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Security reviews for startups
Founders and Sales leaders are all too familiar with the dreaded security review that is a part of closing any B2B deal. At best, these are short 30-minute conversations, and at worst, they take weeks of filling out vendor questionnaires and present the threat of potentially losing a hard-earned deal.
At Vanta we work hard to create tools for companies to improve their own security and showcase their trustworthiness to prospects. This guide has been crafted to demystify security reviews, help readers improve security at B2B companies, and give you direction on how to create trust in the process.
What is a security review?
Security reviews are about trust.
As more and more companies entrust their data and tools with outside vendors, it is increasingly important to prove the security of those vendors.
Companies are trying not only to verify the specific security measures your company is taking, but to see if they can trust that you will take care of their data.
Ultimately, if a breach of data ever occurs, companies also want to be able to say that they did their best to vet the security of their vendor prior to that occurrence.
How do you create trust?
There are many ways to build trust with your prospect’s security team.
Some examples include:
- Spending time on the phone explaining all the security measures your company takes
- Sending policy documents, e.g. your Asset Management Policy
- Presenting an external audit against a common audit framework, such as SOC 2 or ISO 27001, that showcases all the security controls you have in place
- Answering a vendor questionnaire presented by the company
The ultimate goal is to prove that you’ve thought about security; the quicker you can present these types of documents, the better chance you have of moving through this stage.
Ways companies check your security
There are generally two paths a business will take to seek proof of a vendor’s security.
Path 1: Security Questionnaires
A vendor questionnaire is, in essence, a spreadsheet of 30-300 yes/no questions related to all the security measures you’re taking.
Vendor questionnaires can be quite difficult and time-consuming, largely because there’s no standard format.
The most common categories of questions are:
- How does your company store and process data?
- System Access — aka how do employees access customer data?
- What policies do you have in place to ensure security?
- What encryption measures are you taking?
- What compliance checks have you done?
At most startups, the task of answering these questions usually falls to the CTO. As the company grows, they may develop a /security page on their website to address their most commonly asked questions.
- The key to getting through a vendor questionnaire is to work with your lead at the company to determine which questions are most important to them. No company will ever be able to say “yes” to all 300 questions, and you shouldn’t assume that this is what your prospect is seeking.
- Instead, if you figure out which questions are most important to the company, you can work with your team to ensure that those security measures are being addressed.
- We’re sure you wouldn’t have gone there — but know that dishonesty on a vendor questionnaire is a sure-fire way to fail the security review. Your goal is to build a transparent and trust-based relationship with prospects and customers around how your company ensures data security.
Path 2: Get an external audit.
Audits involve a trusted third party, typically a Certified Public Accountant, who creates a comprehensive report that lists all the things your company is doing to keep data secure. Some common examples of practices an auditor will evaluate include having two-factor authentication on google accounts or making sure that laptops’ hard drives are encrypted.
The audit process can take anywhere from a month to a year depending on the size of your company, the current security measures you have in place, and the firm and vendors you choose to work with. As you start selling to larger companies, you’ll find that an audit is required just to begin a sales conversation.
There are many different audit and compliance frameworks, but the most common are SOC 2 and ISO. At a high level, they answer similar questions; ISO is more commonly used and accepted among companies based in Europe, and SOC 2 is more commonly used among American companies. Other industry-specific audit and regulatory frameworks include HIPAA and FedRamp.
The major benefit of completing an audit is that your audit results will be accepted by most companies as proof of security. Rather than filling out a customized questionnaire for each company, you can send your SOC 2 or other audit report to every prospect. Going through an audit can help your company get ahead of security conversations more generally; the effort of getting audited demonstrates that you are serious about keeping user data secure.
The audit process can be broken up into stages: becoming audit ready, and the audit itself.
Becoming audit ready
Audit preparation involves developing a list of 70-100 rules (also known as controls) that your company follows. While this process varies from company to company and there isn’t a standard set of rules or controls that all company types must abide by, there are a number of likely controls your company will want to implement to prepare for an audit. These may include implementing single sign-on and two-factor authentication; implementing a centralized logging system; ensuring disk encryption and timely patches; conducting vendor risk assessments; performing employee background checks; creating a vulnerability management policy, and more. The complexity of detailing the rules your company follows (and will follow) often leads companies to seek outside help to become audit ready.
After creating a list of rules for your company, you’ll create a Gap Assessment that flags all the rules that you aren’t currently following.
Once your company has developed its Gap Assessment, you will enter the Remediation stage, where you begin to fix the items on the list that aren’t yet implemented at your company.
Remediation is the longest and hardest part of the audit process. Once you’ve completed Remediation, you are ready for the audit itself.
Now that your company has completed its list of rules (aka controls), you must find an auditor to attest to the fact that you are doing all the things you said you were.
Depending on the tech-savviness of the audit firm, the audit process can range from four to 40 hours and is typically done in person. The process of auditing your company’s practices against your stated controls involves gathering detailed evidence. Most audit firms gather evidence by taking screenshots that demonstrate how you follow each of these rules.
After the in-person visit, the firm will then prepare a comprehensive report — imagine a ~60 page PDF — that lists these rules and attests to the fact that you follow them.
How do most startups tackle security reviews?
We have seen a lot of companies go through this process, and can share some general data and observations on how most companies tend to handle their security reviews. Of course, every company is different.
Most companies tend to start thinking about security the first time a prospect sends them a vendor questionnaire. They then scramble to answer all of the questions one by one, looping in technical members of the team and trying to complete the detailed questionnaire as quickly as possible.
Startups either choose the “whack-a-mole” approach of answering each questionnaire as it comes up, or they try to create a list of security measures that they send to all companies.
In this approach, startups may also put together one-off security measures to send to prospects, including:
- Penetration tests (aka Pen Tests)
- Copy+Pasted Policies (not the best idea)
- Documents prepared by the CTO answering these questions
While this approach will work for some small and midsize businesses, it will rarely satisfy the needs of larger companies.
As your company aims to secure the business of larger enterprise clients, you’ll notice an increased demand among prospects for an audit and a standardized report of its results. Here at Vanta, we recommend getting a SOC 2 audit as early as possible because it will push your startup to think critically about security practices at an early stage and it will result in more closed deals and shortened sales cycles.
Vanta is “security in a box” for companies of all shapes and sizes, trusted by hundreds for their SOC 2 preparation and more. Vanta provides a suite of automated security and compliance tools that scan, verify, and secure a company’s IT systems and processes. Vanta’s cloud-based technology identifies security flaws and privacy gaps in a company’s security posture, providing a comprehensive view across cloud infrastructure, endpoints, corporate procedures, enterprise risk, and employee accounts. Vanta also offers a set of tools to streamline the non-technical components of security tracking and audit preparation, so gathering and consolidating audit evidence is easier for both your company and your auditor. Ready to get started?
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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