December 27, 2023

How to do penetration testing: A step-by-step guide

What is a penetration test?

A penetration test is a simulated attack conducted by third-party security experts that an organization hires to identify vulnerabilities in their networks, systems, and applications. Using the results of the test, the company can mitigate high-risk findings to reduce the attack surface and risk of a data breach. 

Penetration testing typically involves testing your security controls — such as authentication, authorization, integrity, and confidentiality — against industry standards. A penetration test should also test your application’s business logic and ensure there are no bypasses that could lead to serious issues.

Penetration testing is often required by auditors when working toward security certifications like ISO 27001 or attestations like SOC 2. Penetration tests are also required to comply with privacy-related laws, like HIPAA and PCI DSS.

Why do I need a penetration test?

Your company's internet-facing assets could be getting hit with thousands of malicious connection requests at any given moment — just ask your WAF provider to show you a recent report of blocked IPs attempting to scan your website. Hackers target businesses of all sizes and industries and often see smaller businesses as easier targets given that they are less likely to have strong data security measures in place, which is why it’s important to be prepared no matter the size of your business.

A penetration test is one of the best ways to understand your risks and build a stronger security posture. Here are some ways that penetration tests can benefit your organization: 

Protect your products and customers

An important part of business is earning the trust of your customers, which means you're responsible for protecting your product, your customer’s data, and their identities even if your application is deployed in a cloud-based ecosystem. Customers may ask you to provide evidence of third-party penetration testing as part of their procurement, legal, and security due diligence. 

Avoid penalties

If you're storing any personal data (PII/PHI/PCI) and fail to protect the security and privacy of your customers' data, you could be subject to steep monetary penalties by legal and regulatory authorities. Regular penetration tests can help you avoid fines by discovering misconfigurations, weak encryptions, vulnerabilities, default credentials, and sensitive data that’s been inadvertently exposed by your APIs, applications, and data stores.

Continuous security validation 

Penetration testing can verify if your security tools, such as your WAF or email filters, are working as advertised. It can also identify any changes to your company’s security posture as your business activities, users, employees, partners, and competitors continuously change.

Meet compliance requirements

A penetration test report, or letter of attestation, from a penetration tester is often required by your regulators, insurance companies, and your clients to ensure that you have threat and vulnerability management practices in place.

Achieve and maintain security attestations 

A penetration test is required by SOC 2 and ISO 27001 auditors to confirm the evidence of a mature threat and vulnerability management practice. These standards are designed to verify that your organization maintains high data security. Because of this, an ISO 27001 or a SOC 2 are often required by customers before they can do business with you.

Types of penetration tests

There are varying types of penetration tests depending on your organization’s priorities and the types of risks you want to assess. There are two main focus areas to choose from for your penetration tests: Testing for external attacks or for insider threats.

The focus you choose for your penetration test will impact the type of pen test used. These pen test methods include:

  • Blackbox: The penetration tester will not receive any test accounts or authentication to your applications and infrastructure components (databases or servers). This lets them truly simulate an external hack by someone who has no inside knowledge of your system. 
  • Whitebox: The tester is given the same credentials and permissions that an employee of your business would have. This lets them test to see what resources an employee would be able to access and affect. 
  • Graybox: The tester receives limited knowledge of and access to your system and is asked to try to hack your system using a typical customer account. This shows you what access someone could reach through a customer account.
  • Double blind: A blackbox test in which as few internal employees as possible are told about the test. This allows you to see what an external party could get access to and to see how your data security team responds to the attack.

How to perform penetration testing

The stages of a penetration test can vary based on the tester you hire and the type of pen test you choose, however these are the steps that are generally involved:

Step 1: Planning and scoping

Before your tester can launch into your pen test, you need to figure out what you’re testing for. This includes determining what type of penetration test you want (blackbox, graybox, etc.). You can also establish the scope of your pen test by choosing the attack vectors you'd like to test for vulnerabilities:

  • Network: You provide a range of IP addresses and active hosts within that range.
  • Applications: You provide production URLs and any subdomains to test for web apps or binaries/devices/links for mobile applications or demo/test versions of the applications that mimic production apps and environments.
  • APIs: You provide the number of API endpoints and the number of calls.
  • Physical: On-site attacks to access physical network devices and wireless access points.
  • People: You may or may not provide a list of target emails. Penetration testers can research social media and various open intelligence sources to identify target lists, buy domains that look like yours, and set up servers in the cloud to bypass your email filters and deliver phishing links to your target users and take control of their machines.
  • Cloud: Penetration testers will try to exploit cloud-based services, serverless functions, containers, SQL/no-SQL stores, APIs, and consoles to attack your applications.‍
  • IOT devices: Any hardware device with an IP address is a target. If these devices are set up with default credentials, they can be an easy target of an attack.‍

Step 2: Gathering intelligence

As your tester begins the penetration test, they’ll start with observation and reconnaissance. They’ll see what they can find out about your system and look for the best ways to gain access to the most data.

