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Our approach to threat modeling
In this series, you’ll hear directly from Vanta’s Security, Enterprise Engineering, and Privacy, Risk, & Compliance Teams to learn about the team’s approach to keeping Vanta — and most importantly, our customers — secure.
The following post comes from our Security Team and explains our approach to threat modeling.
What is threat modeling?
Threat modeling is the process of identifying and understanding the potential threats and risks that can impact a given business, system, network, or feature.
The goal of threat modeling is to make better decisions. We do this by building a better mental model of the world, keeping things in mind such as potential attacker’s profiles, motivation, goals, and likely attack vectors. Many of us model threats every day—when making decisions such as choosing to buckle your seatbelt, looking both ways before you cross the street, and more.
How does Vanta approach threat modeling?
At Vanta, we use threat modeling as a tool to help share knowledge and improve our mental model of Vanta as a company, and of the environment in which we operate. These exercises are most frequently run (though not always) by the Security team, and are held on recurring cadences and on an as-needed basis.
We don’t maintain a canonical “threat model” at any given point in time. Instead, we view the exercise itself as the primary mechanism through which we benefit. This is because the discussion that arises during a threat modeling exercise is what improves our mental model and enables us to make better decisions.
In other words: “Threat models are useless. Threat modeling is essential.”
When does the Vanta security team threat model?
We view threat modeling as a team and organizational muscle that requires regular exercise. It can be fun, enlightening and interesting! This means we get together for threat modeling exercises on at least a monthly basis, if not more frequently. Sometimes we'll threat model a given feature, and other times we’ll pick a sample scenario to model and discuss. For some added fun, sometimes we’ll even get together to model threats around a given theme, event, or season.
In addition, we strive to include a wide range of teammates across Vanta in our exercises. This can depend on the topic at hand but often includes individuals from our Enterprise Engineering, Privacy, Risk, & Compliance, Engineering, and Product teams, as well as from our operational and customer-facing teams. Not only does this help evolve our individual mental models of risk, but it also widens our collective lens on hidden risks and opportunities for improvement across the organization to make more informed decisions.
Keep in mind that if you’re focusing on a specific feature or project, it’s helpful to start as early as possible, such as in the design phase. This lowers the cost of any big changes that need to be made.
What are the core steps you follow?
Here are the core steps we follow for our threat modeling exercises:
1. Define your goals
Discuss and agree upon what your collective goals are for your threat modeling exercise, and jot this down to help ensure all teammates are on the same page. This could be to model threats for a given feature or project, or something more broad—such as to help inform your team’s planning for a given quarter. Defining your goals up front can help you keep your discussion more focused.
2. Define your scope
Identify the data, systems, and processes at hand that you’re protecting and understand how they’re used, as well as any dependencies. This helps your team to go into greater depth than they could if you had to keep expanding the breadth of your focus.
3. Identify threats
Brainstorm the most significant threats that could compromise the confidentiality, integrity, or availability of your system. While we often consider external attackers, be sure to also consider internal actors, whether intentional or unintentional.
4. Identify controls
Enumerate the controls that are either in place or could be put into place to mitigate each threat, including both preventative and detective controls.
5. Identify gaps
Model in the gaps that could result in controls failing to block a particular threat. For example, anti-malware doesn’t always detect the malware. What would happen next? What would the next stage of the attack be? Do you have further controls for that step?
6. Next steps
Based on the discussion, identify action items and make sure you address them. Walk away better informed and make good decisions!
During our threat modeling exercises, we use diagramming tools to communicate and connect information and create a clear visual representation of your threat model. This is particularly beneficial during exercises that incorporate a variety of stakeholders—we view these diagrams as primarily for those who are in the room instead of as an artifact for the future.
Tips for threat modeling
An important point to remember is that there are many approaches to threat modeling. Our recommendation is to find what works best for your organization to ensure that you’re able to threat model effectively when you need it most, instead of running an arduous exercise that’s both operationally challenging and outdated quickly.
Here are a few suggestions we have for ensuring threat modeling exercises run smoothly:
- Your team: Assemble a cross-functional team to ensure you’re incorporating diverse perspectives—such as teammates across your security, engineering, business, and operations teams. This can help reduce observational bias (e.g. the streetlight effect) when modeling threats. Be sure to share context beforehand or at the start of the session, especially if it’s your organization’s first time running a threat modeling exercise.
- Your roles: Assign clear roles and responsibilities ahead of time. For example, decide who’ll help run the exercise, update the threat model in real-time, and identify anyone who might play a specific role—such as teammates who represent the perspectives of the adversary, defender, developer, etc.
- Your tools: Identify which tools you’ll use and ensure you’re familiar with how they work prior to threat modeling. Remember, the point is to help create a high-bandwidth information session, not necessarily to capture your discussion for later.
Our goal is to make more informed decisions every day, and we hope you find threat modeling as fun, interesting, and valuable of an exercise as we do.
If you’re looking to learn more about threat modeling, whether individually, for your team, or even for your organization, here are a few resources that have been helpful for us:
- Deciduous: A Security Decision Tree Generator | Kelly Shortridge
- Threat Modeling, by Adam Shostack
- Shostack + Associates > Elevation of Privilege Game
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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