data at risk.
According to Christina, let your team experiment and figure out what tools you want. Spend time learning what works for your organization and use the one that makes the most sense. You’ll save money by not paying for four different email tools and you’ll be more secure with centralized tools in place.
8. Prompt the conversation
If you’re selling a product or service, especially one that works with customer data, your software buyers will ask about your company’s security and compliance. So, prompt the conversation around the tool that you’re selling. This step assumes that you’re ready to talk to buyers about security. Working with any sort of customer data can make buyer’s anxious and you can create assurances by getting ahead of the conversation.
“But actually prompting the conversation in that way one, makes you look like you're totally on top of things. Like, you know enough to know it's a concern, you've read their minds. You understand what a big company enterprise buyer wants,” according to Christina. In doing this, you get to shape the narrative and appear ahead of the game.
9. Do the dance
As you dive further into the conversation around security and product sales, you can expect to have to do the dance. And by that, according to Christina, expect that you will get asked a lot of questions, so be prepared to answer them in a way that makes sense for you but also remains appealing for the buyer. “There is good and bad to it. But it has just ended up being much more inevitable and much more of something that companies do need to engage in. So figure out a way to engage in the dance, in a way that works for you.”
Want to learn more about Christina's nine security tips for startups? Check out her talk from TechCrunch Sessions: SaaS 2021 to learn more.
Determine whether the GDPR applies to you and if so, if you are a processor or controller (or both)
Do you sell goods or service in the EU or UK?
Do you sell goods or services to EU businesses, consumers, or both?
Do you have employees in the EU or UK?
Do persons from the EU or UK visit your website?
Do you monitor the behavior of persons within the EU?
Create a Data Map by taking the following actions
Identify and document every system (i.e. database, application, or vendor) which stores or processes EU or UK based personally identifiable information (PII)
Document the retention periods for PII in each system
Determine whether you collect, store, or process “special categories” of data
Determine whether your Data Map meets the requirements for Records of Processing Activities (Art. 30)
Determine whether your Data Map includes the following information about processing activities carried out by vendors on your behalf
Determine your grounds for processing data
For each category of data and system/application have you determined the lawful basis for processing based on one of the following conditions?
Take inventory of current customer and vendor contracts to confirm new GDPR-required flow-down provisions are included
Review all customer contracts to determine that they have appropriate contract language (i.e. Data Protection Addendums with Standard Contractual Clauses)
Review all in-scope vendor contracts to determine that they have appropriate contract language (i.e. Data Protection Addendums with Standard Contractual Clauses)
Have you performed a risk assessment on vendors who are processing your PII?
Determine if you need to do a Data Protection Impact Assessment
Is your data processing taking into account the nature, scope, context, and purposes of the processing, likely to result in a high risk to the rights and freedoms of natural persons?
Review product and service design (including your website or app) to ensure privacy notice links, marketing consents, and other requirements are integrated
Does the notice to the data subject include the following items?
Does the notice also include the following items?
Do you have a mechanism for persons to change or withdraw consent?
Update internal privacy policies to comply with notification obligations
Update internal privacy notices for EU employees
Determine if you need to appoint a Data Protection Officer, and appoint one if needed
Have you determined whether or not you must designate a Data Protection Officer (DPO) based on one of the following conditions (Art. 37)?
If you export data from the EU, consider if you need a compliance mechanism to cover the data transfer, such as model clauses
If you transfer, store, or process data outside the EU or UK, have you identified your legal basis for the data transfer (note: most likely covered by the Standard Contractual Clauses)
Have you performed and documented a Transfer Impact Assessment (TIA)?
Confirm you are complying with other data subject rights (i.e. aside from notification)
Do you have a defined process for timely response to Data Subject Access Requests (DSAR) (i.e. requests for information, modification or deletion of PII)?
Are you able to provide the subject information in a concise, transparent, intelligible and easily accessible form, using clear and plain language?
Do you have a process for correcting or deleting data when requested?
Do you have an internal policy regarding a Compelled Disclosure from Law Enforcement?
Determine if you need to appoint an EU-based representative, and appoint one if needed
Have you appointed an EU Representative or determined that an EU Representative is not needed based on one of the following conditions?
If operating in more than one EU state, identify a lead Data Protection Authority (DPA)
Do you operate in more than one EU state?
If so, have you designated the Supervisory Authority of the main establishment to act as your Lead Supervisory Authority?
Implement Employee Trainings to Demonstrate Compliance with GDPR Principles and Data Subject Rights
Have you provided appropriate Security Awareness and Privacy training to your staff?
Update internal procedures and policies to ensure you can comply with data breach response requirements
Have you created and implemented an Incident Response Plan which included procedures for reporting a breach to EU and UK Data Subjects as well as appropriate Data Authorities?
Do breach reporting policies comply with all prescribed timelines and include all recipients i.e. authorities, controllers, and data subjects?
Implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk
Have you implemented encryption of PII at rest and in transit?
Have you implemented pseudonymization?
Have you implemented appropriate physical security controls?
Have you implemented information security policies and procedures?
Can you access EU or UK PII data in the clear?
Do your technical and organizational measure ensure that, by default, only personal data which are necessary for each specific purpose of the processing are processed?