Step 3: Scanning

Once the tester has a better understanding of your ecosystem, they’ll use a variety of techniques to see how your system responds. This shows them which attack methods are the most effective for getting in and which ones might be more closely guarded.

Step 4: Gaining access

Now that the tester has scoped out their options and identified the best ways to get into your data, they’ll launch a more structured and aggressive attack to gain access to your system.

Step 5: Remaining in your system

Proper data security is not only about preventing cyberattacks but also about ending cyberattacks quickly. In a penetration test, the tester attempts to maintain their access to your data for as long as possible to see how long it takes your team to remove them.

Step 6: Analysis and reporting

When the pen test has been completed, your tester will prepare a report or meet with you to discuss their findings. They’ll explain what vulnerabilities they were able to exploit, what they were able to access, and offer potential solutions to help you shrink those vulnerabilities.

How long does pen testing take?

The time commitment for this process depends on the type of penetration test you’re pursuing.

If it's a black box test with no authentication, the tester may be able to finish most of the work without much involvement from your team during the testing period.

You may be more involved during a whitebox test. If you have a large, complex network and access provisioning process or if you have a complex procurement and legal contract review process, it may take more time to engage a third-party penetration tester.

For most penetration testing companies, it takes one to four weeks to complete a penetration test depending on the size and scope of the attack vectors. While the test itself may not take much of your time, you should allocate sufficient time to fix vulnerabilities that the penetration test uncovers. Typical remediation cycles can take 90-180 days depending on the availability of your resources.

How often do you need a penetration test?

Most auditors or customers will require that you conduct a third-party penetration test at least once a year, if not twice a year. You should choose a penetration test partner who can accommodate penetration tests at regular intervals for an affordable price. If your penetration test is for SOC 2 compliance, the penetration test must be completed before the end of your SOC 2 observation period in order to be included in your control matrix.

How much does a penetration test cost?

The cost of a penetration test can vary depending on the size of your applications, the number of attack vectors, and the type of test you choose. You will have to go through a scoping exercise to get an accurate quote. It can also depend on the penetration testing company's rate card. Large penetration testing companies and higher rates do not necessarily mean that you get top-quality results and attention. Typically these tests start at $5,000 and can go up to $15,000 depending on the scope and the testing company you choose. 

Is penetration testing required for SOC 2 and ISO 27001?

One of the most common reasons an organization may invest in a penetration test is to meet the compliance requirements of a specific framework, such as SOC 2 or ISO 27001. In this section, we’ll describe the role that penetration testing plays in these standards.


Because of the way the SOC 2 framework is written, it's up to the discretion of your auditor to determine if you meet the SOC 2 requirements. That said, SOC 2 does require you to identify vulnerabilities in your systems so most auditors will require you to do a penetration test as part of the SOC 2 process. Even if your SOC 2 auditor doesn’t require a penetration test, your customers may still require you to perform them.

ISO 27001‍

ISO 27001 requires that you prevent the exploitation of technical vulnerabilities. A common way to do this for ISO 27001 compliance is to pair a penetration test with vulnerability scanning. The vulnerability scan identifies your systems’ vulnerabilities and the pen test tells you how exploitable they are. 

