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Meet the Vanta Privacy, Risk, & Compliance Team
As Vanta continues to grow and deliver new capabilities to our leading trust management platform, we’re excited to share more about our own Security, Enterprise Engineering, and Privacy, Risk, & Compliance teams from the teams themselves.
Today, you’ll hear from Matt Cooper, Senior Manager of Vanta’s Privacy, Risk, & Compliance team, and Adam Duman, Information Security and Compliance Manager on the team.
What does the Privacy, Risk, & Compliance team do at Vanta?
The Privacy, Risk, & Compliance team provides internal and external support for Vanta’s customer, auditor, and partner experience in service of the company’s mission to secure the internet. We work in close collaboration with Vanta's Security team to operate our security, privacy, and compliance programs on a daily basis. In addition, we act as Vanta’s subject matter experts in compliance, risk management, and privacy, and also advocate for customers and partners within Vanta’s Product organization.
This means we interface with nearly every element of Vanta’s business to ensure we walk the talk of trust and compliance, deliver on regulatory privacy requirements and processes, and deliver market-leading insights and product solutions for our customers and partners.
How does the team work?
Like Vanta’s Security team, Vanta’s Privacy, Risk & Compliance team embraces Vanta’s remote-first philosophy. We operate across multiple time zones and support Vanta’s global business, which means we’re never far from the action.
Whether it’s a new compliance framework, product feature, or internal initiative, our work is both highly collaborative and highly independent. On the one hand, our work requires close partnership with multiple teams within Vanta. On the other hand, our work also requires a self-starter mindset to identify and drill into the next big thing we need to focus on—before anyone else has seen it.
How is the team structured?
The Privacy, Risk & Compliance team is structured around three main domains (privacy, risk, and compliance) and a host of sub-domains. Our team meets at the start of each week to discuss our goals and our operational and strategic approach for each.
Here’s an overview of the types of work we tackle:
Within privacy operations, we deliver on Data Protection Impact Assessment (DPIA) and Transfer Impact Assessment (TIA) requests from customers and partners, and review our internal and external privacy operations. We support Vanta counsel in the review of customer and vendor security and privacy requirements.
In addition, we respond to Subject Access Requests (SAR) under both GDPR and CCPA. We also continuously validate that our website and product are behaving in ways that are in line with regulatory demands, follow best practices defined by the International Association of Privacy Professionals (IAPP), and do the right thing for our customers and website visitors.
Affectionately dubbed “Vanta on Vanta,” we keep a close eye on Vanta to ensure we continuously maintain the trust we’ve built with our customers, partners and investors. We drive ongoing compliance for our own SOC 2, ISO 27001, GDPR, CCPA/CPRA, and HIPAA support. This includes weekly product check-ins with our primary stakeholders and daily follow-ups for controls in need of attention.
This means we use Vanta ourselves—and have the incredible opportunity to provide direct feedback to Vanta’s own Product and Engineering teams around features, functionality, and ideas. In these types of scenarios, we work the same way as Vanta’s customers. We submit product feedback, and work with our own Customer Success Manager to identify solutions to more effectively use our own product and maximize the value we get from Vanta.
Within Risk Management, we collaborate closely with the Security team. We maintain a robust and thorough risk register that’s shared with our company leadership regularly and incorporated as part of our quarterly and annual planning process. With our backgrounds in privacy, security engineering, cyber threat intelligence, and various other security and privacy domains, we’re able to partner closely with the Security team to identify and address our risks via a comprehensive risk management approach.
Product Support and Development
We’re fortunate to have experience on both sides of the table as assessors and implementers for multiple standards and in multiple environments, which gives us the opportunity to provide unique input and insight on deliverables for Vanta’s Product teams. In collaboration with Product leadership, we triage requested standards and features, help identify the best places for Vanta to improve support for our customers and partners, and deliver foundational elements for these initiatives to support the company’s mission of securing the internet—while making it as easy and simple as possible to achieve and demonstrate trust.
This can take many forms, from referencing source documentation for security and privacy standards and frameworks to partnering closely with our Product team to address valuable feedback from our customers. We also tackle work that may never see the light of day, but nonetheless serves as inputs in our ongoing efforts to continuously improve Vanta’s product.
Rather than maintain the status quo of compliance, we like to reimagine how our world works, and seek out new ways to empower Vanta’s customers and partners alike.
GTM Enablement & Support
Working closely with our Marketing and Enablement teams, we provide training and pre- and post launch support on Vanta’s products. Our goal is to support our Customer Success Managers and Account Executives to provide solutions for customers and partners, whether in direct conversations with Vanta’s customers or in the background by supporting our customer-facing teams.
Where can prospects and customers learn more about Vanta’s privacy, risk, and compliance program?
You can read more about our privacy, risk, and compliance program on Vanta’s website. We also have resources for prospects and customers on our Trust Report and in the Vanta Blog and the Vanta Learning and Communities accessible from the Resources section of our website.
What excites you the most about Vanta’s product and mission?
From our team’s perspective, the easy problems in this space have been solved—and as experienced practitioners, we’ve had the opportunity to see what works and what doesn’t. It’s important to execute well on the fundamentals, like patching systems, providing employee training and support, aligning with business stakeholders, and more. But we’ve also seen and experienced the reality that even though the fundamentals are fundamental for a reason, executing on them can be challenging to navigate in the real world.
What excites us about Vanta is that we have an opportunity to tackle the underlying issues that make these tasks and processes hard in practice—or at least highly manual. Vanta exists to help bridge these gaps, and make those handoffs smoother and more manageable for teams with other work as well.
Any fun facts about the Vanta Privacy, Risk, & Compliance team?
- Our team consists of individuals who have built deep careers as security, privacy & compliance practitioners—and love the space they’ve built their expertise within!
- All members of the team enjoy tiny homes, but agree they wouldn’t want to live in one full time.
Join Vanta’s mission to secure the internet and protect consumer data—learn about our open roles!
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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