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Engineering at Vanta: How we imported our AWS environment into Terraform
We use Terraform to manage the majority of our infrastructure as code. Terraform enables us to automate provisioning and easily review changes. Since we didn’t manage all of our infrastructure in Terraform—or monitor our AWS environment for unmanaged resources—our list of unmanaged resources continued to grow.
Resources that aren’t managed via Terraform are hard to keep track of and can potentially have security implications. Resources such as Route53 records, S3 buckets, and KMS keys were causing some problems when not managed in Terraform:
- We needed to ask a couple engineers to perform actions on our production environment that involved these resources. One example was to add DNS records for domain verification. These changes didn’t reap the benefits from GitOps, such as review and revertability.
- Resources not in Terraform differed across staging and production environments, and we didn’t have a deep grasp about how they differed.
- It was possible for an engineer to make temporary changes to resources and forget to revert them. This was a particular problem for our staging environment.
- Any static analysis we applied to our Terraform configuration wouldn’t apply to these unmanaged resources.
Moving existing resources to Terraform
The ability to create and destroy resources is well-supported in Terraform, but importing resources isn’t as intuitive. The team at Segment worried about inadvertently destroying resources when getting started, so they created a separate AWS account for Terraform and gradually removed resources from their old AWS account while creating the equivalent resource in their Terraform-managed AWS account. For our use case, this felt too heavy-handed. We already had an environment that was mostly, but not wholly, Terraform-managed.
Within the same AWS environment, we also considered creating an equivalent resource in Terraform, followed by the deletion of the corresponding, manually-created resource. For resources that had to have particular identifiers, such as S3 buckets or Route53 records, this was a non-starter—we would have had to delete the manually-created resources first and incur some downtime. For resources that didn’t have this problem, it wasn’t clear how we could mechanically verify that the resource described in Terraform was identical to the resource we created manually beforehand.
Thankfully, Terraform already has a command to add already existing resources to Terraform state without creating or destroying anything: terraform import. The import command will add a resource to state given configuration, but it will not generate that configuration in your .tf files for you. A subsequent terraform apply after the resource is imported will change the resource to reflect the configuration, so it is important to make sure that the terraform configuration reflects the current state of the resource.
We then broke up this problem into a few steps:
- Regularly monitor our environments for resources that are not managed via Terraform
- Import these resources via the import command
- Add an observability monitor to maintain the invariant that all resources that should be managed via Terraform are managed via Terraform
Thankfully, the monitoring tooling already existed. We ran driftctl as a Github Action on a regular cadence to determine what resources are in our AWS environment but not our Terraform state. The team at driftctl is also quite responsive. One caveat, however, is that driftctl doesn’t yet monitor all possible AWS resources. Here is the current list of resources that they support.
Next, we focused on the import command timing. If running the import out-of-band of your continuous deployment (CD) pipeline, a terraform apply at the wrong time could:
- Delete your newly imported resources
- Attempt to create redundant copies of the resources that you intend to import
If applying Terraform changes automatically in CD, it is important to atomically merge the new Terraform configuration into the CD pipeline and perform the Terraform import. Only then will the subsequent terraform apply become a safe operation.
In our case, we temporarily disabled applying any Terraform changes via CD before running our import step.
Since this was disruptive to our existing CD workflows, we wanted to go through this process as few times as possible. We aimed to perform dry runs of imports in development. Once we were sure that we described our configurations and import commands correctly, running our actual imports should be as simple as running a dry run script with the --do-it flag enabled.
Making Terraform imports dry-runnable
To verify whether our Terraform imports match the resource, we wanted to have a clean terraform plan. This terraform plan in turn needs to be compared against a Terraform state with imported resources. Terraform workspaces provide tooling to manage duplicate, temporary state files. After finishing the dry run, we can delete the workspace.
Be careful when working with state files. State files can store sensitive information, such as database passwords.
Our workflow looked something like this:
We pieced together a script to abstract away these details so that developers only focus on the address-id pairs (and the accompanying Terraform configuration).
Determining Terraform configuration
We’ve now reduced importing resources in Terraform to a process of guess-and-check. Even if we are completely incorrect in our configuration, the dry run’s terraform plan will give you a diff you can interpret as the reversed instructions to import a resource as is.
Let’s say we were trying to import a Route53 zone. We wrote up an attempt at Terraform configuration and now run our dry run script:
Oops! This configuration attempt forgot to associate the resource with a VPC, as it is a private hosted zone. The comment attribute was also missing.Even this process can feel somewhat tedious, so we used Terraformer to generate resource configurations for us. These configuration attribute values are string literals, so they still require some tweaking to instead reference attributes to already-Terraform-managed resources.
What resources are we responsible for?
Not all resources should be managed via Terraform. Here are some examples of resources driftctl marked as drifted which we decided not to import:
- IAM roles, policies, and policy attachments generated by AWS. Some examples include roles with the prefixes AmazonSSMRoleFor, AWSServiceRoleFor, AWS_InspectorEvents, and AWSReservedSSO . The AWS console’s policies page can give you some hints about whether certain IAM roles are customer managed versus AWS managed.
- Resources managed via a separate cloudformation stack
- Default AWS Network ACL rules
- AWS IAM Access keys, which cannot be changed if the resource is imported.
Thankfully, driftctl supports a .driftignore file that can ignore resources. Once we imported all of our resources, we found that deciding whether to manage a new resource in Terraform became easier. We now have more temporal context when a resource suddenly appears in driftctl that wasn’t there before, so we can make a guess about why the resource was created.
What we learned
After importing, deleting, or ignoring all the resources in our production and staging AWS environments that were not managed via Terraform, we added a Datadog Monitor to notify us via Slack if a new resource appears in driftctl. This monitoring gives us the added benefit of learning when AWS automatically creates certain resources in our AWS environment.
Making changes with Terraform can feel risky. Making changes replicable in a development environment helps us build confidence in the safety of these changes. Since Terraform imports are primarily changes in Terraform state, we were able to simulate imports by creating throwaway duplicates of our Terraform state. This enabled us to find a solution that was more effective than trying to create and then import a resource in a development AWS environment.
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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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