How to choose a penetration testing company

A penetration test is an impactful investment in your data security, so it’s important you choose a pen testing partner that is reliable and will provide you with valuable results. Use these tips to choose the right partner:

  1. Look for a CREST accredited partner: CREST is the only international certification authority that audits and approves penetration testing organizations for their methodologies, processes, and data handling practices.
  2. Look for testers' certifications: Ask for the profile of the tester, looking for hands-on lab-based certifications like OSCP, CRTP, OSCE, GXPN, GPEN, GWAPT, GAWN, GCIH, GCFA, GMOB, GCIA, GSEC, etc.
  3. Get a clear Statement of Work (SOW): The SOW should clearly state what's included and not included in the test and have clear timelines for deliverables. Choose a penetration testing company with an all-inclusive fixed price, given that an hourly rate can add up for all the tasks included in a penetration test. The SOW should include an escalation and remediation process and contacts in case the testing impacts your services.
  4. Risk analysis: The penetration testing company should provide a business impact analysis to reflect the reality of the risks your organization faces. They should be flexible to accommodate your risk appetite and decision to accept or not accept risks.
  5. Insurance requirements: Make sure they have adequate insurance to cover any professional liability due to penetration testing activities.
  6. Report quality: Experienced auditors and risk managers can challenge the validity of a penetration test done by an inexperienced tester. If the tester doesn’t follow industry best practices and methodologies, your report will not support legal liability and forensic cases.

We recommend choosing a penetration testing partner that integrates well with the compliance and security tools your organization uses. This makes it so you can map the findings from your pen test to the compliance framework you're working toward and include them in your existing risk mitigation workflows. 

Vanta is the leading trust management platform with compliance automation and continuous monitoring capabilities — offering frameworks like SOC 2, ISO 27001, GDPR, and more. We partner with Prescient Security, which offers penetration testing, expert security reviews, and security test services. By using an integrated service provider and compliance automation solution, you can simplify and streamline your security. Learn more about our partnership.


Determine if you need to comply with GDPR

Not all organizations are legally required to comply with the GDPR, so it’s important to know how this law applies to your organization. Consider the following:

Do you sell goods or services 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?

If any of the above statements apply to your business, you’ll need to be GDPR compliant.

Document the personal data you process

Because GDPR hinges on the data you collect from consumers and what your business does with that data, you’ll need to get a complete picture of the personal data you’re collecting, processing, or otherwise interacting with. Follow these items to scope out your data practices: 

Identify and document every system (i.e. database, application, or vendor) that 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, including:

Racial or ethnic origins
Religious or philosophical beliefs
Genetic data
Health, sex life, or sexual orientation data
Political opinions
Trade union membership
Biometric data that could uniquely identify someone

Determine whether your documentation meets the GDPR requirements for Records of Processing Activities, that include information on:

The name and contact details of the controller
The purpose behind the processing of data
A description of the categories of data that will be processed
Who will receive the data 
Documentation of suitable safeguards for data transfers to a third country or an international organization
The retention period of the different categories of data
A general description of the technical and organizational security measures

Determine whether your documentation includes the following information about processing activities carried out by vendors on your behalf:

The name and contact details of the processor(s) and of each controller on behalf of which the processor is acting, and, where applicable, of the controller’s or the processor’s representative, and the data protection officer
The categories of processing carried out on behalf of each controller
Documentation of suitable safeguards for data transfers to a third country or an international organization
A general description of the technical and organizational security measures

Determine your legal grounds for processing data

GDPR establishes conditions that must be met before you can legally collect or process personal data. Make sure your organization is meeting the conditions listed below:

For each category of data and system/application, determine the lawful basis for processing based on one of the following conditions:

Consent of the data subject
Contract with the data subject
Necessary for compliance with a legal obligation
Necessary in order to protect the vital interests of the data subject or a third party
Necessary for the performance of a task in the public interest or in the exercise of official authority vested in the controller
Necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the rights of the data subject

Review and update current customer and vendor contracts

For your organization to be fully GDPR compliant, the vendors you use must also maintain the privacy rights of your users’ and those rights should be reflected in your contracts with customers:

Review all customer and in-scope vendor contracts to determine that they have appropriate contract language (i.e. Data Protection Addendums with Standard Contractual Clauses).


Determine if you need a Data Protection Impact Assessment

A Data Protection Impact Assessment (DPIA) is an assessment to determine what risks may arise from your data processing and steps to take to minimize them. Not all organizations need a DPIA, the following items will help you determine if you do:

Identify if your data processing is likely to create high risk to the rights and freedoms of natural persons. Considering if your processing involves any of the following:

Automated processing, including profiling, and on which decisions are based that produce legal effects
Special categories of data or data related to criminal convictions and offenses
Monitor any publicly accessible area on a large scale
If any of the above are true, you may need to conduct a data protection impact assessment for existing and new data projects.

Clearly communicate privacy and marketing consent practices

A fundamental element of GDPR compliance is informing consumers of their data privacy rights and requesting consent to collect or process their data. Ensure your website features the following:

A public-facing privacy policy which covers the use of all your products, services, and websites.

