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How to start a security compliance program
Security compliance programs help your organization identify, implement, and maintain appropriate security controls to protect sensitive data, comply with laws and contractual obligations, and adhere to the standards, regulatory requirements, and frameworks needed to protect customers and enable the business to succeed.
In other words, with a security compliance program in place, companies are able to demonstrate that they meet designated security requirements and objectives. These objectives can be internally-defined or established by industry-specific standards, external organizations, or government agencies.
In this post, Matt Cooper and Adam Duman from Vanta’s Privacy, Risk, & Compliance team explain how you can start a security compliance program in your organization.
How to identify when you need a formalized program
Alongside the evolution of a company’s security journey, your organization might want to proactively opt to build a security compliance program. The right time to set up a formal security compliance program will look different depending on your organization. Indicators to consider a formal investment might include:
- You’re unable to close deals: If you’re running into compliance as a sticking point in deal cycles, you’re looking at a fork in the road for the kinds of customers you’ll be able to work with in the future. Your customers expect you to be compliant; more mature companies will often expect you to mature too.
- You aren’t following common best practices: If you’re increasingly noticing that what you do seems to be genuinely unique or doesn’t sound like how your peers are operating, it's probably time to look to formal guidance. Remember, it’s far easier to implement these practices early on—organizational inertia, process friction, and complexity sneak up quickly.
- Increasing regulatory or social pressure: If you know you’re in violation of regulatory commitments, you could be risking fines that could jeopardize the operation of the organization. In addition, if you’re in a field or area that is highly contentious, high risk, or potentially viewed with a high level of skepticism, you may want to consider a formal investment in security compliance.
- If you’re unable to answer security questionnaires fully or transparently: While we hope this isn’t the case, if you’re unable to answer questionnaires thoroughly, it may be time to bite the bullet and start moving in a more definitive direction.
Steps for getting started
Step 1: Define your organizational goals and needs
Start by identifying your organizational goals and needs. For instance, are you starting the program to close deals? Do you want to proactively demonstrate trust or compliance? More importantly, what are you trying to accomplish and why? After answering these questions, we recommend identifying your desired end state and vetting and aligning this with key stakeholders and their needs. The more granular you can be about your intended goals and desired end state, the easier it will be to work backward to work toward your objectives and to bring others on board as well.
Before worrying about which standard to implement or what tools to buy, it’s critical to ensure these goals are doing more for the organization than just unblocking deals or solving for one problem. At Vanta, we leverage our compliance efforts as force multipliers wherever possible. For instance, a known compliant process in one business unit could potentially be adapted to work in another, which could streamline cross-functional work and alignment across different projects.
Step 2: Define your roadmap and timeline
Next, define your roadmap and timeline to understand what you’ll need to do along the way to achieve those end goals. Consider breaking your timeline down into specific milestones you’ll be able to track and work toward along the way. In addition, think through whether there are any dependencies you’ll need to account for and how they relate.
This step should include identifying the answer to questions such as:
- What are our known technology needs or gaps?
- Do we expect we will need to invest in some additional tooling or support?
- Do we have an understanding of the technical demands of where we want to go?
- Do we build, buy, or partner?
For instance, if you’d like to build and are planning to hire for the role, consider whether you need someone who’s more of a manager who can set direction or someone who’s willing to roll up their sleeves as a doer. This is especially important for a foundational role like your first compliance hire.
If you opt to buy or partner, consider whether using services such as a virtual CISO (vCISO), Managed Service Provider (MSP), or other fractional resources could address your needs and objectives in a more cost-effective manner. This is especially important if you have a very broad tech stack or complex operations, as an MSP or vCISO firm will usually have access to more expert resources than any one person can be expected to know. If you’re building a program from the ground up or for the first time, it may be more cost-effective to use a trusted third party to supplement your work than to hire one or more FTEs to build a program in-house. Regardless of what option you go with, you’re likely looking for an individual—or even a team—with privacy and/or compliance knowledge as well as technical engineering knowledge.
Part of defining your objectives also includes measuring your progress and ensuring that what you’re measuring is relevant to your intended outcomes. As you develop your program, be sure to identify key metrics that help your organization understand and share the achievements and outcomes of your security compliance program.
Remember you’ll need to prioritize what you’ll build and when. This is especially true given that you’ll likely have a long list of action items, and more tools and needs than you have budget for. The approach we’ve taken at Vanta is to align our security compliance program with our business objectives—which also ensures we’re meeting the needs of our customers and our overall business.
As a tip, our team likes to reference Verizon’s Five Constraints of Organizational Proficiency as described in their 2019 Payment Security Report to help structure our approach to our compliance program. This framework highlights the importance of capacity, capability, competence, commitment, and communication as key for the health and effectiveness of a strong data protection compliance program—we suggest giving it a quick read if you’re interested!
Step 3: Prioritize and start building
Now that you have an understanding of your needs and timeline, it’s time to start prioritizing your efforts based on the needs and constraints of your business. You can start by taking the following steps:
- Double-check alignment with business objectives—does your plan still look like what the business needs or has it had some scope creep or plan drift that might introduce unnecessary friction?
- Set up official deadlines based on your new understanding of your project goals, and officially kick off the implementation of your program.
Remember, security and compliance are infinite black holes without context. Make sure that what you are planning on doing for compliance has guardrails to ensure you’re spending your time and effort in places that drive measurable business outcomes.
