August 31, 2023

How we scaled our security culture at Vanta

‍Security is at the heart of what we do at Vanta—helping our customers improve their security and compliance posture starts with our own. Our team’s mission is to ensure that Vanta is a trusted and trustworthy steward of customer data.

At Vanta, we believe that nurturing and scaling our security culture is one of the most powerful ways to achieve our mission. We define security culture as the norms, behaviors, and attitudes around security. We look at our security culture through the following three primary tenets with the belief that these are distinct:

  1. Vanta staff cares about security (beliefs and values)
  2. Vanta staff understands their responsibilities when it comes to keeping the company secure (knowledge)
  3. Vanta staff reaches out with security questions and to ask for guidance (behaviors)

Why three tenets? An individual can care about security and understand their responsibilities, but make a misguided security decision if they opt to not ask for guidance at a critical junction in their project. An employee who doesn’t care about security will likely not understand their responsibilities, and is even less likely to reach out to ask for security guidance. A healthy security culture requires all three tenets operating in tandem to sustain itself.

Why security culture matters

While there are many reasons why security culture matters, one thing in particular stands out to us—which is that establishing a strong security culture enables the Security team to have greater leverage and be more impactful. 

By equipping and empowering teams to partner with the Security team or even address security issues on their own, establishing a strong security culture allows the team to multiply their impact—even with the same resources. For example, at Vanta we partner closely with our Platform team within the Engineering organization through regular meetings that address problems before they even arise. Not only does this help broaden our team’s impact, but also helps avoid creating issues that will surface later. 

Security culture interfaces and principles

You might be wondering how to define and scale your security culture. You may have a function devoted to human risk, security culture, or even security education or generalists on your security team who can lend a hand.

At Vanta, we have a shared responsibility model for nurturing our security culture. We group our guiding principles into two categories depending on whether an employee is interacting with our Security team or tooling we manage, and we work to nurture and improve these consistently: 

  • Human touchpoints: Between the Security team and Vanta’s staff
  • Tooling touchpoints: Between Vanta’s staff and the tooling or controls built by the Security team 

While related, these two distinct touchpoints have different principles that guide our approach to consistently improving our security culture and our overall security strategy. We’ve shared these team principles below with the hopes that these will be helpful as you look to build and scale your own security culture as well.

Human touchpoint principles: Between Vanta’s Security team and staff

1. Culture of yes: We strive to nurture a culture where partner teams come to us collaboratively to work toward solutions, instead of a culture of fear or one where the Security team consistently says no. This means we must cultivate a responsive, supportive, and judgment-free environment that encourages active engagement with Security. We invite feedback through a biannual, company wide survey that measures friction against security controls and guidance and regularly remind employees how to get help from the Security team. In addition, we operate in a blameless environment that focuses on identifying root causes and solutions.

2. Guardrails are better than gates: Our goal is to help our partner teams by providing guidance and solutions that help meet their needs while not slowing them down. At times, we recognize that this requires imparting a significant amount of trust on our partner teams. Developer experience and productivity are critical to making our systems and processes more secure. We should favor guardrails that make the right and secure thing easy to do, instead of gates that add friction and toil.

3. Be predictable and consistent: In providing guidance, we always seek to provide practical, consistent, and clear guidance from a first principles approach. This means that we’re also transparent when we don’t know what the right answer is—and work closely with teammates to connect our technical expertise in security with their domain expertise. After all, we can’t be successful without the deep domain expertise of our partner teams. In addition, when we’re asked for help, it’s important for us to share clear next steps and a timeline with the requester so they know what to expect and when. 

4. Security is everyone’s responsibility (and can be fun!): While Vanta certainly has a dedicated Security team (us!), we also find ways to create fun, inviting, and accessible ways to learn about security—whether related to Vanta and our work or to our personal lives outside work. Our Security team runs a monthly Capture the Flag (CTF) open to all employees, and also maintains an open Slack channel for articles and discussions on a range of security topics. 

Example of monthly CTF invite from the Vanta Security team
Example of monthly CTF invite from the Vanta Security team

In addition, we share monthly company-wide security updates on what we’re working on and why, as well as threat briefings on an as-needed basis for any potential threats relevant to Vanta or our staff. On a quarterly basis, we also share our top risks and priorities, which helps inform teams and assists in their planning and prioritization. Lastly, as a security company, having clear support from Vanta’s leadership team has also helped emphasize the importance of our internal security initiatives—such as our MDM rollout and migration to WebAuthn.

5. Build a security mindset from the start: To ensure our staff cares about security, understands their responsibilities in keeping Vanta secure, and knows how to ask security questions and get guidance from Day 1, we introduce security at the start—with general onboarding for all employees as well as security training for developers. In addition, we pair our dynamic onboarding content with Vanta’s in-product security and privacy training, and provide regular training on an as-needed basis.

Tooling touchpoint principles: Between Vanta’s staff and tooling

1. Prioritize developer experience: One of the primary goals behind our biannual internal Security team survey is to understand and address any potential points of friction, particularly in our developer experience. If the developer experience is suboptimal because of security controls or otherwise, it will materially impact our overall security culture and lead to decreased engagements with our team. What we build is most readily adopted when it fits into the workflows our developers use—and doesn’t cause additional friction.