Notice to the data subject that include the essential details listed in GDPR Article 13.

Have a clear process for persons to change or withdraw consent.


Update internal privacy policies

Ensure that you have privacy policies that are up to the standards of GDPR:

Update internal privacy notices for EU employees.

Have an employee privacy policy that governs the collection and use of EU and UK employee data.

Determine if you need a data protection officer (DPO) based on one of the following conditions:

The data processing is carried out by a public authority
The core activities of the controller or processor require regular and systematic monitoring of data subjects on a large scale

Review compliance measures for external data transfers

Under GDPR, you’re responsible for protecting the data that you collect and if that data is transferred. Make your transfer process compliant by following these steps:

If you transfer, store, or process data outside the EU or UK, identify your legal basis for the data transfer. This is most likely covered by the standard contractual clauses.

Perform and document a transfer impact assessment (TIA).


Confirm you comply with additional data subject rights

Ensure you’re complying with the following data subject rights by considering the following questions:

Do you have a process for timely responding to requests for information, modifications, or deletion of PII?

Can you 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 an EU-based representative

Depending on how and where your organization is based, you may need a representative for your organization within the European Union. Take these steps to determine if this is necessary:

Determine whether an EU representative is needed. You may not need an EU-rep if the following conditions apply to your organization:

Data processing is occasional
Data processing is not done on a large scale
Data processing doesn’t include special categories or data related to criminal convictions and offenses
Doesn’t risk to the rights and freedoms of data subjects
A public authority or body

If the above conditions do not apply to you, appoint an EU-based representative.


Identify a lead data protection authority (DPA) if needed

GDPR compliance is supervised by the government of whatever EU member-state you’re operating in. If you’re operating in multiple member-states, you may need to determine who your lead data protection authority is:

Determine if you operate in more than one EU state.

If so, designate the supervisory authority of the main establishment to act as your DPA.


Implement employee training

Every employee in your organization provides a window for hackers to gain access to your systems and data. This is why it's important to train your employees on how to prevent security breaches and maintain data privacy:

Provide appropriate security awareness and privacy training to your staff.


Integrate data breach response requirements

GDPR requires you to create a plan for notifying users and minimizing the impact of a data breach. Examine your data breach response plan, by doing the following:

Create and implement an incident response plan which includes procedures for reporting a breach to EU and UK data subjects as well as appropriate data authorities.

Establish breach reporting policies that comply with all prescribed timelines and include all recipients (i.e. authorities, controllers, and data subjects).


Implement appropriate security measures

GDPR requires you to take measures to minimize the risk of a data breach. This includes security practices such as pseudonymization/encryption, maintaining confidentiality, restoration of access following physical/technical incidents, and regular testing of measures. Consider the following:

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 measures ensure that, by default, only personal data that are necessary for each specific purpose of the processing are processed?


Streamline GDPR compliance with automation

GDPR compliance is an ongoing project that requires consistent upkeep with your system, vendors, and other factors that could break your compliance. Automation can help you stay on top of your ongoing GDPR compliance. The following items can help you streamline and organize your continuous compliance:

Explore tools for automating security and compliance.

Transform manual data collection and observation processes via continuous monitoring.

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GDPR compliance FAQs

In this section, we’ve answered some of the most common questions about GDPR compliance:

What are the seven GDPR requirements?

The requirements for GDPR compliance are based on a set of seven key principles:

  • Lawfulness, fairness, and transparency
  • Purpose limitation
  • Data minimization
  • Accuracy
  • Storage limitations
  • Integrity and confidentiality
  • Accountability

These are the seven requirements you must uphold to be GDPR compliant.

Is GDPR compliance required in the US?

GDPR compliance is mandatory for some US companies. GDPR compliance is not based on where your organization is located but whose data you collect, store, or process. Regardless of where your organization is based, you must comply with GDPR if you are collecting or processing data from EU residents.

What are the four key components of GDPR?

The four components of GDPR include:

  • Data protection principles
  • Rights of data subjects
  • Legal bases for data processing
  • Responsibilities and obligations of data controllers and processors

Safeguard your business with GDPR compliance

If your organization collects data from EU residents, GDPR compliance is mandatory for you. It’s important to follow the steps listed above to protect your business from heavy fines and to respect the data privacy rights of consumers. 

