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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:
- Vanta staff cares about security (beliefs and values)
- Vanta staff understands their responsibilities when it comes to keeping the company secure (knowledge)
- 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.
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?
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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