2. Shift security left: Embracing this emerging industry principle, we put interfaces in the paths and toolkit of engineers to help keep Vanta secure while also cultivating a healthy relationship with our developers. Our highest leverage efforts are in pushing controls closer to our teammates, while they’re building, designing, and coding. This gives quicker feedback cycles and helps catch security bugs early on in the software development process.

3. Minimize alert fatigue: It’s well-established that tooling with overly-sensitive or poorly-defined monitoring and alerting protocols can lead to alert fatigue and easy dismissal of alerts, even when these alerts may be important. This can create a negative security culture of quickly clicking through a security speed bump versus a culture of paying attention. To combat this, we consistently work to fine-tune our monitoring and alerting and adjust on a continual basis.

4. Secure by default: To help create the right guardrails for our employees and environment, we opt for settings and controls that balance the right levels of security and productivity—and provide clear rationale and guidance for employees where needed.

Additional guidance: Always be automating & documenting

Two additional principles we love internally on Vanta’s Security team include always be automating and always be documenting. These two principles help ensure we’re building repeatable processes, improving our overall team bandwidth and consistency, and creating ways for us to continue to evolve alongside Vanta’s business needs. 

As an example, the Security team maintains a decision log that helps us understand any important internal decisions that might help us evaluate future stance and direction. This helps ensure we’re able to provide consistent, principle-based guidance as we grow and scale, and reference prior decisions where relevant.

Lastly, we recognize that every company and team has their own approach to building and nurturing security culture—and we hope that sharing our internal principles and perspectives can help you decide how to approach defining and scaling your own.


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?

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

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

racial or ethnic origins
genetic data
political opinions
biometric data that can uniquely identifying someone
religious or philosophical beliefs
health, sex life or sexual orientation data
trade union membership

Determine whether your Data Map meets the requirements for Records of Processing Activities (Art. 30)

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 including 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 Data Map includes the following information about processing activities carried out by vendors on your behalf

the name and contact details of the processor or processors 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 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?

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 data subject

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)

Do your agreements cover the following items?
vendor shall process the personal data only on documented instructions (including when making an international transfer of personal data) unless it is required to do otherwise by EU or member state law
vendor ensures that persons authorized to process the personal data are subject to confidentiality undertakings or professional or statutory obligations of confidentiality.
vendor have adequate information security in place, technical and organizational measures to be met to support data subject requests or breaches
vendor shall not appoint or disclose any personal data to any sub-processor unless required or authorized
vendor shall delete or return all the personal data after the end of the provision of services relating to processing, and deletes existing copies unless Union or Member State law requires storage of the personal data;
vendor makes available all information necessary to demonstrate compliance and allow for and contribute to audits, including inspections

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?

Does your processing involve 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 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.

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?

the identity and the contact details of the organization and its representative
the contact details of the data protection officer, if applicable
the purposes to process personal data and its legal basis for the processing
the recipients or categories of recipients of the personal data, if any
the details regarding any transfer of personal data to a third country and the safeguards taken applicable

Does the notice also include the following items?

the retention period, or if that is not possible, the criteria used to determine that period
the existence of the data subject rights (i.e. requests for information, modification or deletion of PII)
the right to withdraw consent at any time
the right to lodge a complaint with a supervisory authority
whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data
the existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the consequences

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)?

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

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?

data processing is occasional
data processing is not 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 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

This includes pseudonymization/ encryption, maintaining confidentiality, restoration of access following physical/technical incidents and regular testing of measures

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

Download this checklist for easy reference

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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

Download this checklist for easy reference

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Written by
Jess Chang
Allan Reyes
Access Review Stage Content / Functionality
Across all stages
  • Easily create and save a new access review at a point in time
  • View detailed audit evidence of historical access reviews
Setup access review procedures
  • Define a global access review procedure that stakeholders can follow, ensuring consistency and mitigation of human error in reviews
  • Set your access review frequency (monthly, quarterly, etc.) and working period/deadlines
Consolidate account access data from systems
  • Integrate systems using dozens of pre-built integrations, or “connectors”. System account and HRIS data is pulled into Vanta.
  • Upcoming integrations include Zoom and Intercom (account access), and Personio (HRIS)
  • Upload access files from non-integrated systems
  • View and select systems in-scope for the review
Review, approve, and deny user access
  • Select the appropriate systems reviewer and due date
  • Get automatic notifications and reminders to systems reviewer of deadlines
  • Automatic flagging of “risky” employee accounts that have been terminated or switched departments
  • Intuitive interface to see all accounts with access, account accept/deny buttons, and notes section
  • Track progress of individual systems access reviews and see accounts that need to be removed or have access modified
  • Bulk sort, filter, and alter accounts based on account roles and employee title
Assign remediation tasks to system owners
  • Built-in remediation workflow for reviewers to request access changes and for admin to view and manage requests
  • Optional task tracker integration to create tickets for any access changes and provide visibility to the status of tickets and remediation
Verify changes to access
  • Focused view of accounts flagged for access changes for easy tracking and management
  • 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

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