Vanta provides compliance automation tools and continuous monitoring capabilities that can help you get and stay GDPR compliant. Learn more about getting GDPR compliance with Vanta.


Pre-work for your SOC 2 compliance

Choose the right type of SOC 2 report:

Do you sell goods or services to EU businesses, consumers, or both?

Do you sell goods or services to EU businesses, consumers, or both?

Do you sell goods or services to EU businesses, consumers, or both?

Determine the framework for your SOC 2 report. Of the five Trust Service Criteria in SOC 2, every organization needs to comply with the first criteria (security), but you only need to assess and document the other criteria that apply. Determining your framework involves deciding which Trust Service Criteria and controls are applicable to your business using our Trust Service Criteria Guide.

Estimate the resources you expect to need. This will vary depending on how closely you already align with SOC 2 security controls, but it can include several costs such as:

Compliance software

Engineers and potentially consultants

Security tools, such as access control systems

Administrative resources to draft security policies

Auditing for your compliance certification

Choose the right type of SOC 2 report:

Do you sell goods or services to EU businesses, consumers, or both?

Do you sell goods or services to EU businesses, consumers, or both?

Do you sell goods or services to EU businesses, consumers, or both?


Work toward SOC 2 compliance

Begin with an initial assessment of your system using compliance automation software to determine which necessary controls and practices you have already implemented and which you still need to put in place.

Review your Vanta report to determine any controls and protocols within the “Security” Trust Service Criteria that you do not yet meet and implement these one by one. These are multi-tiered controls across several categories of security, including:

CC1: Control Environment

CC2: Communication and Information

CC3: Risk Assessment

CC4: Monitoring Activities

CC5: Control Activities

CC6: Logical and Physical Access Controls

CC7: System Operations

CC8: Change Management

CC9: Risk Mitigation

Using Vanta’s initial assessment report as a to-do list, address each of the applicable controls in the other Trust Services Criteria that you identified in your initial framework, but that you have not yet implemented.

Using Vanta’s initial assessment report, draft security policies and protocols that adhere to the standards outlined in SOC 2. 

Vanta’s tool includes thorough and user-friendly templates to make this simpler and save time for your team.

Run Vanta’s automated compliance software again to determine if you have met all the necessary criteria and controls for your SOC 2 report and to document your compliance with these controls.


Complete a SOC 2 report audit

Select and hire an auditor affiliated with the American Institute of Certified Public Accountants (AICPA), the organization that developed and supports SOC 2.

Complete a readiness assessment with this auditor to determine if you have met the minimum standards to undergo a full audit.

If your readiness assessment indicates that there are SOC 2 controls you need to address before your audit, complete these requirements. However, if you have automated compliance software to guide your preparations and your SOC 2 compliance, this is unlikely.

Undergo a full audit with your SOC 2 report auditor. This may involve weeks or longer of working with your auditor to provide the documentation they need. Vanta simplifies your audit, however, by compiling your compliance evidence and documentation into one platform your auditor can access directly.

When you pass your audit, the auditor will present you with your SOC 2 report to document and verify your compliance.


Maintain your SOC 2 compliance annually

Establish a system or protocol to regularly monitor your SOC 2 compliance and identify any breaches of your compliance, as this can happen with system updates and changes.

Promptly address any gaps in your compliance that arise, rather than waiting until your next audit.

Undergo a SOC 2 re-certification audit each year with your chosen SOC 2 auditor to renew your certification.

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Prioritizing Your Security and Opening Doors with SOC 2 Compliance

Information security is a vital priority for any business today from an ethical standpoint and from a business standpoint. Not only could a data breach jeopardize your revenue but many of your future clients and partners may require a SOC 2 report before they consider your organization. Achieving and maintaining your SOC 2 compliance can open countless doors, and you can simplify the process with the help of the checklist above and Vanta s compliance automation software. Request a demo today to learn more about how we can help you protect and grow your organization.

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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
  • Communication
  • 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


Learn more about achieving ISO 27001 certification with Vanta

Book an ISO 27001 demo with Vanta

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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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  • Automated evidence of remediation completion displayed for integrated systems
  • Manual evidence of remediation can be uploaded for non-integrated systems
Report and re-evaluate results
  • Auditor can log into Vanta to see history of all completed access reviews
  • Internals can see status of reviews in progress and also historical review detail

The ultimate guide to scaling your compliance program

Learn how to scale, manage, and optimize alongside your business goals.

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