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AWS: Foundational Technical Review overview
Amazon Web Services or AWS is among the top organizations around the world when it comes to the cloud, and if it’s used in the best way, it can be the place to host secure, reliable software and SaaS solutions. But how do you know if you’re using it to the best of its potential?
That’s where an AWS Foundational Technical Review comes in. Our information security specialists are taking you through the essentials of an AWS FTR and how it can benefit your cloud infrastructure.
What is an AWS Foundational Technical Review?
The AWS Foundational Technical Review or AWS FTR is an in-depth technical review designed for vendors that host their cloud solutions in AWS. You may be familiar with AWS’s Well-Architected Framework. The AWS FTR is essentially a review of whether you have implemented Well-Architected Framework best practices and a self-conducted risk mitigation.
The aim of an AWS FTR is to identify ways you can enhance cloud architecture. This includes making your software more secure, making it more reliable, and helping it run more efficiently.
While the AWS FTR is a self-service assessment, you submit your assessment and documentation to AWS. Specialists then review it and determine whether or not your FTR is approved as demonstrating strong best practices. Your approval is valid for two years.
Who should complete AWS FTR?
The AWS FTR is designed for AWS ISVs. What is an AWS ISV? This is the term for an independent service vendor that hosts its cloud infrastructure on AWS.
An AWS FTR is completely voluntary but it is a necessary step to unlock certain perks and programs within AWS. Of course, an AWS FTR is also helpful for any AWS ISV to determine if they are using AWS in the best way and aligning with the suggested best practices.
Benefits of AWS FTR
Should your organization pursue an AWS FTR? While it can take engineering time, there are plenty of benefits that make an FTR worth the investment.
AWS offers certain funding opportunities to its partners. An AWS FTR, though, is a requirement to unlock a variety of these funding benefits. For some organizations, this alone makes up for the time and effort they put into their FTR.
Access to select AWS programs
Several partner programs within the AWS ecosystem are only available to partners that have completed an AWS FTR. For example:
- The AWS Competency Program which allows you to demonstrate and certify your AWS expertise
- The AWS Service Ready Program which lets you validate software solutions you’ve built and their ability to work with specific AWS services
- The AWS ISV Accelerate Program which allows you to co-sell and offers growth opportunities for ISVs
Depending on your organization’s future goals, these programs can open lucrative doors that justify the effort of an AWS FTR.
“Reviewed by Amazon” badge
When you have completed your FTR and it has been reviewed and approved by AWS, you’ll be awarded a “Reviewed by Amazon” badge. This badge certifies that you have a valid FTR and, by extension, that you are a trustworthy ISV that has a well-designed and secured AWS infrastructure.
The badge also comes with a listing for your organization in the AWS Partner Solution Finder directory. This gives you a strong competitive edge and allows potential clients and business partners to find you more easily.
Cost effective review process
Not only does an AWS FTR come with several benefits but it’s a rather low-risk project because there is no direct cost involved. You don’t need to pay for your AWS FTR; you only need to pay any potential costs that come from implementing the best practices detailed in the FTR.
What FTR includes: An AWS FTR checklist
What can you expect when you complete your AWS FTR? The process is rather straightforward:
- Join the AWS Partner Network or APN: An AWS FTR is only available to organizations that are part of the AWS Partner Network or APN. Fortunately, signing up for the APN is free and simple.
- Enroll in the Software Partner Path: When you are a part of the APN, you have access to different paths within the APN based on the services you provide and the ways you want to work with AWS. The AWS FTR is part of the Software Partner Path, so join this path in your APN portal.
- Conduct a review of your architecture: With your APN account and Software Partner Path in place, you can get started on your FTR. AWS offers an FTR guide that walks you through the risk mitigation process and best practices in your FTR. Start by doing a review of your software or solution with the FTR guide to see which aspects of the FTR you’ve already implemented and which you are missing. The most efficient way to do this is to use an automated compliance tool like Vanta to investigate your software for you and give you a detailed report on how you match up with the FTR guide’s checklist.
- Implement missing best practices: Now that you know what best practices you need to implement as part of your FTR, you can hit the ground running. Address each of them to be ready for your formal FTR assessment.
- Request an FTR: When you’re confident that you’re following the best practices outlined in the FTR guide, it’s time to start the official process. Go into your APN portal and request an FTR. AWS will provide you with a checklist of documents and assessments to complete and submit.
Once you’ve submitted your package, AWS will review it and determine whether it is approved. If not, it will send you instructions for remediation so that you can then re-submit your FTR. If and when your FTR is approved, you’ll receive your “Reviewed by AWS” badge and other perks.
Starting your AWS FTR process
For many organizations, an AWS FTR is well worth the effort for the opportunities, programs, and perks that it unlocks. If you’re ready to learn more and start pursuing your AWS FTR, explore more about Vanta today and learn how our platform can streamline the process for you.
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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