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How we operationalize security risk assessments at Vanta
This post is part of an ongoing series where you’ll hear directly from Vanta’s own Security, Enterprise Engineering, and Privacy, Risk, & Compliance Teams to learn about the team’s approach to keeping Vanta—and most importantly, our customers—secure. In today’s post, you’ll hear from Rob Picard, who leads Vanta’s Security team, and Matt Cooper, who leads Vanta’s Privacy, Risk, & Compliance team.
Why security risk assessments are important
Risk assessments are exercises that help an organization understand, analyze, and address the most significant risks to their objectives. By approaching these exercises with a little formality, we can better respond and make sure that our risk treatment plans don’t fall through the cracks.
What would prevent your organization from achieving its objectives or missing opportunities? What are known weaknesses or vulnerabilities within your environment? How will you address or accept these? Conducting formal risk assessments helps you uncover and understand these answers before adverse events happen (or your auditor points them out).
As Vanta continues to grow, our internal Security and Privacy, Risk, & Compliance teams have worked together to develop a methodology for conducting information security risk assessments, both on a defined cadence and on an as-needed basis. Our goal for this post is to share more detail about our approach to operationalizing our security risk assessments, as well as tips for getting started if you’re new to risk assessments.
How to approach security risk assessments
It’s important to remember that security risk assessments aren’t one-size-fits-all. How you structure your risk assessments will depend on what works for your culture and your objectives. In general, industry best practices and just about any compliance framework you’re implementing recommend that formal risk assessments should be conducted at least annually.
Assessing risk is a skill that can be embedded in many processes throughout your organization. While you might commit to a thorough enterprise-level risk assessment on an annual basis, risk should be considered for all projects and initiatives your organization undertakes. This can be baked into your product development lifecycle, business change processes, changes to technical infrastructure, and more.
Importantly, if you’ve identified risks on an at-least annual basis, be sure to consider these (and remind teams who may own specific risks) to incorporate these when planning for future work. More specifically, teams should plan specific work or allocate a certain percentage of their bandwidth to address or reduce significant risks that have been identified.
How Vanta operationalizes security risk assessments
Models for risk assessment differ by team and organization depending on how risk assessments are used. Vanta runs our enterprise-wide security risk assessment on an annual basis, and we incorporate considerations of risk throughout our daily workflows and processes.
Here are a few specific lessons we’ve learned while implementing this for our business:
- Process and cadence: First, determine the most appropriate process and cadence to run your risk assessment. This will include updating your assessment document and defining a risk treatment plan for each identified risk. If you don’t have a specific cadence in mind, consider starting with a quarterly cadence, which can always be adjusted to be more or less frequent depending on your needs and goals.
- Tracking: Determine how you’ll track the work that comes out of your risk assessment, whether manually in a spreadsheet or fed into a ticketing system like Jira. This helps you understand the volume of potential work required to track discussions, decisions, and next steps with the action items that derive from a risk assessment.
- Definitions: Define your criteria for what constitutes a risk. For instance, if you’re a small business, you may have a different threshold than a large enterprise for what constitutes a risk. In addition, it helps to consider the levels of impact that a risk could pose to your business, as well as the likelihood of occurrence. Here’s an example of how we’ve defined these levels at Vanta:
- Structure: Decide if you’ll incorporate more frequent, smaller risk assessment activities into your risk assessment document and if so, how. You may also opt to only conduct one larger risk assessment per year instead of more frequent assessments.
- Audience: Consider your audience — for instance, is your risk assessment primarily for compliance purposes or internal purposes to manage business risk? If for compliance, you might opt to update this less frequently but ensure you have a thorough, comprehensive review prior to kicking off your audits. If it’s for your business, you might consider a process that’s more iterative and dynamic, with greater availability to your team so more stakeholders are able to interact with your risk assessment project. In addition, you’ll likely want an integration with whichever ticketing platform makes most sense, which not only helps with tracking but also enables your teams to tie their work to reducing business risk.
Guidance for presenting risk assessments
After conducting your risk assessment, you’ll want to determine who to share the results with — it’s common to share your findings with a leadership or executive team.
When presenting your risk assessment, be mindful of your audience and practical outcomes, and remember that less is usually more. For instance, distilling your risks to a focused, prioritized list of higher-level risks is more digestible and impactful for a senior manager or leadership team than enumerating dozens of granular risks.
In addition, consider who will be presenting or part of the presentation. In general, those who were involved in conducting the risk assessment should either be part of the presentation or have rigorously prepped the presentation team. This is because it’s important to be able to understand the level of detail needed to support questions at a tactical level, particularly from an executive or leadership team.
And finally, be sure you’ve already defined thorough risk solution plans for each identified risk before presenting. As with any challenges you’re presenting to an executive team, remember that their role is to provide oversight, not to ask them to actually conduct the risk assessment work or arrive at solutions themselves.
Tips for getting started
While every company and organization’s approach to operationalizing risk assessments may differ, here are a few tips from Vanta’s Security and Privacy, Risk, & Compliance teams:
Remember that you don’t have to boil the ocean: You can start by creating a security risk assessment that will fundamentally meet your compliance objectives and will help set an annual checkpoint for the business
How to get started: It can help to use a tool like Vanta to conduct your risk assessment in a systematic way. In any case, you can start with the following steps:
- Ask a simple question of your leadership team and managers: “From an information security perspective, what situations would be bad for our business? What are you worried about?”
- Regardless of likelihood or impact, these can be defined as threat scenarios — be sure to incorporate any additional technical detail needed.
- Once you’ve gathered your threat scenarios, you can turn these into a formalized risk scenario by including an event and an outcome, e.g. “Employee installs malicious remote access tool, leading to breach of customer or company data.”
- For each threat scenario, identify the controls you have in place to ensure it doesn’t happen, as well as the known vulnerabilities. Remember that vulnerabilities may not always be technical — they can also be factors of your environment that make the threat scenario more realistic or concerning.
- Next, discuss the potential impact this threat scenario could have, as well as how likely it is to occur. You can rate these in a way that makes sense for your organization, whether on a scale of low to high, 1-3, or otherwise.
- Finally, discuss and capture what you’ll do about this scenario — for instance, you may decide to accept, transfer, mitigate, or avoid the risk as an organization.
Interested in learning more? Read more from Matt Cooper about how to work backward from the controls to perform an information security risk assessment.
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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