Develop a roadmap for successful implementation of an ISMS and ISO 27001 certification
Implement Plan, Do, Check, Act (PDCA) process to recognize challenges and identify gaps for remediation
Consider ISO 27001 certification costs relative to org size and number of employees
Clearly define scope of work to plan certification time to completion
Select an ISO 27001 auditor
Set the scope of your organization’s ISMS
Decide which business areas are covered by the ISMS and which are out of scope
Consider additional security controls for business processes that are required to pass ISMS-protected information across the trust boundary
Inform stakeholders regarding scope of the ISMS
Establish an ISMS governing body
Build a governance team with management oversight
Incorporate key members of top management, e.g. senior leadership and executive management with responsibility for strategy and resource allocation
Conduct an inventory of information assets
Consider all assets where information is stored, processed, and accessible
- Record information assets: data and people
- Record physical assets: laptops, servers, and physical building locations
- Record intangible assets: intellectual property, brand, and reputation
Assign to each asset a classification and owner responsible for ensuring the asset is appropriately inventoried, classified, protected, and handled
Execute a risk assessment
Establish and document a risk-management framework to ensure consistency
Identify scenarios in which information, systems, or services could be compromised
Determine likelihood or frequency with which these scenarios could occur
Evaluate potential impact of each scenario on confidentiality, integrity, or availability of information, systems, and services
Rank risk scenarios based on overall risk to the organization’s objectives
Develop a risk register
Record and manage your organization’s risks
Summarize each identified risk
Indicate the impact and likelihood of each risk
Document a risk treatment plan
Design a response for each risk (Risk Treatment)
Assign an accountable owner to each identified risk
Assign risk mitigation activity owners
Establish target dates for completion of risk treatment activities
Complete the Statement of Applicability worksheet
Review 114 controls of Annex A of ISO 27001 standard
Select controls to address identified risks
Complete the Statement of Applicability listing all Annex A controls, justifying inclusion or exclusion of each control in the ISMS implementation
Continuously assess and manage risk
Build a framework for establishing, implementing, maintaining, and continually improving the ISMS
Include information or references to supporting documentation regarding:
- Information Security Objectives
- Leadership and Commitment
- Roles, Responsibilities, and Authorities
- Approach to Assessing and Treating Risk
- Control of Documented Information
- Internal Audit
- Management Review
- Corrective Action and Continual Improvement
- Policy Violations
Assemble required documents and records
Review ISO 27001 Required Documents and Records list
Customize policy templates with organization-specific policies, process, and language
Establish employee training and awareness programs
Conduct regular trainings to ensure awareness of new policies and procedures
Define expectations for personnel regarding their role in ISMS maintenance
Train personnel on common threats facing your organization and how to respond
Establish disciplinary or sanctions policies or processes for personnel found out of compliance with information security requirements
Perform an internal audit
Allocate internal resources with necessary competencies who are independent of ISMS development and maintenance, or engage an independent third party
Verify conformance with requirements from Annex A deemed applicable in your ISMS's Statement of Applicability
Share internal audit results, including nonconformities, with the ISMS governing body and senior management
Address identified issues before proceeding with the external audit
Undergo external audit of ISMS to obtain ISO 27001 certification
Engage an independent ISO 27001 auditor
Conduct Stage 1 Audit consisting of an extensive documentation review; obtain feedback regarding readiness to move to Stage 2 Audit
Conduct Stage 2 Audit consisting of tests performed on the ISMS to ensure proper design, implementation, and ongoing functionality; evaluate fairness, suitability, and effective implementation and operation of controls
Address any nonconformities
Ensure that all requirements of the ISO 27001 standard are being addressed
Ensure org is following processes that it has specified and documented
Ensure org is upholding contractual requirements with third parties
Address specific nonconformities identified by the ISO 27001 auditor
Receive auditor’s formal validation following resolution of nonconformities
Conduct regular management reviews
Plan reviews at least once per year; consider a quarterly review cycle
Ensure the ISMS and its objectives continue to remain appropriate and effective
Ensure that senior management remains informed
Ensure adjustments to address risks or deficiencies can be promptly implemented
Calendar ISO 27001 audit schedule and surveillance audit schedules
Perform a full ISO 27001 audit once every three years
Prepare to perform surveillance audits in the second and third years of the Certification Cycle
Consider streamlining ISO 27001 certification with automation
Transform manual data collection and observation processes into automated and continuous system monitoring
Identify and close any gaps in ISMS implementation in a timely manner
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Determine which annual audits and assessments are required for your company
Perform a readiness assessment and evaluate your security against HIPAA requirements
Review the U.S. Dept of Health and Human Services Office for Civil Rights Audit Protocol
Conduct required HIPAA compliance audits and assessments
Perform and document ongoing technical and non-technical evaluations, internally or in partnership with a third-party security and compliance team like Vanta
Document your plans and put them into action
Document every step of building, implementing, and assessing your compliance program
Vanta’s automated compliance reporting can streamline planning and documentation
Appoint a security and compliance point person in your company
Designate an employee as your HIPAA Compliance Officer
Schedule annual HIPAA training for all employees
Distribute HIPAA policies and procedures and ensure staff read and attest to their review
Document employee trainings and other compliance activities
Thoroughly document employee training processes, activities, and attestations
Establish and communicate clear breach report processes
to all employees
Ensure that staff understand what constitutes a HIPAA breach, and how to report a breach
Implement systems to track security incidents, and to document and report all breaches
Institute an annual review process
Annually assess compliance activities against theHIPAA Rules and updates to HIPAA
Continuously assess and manage risk
Build a year-round risk management program and integrate continuous monitoring
Understand the ins and outs of HIPAA compliance— and the costs of noncompliance
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