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Fitting incident management into the SOC 2 puzzle
This is a guest post by Luis Gonzalez, Senior Content Marketing Manager at incident.io.
In today’s business landscape, security and compliance mean everything.
Because of this, many modern businesses look towards solutions that will provide customers and prospects with the most confidence and trust. One of these is SOC 2 compliance and attestation. SOC 2 is a marker of solid and consumer-minded companies that want to protect customer data.
That said, there are many things that companies can do to best position themselves for a SOC 2—adopting an incident management tool is one of them.
An incident management tool can help businesses respond better to incidents and reduce downtime, which falls squarely within the Availability principle of SOC 2. Here, we’ll discuss how you can leverage an incident management platform to obtain your SOC 2 attestation and increase long-term customer confidence.
SOC 2 attestation is worth the effort
As we hinted above, getting your SOC 2 is much more than another item to check off on your company’s to-do list. It helps your company out with a whole host of things, such as:
Since SOC 2 attestations require businesses to adhere to defined criteria for protecting consumer data, companies will have to ensure that they’re following best practices when it comes to security. Granted, even with the best shot, incidents can still happen, but at least you’ve put in as many measures to be able to respond to these as efficiently as possible.
On the other side of that token, customers can rest easy knowing that, at the very least, companies are putting forth a legitimate effort to protect their data—a small but hugely consequential decision.
We exist in an age of hyper-competition. Gone are the days of being the only option on the block—now, businesses go up against dozens, if not hundreds, of competitors.
So what’s one way to stand out?
A SOC 2 showcases your commitment to security. Ultimately, businesses want to work with companies they know and trust. You can make the “trust” part of this equation much more straightforward by getting your SOC 2.
Allows you to sell to larger companies
It’s common for enterprise-sized businesses and some SMBs to require SOC 2 documentation as a part of their SaaS procurement process. If you’re in a position to meet the needs of these businesses without a SOC 2, you can very quickly lose the bidding war against companies with the attestation.
It makes it easier to obtain other security certifications
Getting one security and compliance certification creates a snowball effect, but that’s a positive. Doing so makes it much easier to obtain subsequent security and compliance certifications since you would have implemented all of the necessary controls and measures.
Many certifications have slightly overlapping and, in some cases, identical requirements, e.g., SOC 2 and ISO 27001.
What do incident management tools do?
If your business wants a SOC 2 or related security and compliance certification, you’re likely already searching for an incident management tool. And you may be very familiar with whether a tool like this will help. For those in the latter group, here’s what a dedicated incident management tool can assist you with:
Ensure outages are resolved as quickly as possible
Many businesses take an ad hoc approach to resolving incidents; in some cases, this works out just fine. But in other cases, this approach leaves businesses liable to more downtime as they scramble to respond tactfully.
A dedicated incident management tool solves this problem by giving businesses a streamlined process to follow during incident response. Ultimately, this reduces downtime as outages are resolved faster.
Give you actionable insights into incidents
Incidents may happen, but you may be doomed to repeat them if you can’t learn from them. Incident management tools allow businesses to glean insights into their resolved incidents that they can implement. This way, you can cut down on wholly preventable incidents that come up repeatedly.
Give you structure around your incident response process
We hinted at this earlier, but an incident management tool gives structure to your response process. From the initial declaration to assigning an incident lead and severity down to creating a post-mortem, incident management tools help ensure that you’re following a workflow that works to resolve incidents faster.
When one action is completed, you’re prompted to do the next, so you’ll never have to guess the next logical step in the response process.
Improve your communications so customers stay in the loop
This is a significant process improvement that often gets overlooked.
Sure, incident management tools can help you streamline your incident response for a drastic cut-down in downtime, but they can also improve both your internal and external communications. Let’s break both of these down:
Internal communications: Let’s use incident.io’s workflow as an example here. When an incident is declared, a Slack channel is created as a place for all communication about that incident to happen. This does away with side channels and consolidates comms into a single location. All actions and updates are visible to everyone on the incident response team. Visibility is essential as a general point, but even more so during the incident response process—an incident management tool helps with this.
External communications: Without an incident management tool, getting your external communications in order becomes a game of whack-a-mole. Who’s the incident lead? Who’s on external comms? What’s the issue in the first place? What’s our ETA for resolution? When you know what’s going on internally, you can communicate more clearly and effectively externally. Let’s say you have a system outage that’s causing global disruption of your product. Once you declare the incident and figure out the root cause, you can jump onto Twitter or LinkedIn or update your status page with relevant information to keep customers in the loop. This way, your customers know that they're always in the loop, no matter what's happening.
So, how does an incident management tool fit into the SOC 2 attestation process?
Part of the requirements for SOC 2 revolves around availability, specifically disaster recovery and security incident handling—the latter of which an incident management tool can help you with.
We’ve touched on most of these throughout this article, but here’s a recap of how integrating an incident management tool can make getting your SOC 2 attestation that much more straightforward.
Automated workflows that allow for seamless incident response
We’re all busy and would love to automate many of the manual tasks we do daily. It can help to look for an incident response tool with built-in automation that walks incident responders through the process. For example, you can set up an automation that nudges responders to create a post-mortem as soon as the incident status is set to closed.
This way, folks can go through the incident response process as seamlessly as possible since they always know the next step—cutting back on your downtime.
A simple incident declaration process that loops in appropriate people quickly
With an incident response tool like incident.io, you can declare incidents very quickly and simply to help you get to the quickest resolution possible. All you need to do is fill out a form with fields like severity and type. To simplify things, you can do all this by typing the /inc command on Slack.
And by setting up appropriate workflows, you can ensure that certain folks are looped in when specific parameters are met, e.g., incidents of a certain severity or type.
Seamless post-mortem documentation
Documenting your incidents is crucial so you can both keep a track record and learn from them. It’s a highly valuable process that will make your incident response better in the long term. With incident.io, you can automatically generate incident post-mortems with relevant information such as response and resolution times, timeline activity, etc.
Deep insights that can highlight vulnerabilities, prompting you to create a more secure product
When it comes to incidents, the more you learn, the better you can prevent them. Incident management tools like incident.io often provide dashboards that show trends in things like severity types, responding teams, duration, seasonality, and more. These insights can help you minimize or eliminate recurring issues, and ultimately help you create a more efficient process and a better product.
Looking to get your SOC 2? Check out an incident management tool
If you’re looking into a SOC 2 attestation to help boost your company’s overall rapport, it’s also worth looking into an incident management tool at the same time.
The latter will help you with many requirements to secure a SOC 2 and make your organization more efficient when responding to incidents. While you can get by with an ad hoc approach, it's important to invest in a scalable, efficient process for long-term benefit.
In the end, if you like the idea of saving time and money, and making your organization more efficient in responding to incidents, then look into a dedicated tool like incident.io.
incident.io helps businesses simplify and take the effort out of incident management. Between automated workflows, deep insights into trends and integrations with over a dozen popular SaaS tools, businesses can save up to seven hours per incident.
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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