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ISO 27001 for startups: What every startup needs to know
Building a startup is always a learning process, whether you’re a new entrepreneur or you’ve built a dozen businesses in the past. Every business has its own hurdles and challenges, so no two startups have the same experience with funding, product development, client acquisition, or other aspects of launching a company.
One area that can also vary considerably is your startup’s compliance needs. There are regulations and standards for businesses in technology, businesses in healthcare, and so on. You may need to document your compliance with several standards, but if you use secure data in any way and you want to do business with any customers or partners outside the US, ISO 27001 will be among them. Consider this to be your introductory guide to ISO 27001 for startups.
The basics of ISO 27001
In a nutshell, ISO 27001 is a standard that was developed by the International Organization for Standardization. Its key focus is your Information Security Management System (ISMS). In other words, this standard is designed to determine whether you have the controls in place to properly secure the data you use.
Who needs to get ISO 27001 certified?
ISO 27001 is not a law, so technically, it isn’t legally required. However, most organizations internationally, whether they’re potential customers of your business or potential partners, will not do business with anyone who does not have ISO 27001 certification.
Because of this, every business should work toward ISO 27001 compliance and certification if they meet two criteria:
- You collect, store, transmit, or process data in any way
- You want to do business outside the US (or both outside and inside the US)
How to get ISO 27001 certified
The process for acquiring your ISO 27001 certification is a multi-step endeavor, and depending on how prepared you are and how thorough your ISMS already is, it could be a long process. Generally, though, you’ll follow these steps to get your certification:
1. Assess your ISMS
Before you invest in hiring an auditor you want to be as confident as possible that your ISMS will pass the certification assessment. The best way to begin is with your own assessment of your ISMS against the ISO 27001 controls to see how you stack up. This may be called a gap analysis. A software tool like Vanta can automate this for you by evaluating your ISMS and giving you a clear checklist of which controls you meet or don’t meet.
2. Fix your ISMS
After your gap analysis, you have a clear idea of what you need to do to bring your ISMS up to the standards of ISO 27001. Use this checklist to prioritize and update your ISMS so that you’re confident it will pass a formal ISO 27001 audit.
3. Choose an ISO 27001 certification provider
It’s important to note that while the ISO developed ISO 27001, the organization doesn’t actually provide certification. You can only get ISO 27001 certification from third parties. However, the ISO does have a list of standards that all these auditors and certifying organizations should adhere to, called CASCO. Be sure to choose an ISO 27001 certification provider that adheres to CASCO standards and is also accredited by the appropriate board in your country.
4. Complete the auditing process
When you’ve hired your ISO 27001 certification provider, you’ll then start on a two-step auditing process. The first step is an informal readiness assessment, which takes a cursory look at your ISMS to see if it measures up to the ISO 27001 standards. If your system passes the readiness assessment, you’ll move on to step two: the formal audit.
A formal audit can take weeks to perform because the auditor is thoroughly investigating your ISMS. At the end of this audit, you’ll either pass or fail based on what the auditor finds. If you fail, you’ll have the added expense of paying for a new audit after you’ve fixed the issues. If you pass, your auditor will give you your full report as well as your ISO 27001 certificate. Customers or partners may ask to see both of these, so keep them secure.
5. Maintain future compliance
ISO 27001 compliance isn’t something you complete once and then move on. You will have some level of assessment each year to keep your compliance. For each of the next two years, your auditor will only assess a few controls or aspects of your ISMS at random to see if they still pass. If they do, you maintain your certification. If they don’t pass, you’ll need to undergo another full audit to determine if your certification stands. After three years, you’ll need a new full audit regardless to be recertified.
How to make your ISO 27001 certification process startup-friendly
For startups, both finances and manpower are typically in short supply. As essential as ISO 27001 certification is, it can be an expensive and labor-intensive process. To make your certification more manageable for your budding business, a compliance automation tool like Vanta will automate over 80% of the work needed to prove compliance.
Vanta gives you an automated assessment to determine what you need to do to reach ISO 27001 compliance. It also gathers thorough documentation of your ISMS and security controls, making your audit smoother. Vanta even offers policy templates to help you develop the policies and protocols your security system needs. Vanta also automates future assessments to help you maintain your compliance.
Learn more about ISO compliance
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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