Lastly, understanding, defining and communicating why you’re working toward these objectives—whether toward meeting customer needs, revenue goals, or internal risk reduction—can bring others on board as well.
Additional considerations: stakeholders and resources
Don’t forget that executive sponsorship, commitment, and budget are some of the most critical components of a strong security compliance program. We suggest seeking these out earlier rather than later, and continuing to build this bridge by highlighting risks, impact (including positive!) and your company’s overall security compliance journey.
As discussed in our previous post, we use Vanta as a key element in building and scaling our own security compliance program. Vanta’s Partnerships team also has a strong network of trusted organizations who can guide you in the process of defining and getting started on your own security journey.
After you determine your goals and identify your tooling and technology needs, it helps to know what tooling is available and what meets those needs most. Referencing industry trends and feedback can be a good place to start, as well as networking with others in the industry who are or have addressed similar challenges.
Tips and suggestions for building your security compliance program
While every team and company approaches building security compliance programs slightly differently, here are a few tips we’d suggest:
- Build repeatability: While it may be tempting to aim for quick wins, focus on repeatable processes and repeatable outcomes within your program. Remember that fire drills are often an indication of broken processes.
- Start with a strong foundation: Focus on the fundamentals and do your basics well—no matter how mature your program, the fundamentals always matter.
- Avoid shiny object syndrome: Tools and technology may help, but will only exacerbate broken processes.
Read more from Matt and Adam: Meet the Vanta Privacy, Risk, & Compliance Team
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?
If any of the above apply to your business, you’ll need to get GDPR compliant.
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
racial or ethnic origins
genetic data
political opinions
biometric data that can uniquely identifying someone
religious or philosophical beliefs
health, sex life or sexual orientation data
trade union membership
Determine whether your Data Map meets the requirements for Records of Processing Activities (Art. 30)
the name and contact details of the controller
the purpose behind the processing of data
a description of the categories of data that will be processed
who will receive the data including data
documentation of suitable safeguards for data transfers to a third country or an international organization
the retention period of the different categories of data
a general description of the technical and organizational security measures
Determine whether your Data Map includes the following information about processing activities carried out by vendors on your behalf
the name and contact details of the processor or processors and of each controller on behalf of which the processor is acting, and, where applicable, of the controller’s or the processor’s representative, and the data protection officer
the categories of processing carried out on behalf of each controller
documentation of suitable safeguards for data transfers to a third country or an international organization
a general description of the technical and organizational security measures
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?
consent of the data subject
contract with the data subject
necessary for compliance with a legal obligation
necessary in order to protect the vital interests of the data subject or a third party
necessary for the performance of a task in the public interest or in the exercise of official authority vested in the controller
necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the rights of data subject
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)
Do your agreements cover the following items?
vendor shall process the personal data only on documented instructions (including when making an international transfer of personal data) unless it is required to do otherwise by EU or member state law
vendor ensures that persons authorized to process the personal data are subject to confidentiality undertakings or professional or statutory obligations of confidentiality.
vendor have adequate information security in place, technical and organizational measures to be met to support data subject requests or breaches
vendor shall not appoint or disclose any personal data to any sub-processor unless required or authorized
vendor shall delete or return all the personal data after the end of the provision of services relating to processing, and deletes existing copies unless Union or Member State law requires storage of the personal data;
vendor makes available all information necessary to demonstrate compliance and allow for and contribute to audits, including inspections
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?
Does your processing involve any of the following?
automated processing, including profiling, and on which decisions are based that produce legal effects
special categories of data or data related to criminal convictions and offenses
monitor publicly accessible area on a large scale.
If any of the above are true, you may need to conduct a Data Protection Impact Assessment for existing and new data projects.
Review product and service design (including your website or app) to ensure privacy notice links, marketing consents, and other requirements are integrated
Do you have a public-facing Privacy Policy which covers the use of all your products, services and websites?
Does the notice to the data subject include the following items?
the identity and the contact details of the organization and its representative
the contact details of the data protection officer, if applicable
the purposes to process personal data and its legal basis for the processing
the recipients or categories of recipients of the personal data, if any
the details regarding any transfer of personal data to a third country and the safeguards taken applicable
Does the notice also include the following items?
the retention period, or if that is not possible, the criteria used to determine that period
the existence of the data subject rights (i.e. requests for information, modification or deletion of PII)
the right to withdraw consent at any time
the right to lodge a complaint with a supervisory authority
whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the data subject is obliged to provide the personal data and of the possible consequences of failure to provide such data
the existence of automated decision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the consequences
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
Do you have an Employee Privacy Policy governing the collection and use of EU and UK employee data?
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)?
the data processing is carried out by a public authority
the core activities of the controller or processor require regular and systematic monitoring of data subjects on a large scale
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?
data processing is occasional
data processing is not on a large scale
data processing doesn’t include special categories or data related to criminal convictions and offenses
doesn’t risk to the rights and freedoms of data subjects
a public authority or body
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
This includes pseudonymization/ encryption, maintaining confidentiality, restoration of access following physical/technical incidents and regular testing of measures
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
Download this checklist for easy reference
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
- Communication
- 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
Learn more about achieving ISO 27001 certification with Vanta
Book an ISO 27001 demo with Vanta
Download this checklist for easy reference
Download NowDetermine 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
Download this checklist for easy reference
Download NowMatt Cooper
Adam Duman
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