Introducing automated ISO 27001 and HIPAA compliance
Vanta was founded in 2017 with a mission to secure the internet and protect consumer data. From the ever-increasing number of data breaches, it’s clear that online security is only becoming more important. At the same time, we understand how hard it can be for fast-growing companies to invest the time and manpower it takes to build a solid security foundation.
That’s why we started by automating SOC 2, the most commonly-accepted framework for demonstrating security in the United States. But SOC 2 has always been just the beginning for Vanta. In May, we announced an invite-only Beta for our two other most requested security standards, ISO 27001 and HIPAA.
Today, after several months of product refinement, we’re excited to announce public availability of our ISO 27001 and HIPAA compliance products. These standards are now available as standalone services or packaged with our award-winning SOC 2 offering.
With this release, Vanta customers can enhance their security posture and prove compliance––all in one automated security platform.
ISO 27001 is the global benchmark for demonstrating an effective Information Security Management System (ISMS). For businesses selling to customers outside of the US, a well-defined ISMS may be required by local law and potential buyers will likely ask to see an ISO 27001 certificate prior to purchasing.
Becoming ISO 27001 certified is a months-long to even year-long process that requires documenting policies and procedures, identifying risks, assigning responsibilities, and training personnel. Further, ISO 27001 certification includes both an internal and external audit to ensure that an organization’s ISMS has been properly implemented.
Fortunately, Vanta’s ISO 27001 product brings clarity to this complexity. Vanta provides customizable policy templates to help you define the scope of your ISMS, assign roles and responsibilities, identify risks and mitigation measures, and more. And the Vanta platform leverages read-only integrations with leading cloud providers, task trackers, MDMs and more to automatically collect evidence for and map it to your Annex A controls.
In fact, Vanta automates over 80% of the ISO 27001 certification requirements - meaning you can spend less time on compliance, and more time growing your business.
As one of our ISO 27001 Beta customers said:
"Lots of companies claim to automate compliance but Vanta is actually doing it. They really help guide me through the SOC 2 and ISO 27001 experience. This is my first time working with both of these frameworks and I really appreciate having the Vanta team behind me to support."
– Vicky Levay, Director of Compliance at FloQast
Companies that create, access, store, or share Protected Health Information (PHI) must comply with HIPAA legal requirements or potentially face steep fines and penalties. But becoming HIPAA compliant can be a complex and time-consuming process. And because there is no independent audit associated with HIPAA, it can be difficult to even know whether or not you’re compliant at any given time.
Vanta’s HIPAA product demystifies the path towards becoming and staying HIPAA compliant. In fact, Vanta automates over 85% of the evidence requirements needed to prove HIPAA compliance and helps you manage the evidence that is not automated, such as signed Business Associate Agreements. Additionally, built into Vanta are CPA-vetted policy templates that help you codify your company’s PHI privacy and security procedures, saving you from drafting these documents from scratch or hiring a security consultant.
With Vanta’s HIPAA product, you’ll spend less time chasing down evidence from employees, systems, and Business Associates––and confidently track progress towards HIPAA compliance in one place.
As one of our HIPAA Beta customers said:
“Vanta's policy generator really saved our small team a lot of time at the beginning, to cover all our bases for SOC2 and HIPAA, especially as we're not experts in writing policies. It provides a solid foundation with a lot of options and the ability to fully customize them as needed.”
–Anthony Powles, Head of Security at HeyMarket
The Vanta Platform
Vanta streamlines the path towards compliance with powerful automations, reports on where your business stands, and clear instructions on how to fix any gaps. Vanta does this by leveraging a robust library of API integrations that connect with the business tools you already use to automate most of the evidence gathering process. Vanta’s continuous monitoring platform is the foundation for all of the standards we support.
And to better serve our customers pursuing multiple standards at once, Vanta now gives you a single view to easily track progress towards each standard––and see the specific controls and pieces of evidence behind each requirement.
We’re very excited to introduce ISO 27001 and HIPAA compliance, our two most-requested standards. With SOC 2, ISO 27001, and HIPAA support, Vanta customers can further demonstrate their enhanced security posture, comply with US federal law, and reach new global customers. Book a demo to learn more.
Vanta restores trust in internet businesses by giving startups an easy-to-use set of tools to improve and prove their security. Over 1,000 fast-growing companies rely on Vanta to automate their security monitoring and prepare for SOC 2, ISO 27001, or HIPAA compliance in weeks instead of months. Vanta was founded in 2017 and is headquartered in San Francisco.
For more information, visit https://www.vanta.com.
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?
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
- 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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