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How to perform effective user access reviews
In this series, you’ll hear directly from Vanta’s own Security, Enterprise Engineering, and Privacy, Risk, & Compliance Teams to learn about the teams’ approaches to keeping the Vanta organization secure. We’ll also share some guidance for teams of all sizes — whether you’re just getting started or looking to uplevel your operations.
In this post, you’ll hear from Bart Tissue, Senior Systems Engineer on our Enterprise Engineering team, and Jess Chang, Staff Technical Program Manager on our Security team.
Why access reviews matter
In a nutshell, performing regular user access reviews help ensure that current employees have access to the right tools (and no more privileges than they need), offboarded users no longer have access, and anyone who’s transferred roles internally no longer has access to tools they don’t need.
User access risk scenarios
When conducting user access reviews, here are a few common scenarios you might encounter:
- User leaves the company, but still retains access to apps and tools.
- User leaves the company and no longer has access, but retains a user license.
- User changes roles or teams internally and retains access to apps and tools that aren’t needed for their new role or team.
- User has elevated access (e.g. admin) that is not required for their existing role.
These are specific risk scenarios that our Enterprise Engineering team looks for when performing our access reviews. We also structure this into our process so that system owners who own applications or infrastructure and are asked to review access on a periodic basis also understand how to identify and address access privileges in each of these cases.
Cadence of user access reviews
While the cadence of user access reviews may depend on a company’s risk profile, they’re typically conducted on a monthly or quarterly basis.
It’s important to maintain a calendar to mark and initiate your reviews — or ensure this cadence is reflected in any automated reminders and tooling you’re working within. At Vanta, we rely on an automated reminder within Vanta’s Access Reviews product as well as on our Enterprise Engineering team’s calendar to kick off our reviews.
How Vanta performs user access reviews
At Vanta, our user access reviews are performed on a quarterly basis by our Enterprise Engineering team in partnership with our Security and Privacy, Risk, and Compliance teams. We maintain a playbook as our source of truth, with step-by-step instructions and a list of systems and applications in scope.
We start by reviewing the list of systems and applications in scope collectively and making any changes needed. For instance, we’ll add any new, high-risk applications that are in scope from a security or compliance perspective. We’ll also remove any tools that have been moved behind SSO since our last user access review and review our list of system owners to make sure it’s up-to-date. Since this list is maintained and used for future user access reviews, we make these changes directly in our playbook.
Next, we’ll send out a reminder to system owners. This reminder provides them with an overview of their responsibilities for reviewing user access on a periodic basis, as well as steps and guidance for reviewing user access based on risk. We’ll also provide them with a list of offboarded users during the relevant time period to ensure these individuals no longer have access.
For any systems that are owned by our Enterprise Engineering team, we manage these user access reviews ourselves. In addition to what we look for as reviewers, we also look for ways to eliminate manual processes, such as opportunities to move any outstanding tools behind SSO. If any systemic issues are uncovered, we also work with our partner teams to address these and reduce the likelihood of future occurrences.
Finally, we work with our system owners to ensure they’re able to complete the reviews within the timeline allocated. We help answer any questions they may have along the way and most importantly — thank them for thoroughly reviewing the systems and infrastructure in scope to help keep Vanta secure.
How Vanta helps
In addition to the processes covered above, we use Access Reviews in Vanta to help manage our quarterly user access reviews. Using Access Reviews in Vanta has helped streamline our reviews by eliminating manual effort while integrating directly with relevant applications in scope.
Some of Vanta’s Access Reviews features we particularly find useful include:
- Centralized hub for access reviews alongside security monitoring.
- Sends out notifications to system owners and provides them with instructions.
- Automated and customized reminders for system owners.
- Ability to directly pull user lists for integrated apps, or to upload if needed.
- Keeps track of next access review with automated cadence and reminders.
- Automatically flags any offboarded user accounts that still have access.
Tips for performing user access reviews
While every company may differ, here are some steps we’ve found to be helpful in performing periodic and effective user access reviews:
- Maintain a playbook with step-by-step instructions for conducting the user access review and a definitive list of systems and infrastructure in scope. This ensures consistency and can be updated on an as-needed basis.
- Maintain a calendar or use a tool like Vanta to initiate regular user access reviews based on the cadence you’ve identified for your company or institution.
- Automate what you can by moving tools behind SSO to streamline the user login experience while also eliminating the manual need for removal during the offboarding process.
- Always buffer in additional time before your reviews to prepare any tooling and internal resources needed. This ensures you’re ready to launch your user access reviews on-time.
- Partnerships are key — be sure to partner closely with your system owners and their teams, and ensure that their responsibilities as system owners are clear and captured. In addition, work with your Security and Compliance teams to ensure that the list of systems in scope is accurate and up-to-date.
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
Do you have a public-facing Privacy Policy which covers the use of all your products, services and websites?
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
Do you have an Employee Privacy Policy governing the collection and use of EU and UK employee data?
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?
Consider streamlining GDPR compliance with automation
Transform manual data collection and observation processes into continuous monitoring
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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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Download NowDetermine 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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