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Vanta’s 6 principles for pragmatic startup security
Building startups is hard; securing them can be downright confusing. There are a mess of standards, frameworks, consultants, and bloggers. Even YouTubers are competing to overwhelm you with advice.
There is often an underlying assumption that security should be the main concern of the startup founder and early engineers, but that’s not always the case. Security is a tool to protect your customers and your business, and a founder’s main concern is growing that business. That’s a good thing.
It usually takes several years for security jobs to appear at a new startup. In the beginning, it’s a shared responsibility of everyone working to build the business. With this in mind, Vanta has put together a set of tips for a more pragmatic startup security program. These are the things that should matter to your team on day one. They’ll not only improve your security, they’ll make it easier for your team to scale quickly and safely. If you’re wondering whether you’re behind the ball when it comes to your startup’s security, this list should help you close any gaps in the early stages of growth.
1. It’s easier to secure one thing than it is to secure many things
Use SSO everywhere you can
Today there are a ton of SSO tools to choose from. If your team uses Google Workspace, you should sign in to everything you can with Google. The same idea applies to any other identity provider. This gives you the opportunity to securely configure one system and avoid inconsistent configurations, like multi-factor authentication (MFA), across different tools.
Write your infrastructure as code
Tools like Terraform or CloudFormation allow you to define your cloud infrastructure in code. This means changes can be peer reviewed and tracked in revision control repositories. This also means you don’t have to dig through dozens of dashboards to spot insecure configurations. Everything comes back to the source.
Consider Mobile Device Management (MDM)
MDM software manages the configuration of all of your employee laptops from a single tool. This lets you set up things like disk encryption, firewalls, screen locks, and installed software consistently across your whole fleet. If you’re not ready to deploy MDM software yet, you should try and centralize the process of setting up new employee machines as much as possible. This could be a simple shell script you have new employees run during onboarding.
Having a centralized deployment pipeline allows you to provide an easy “paved path” for engineers to deploy their code. If you’re asking everyone to SSH into production machines every day, you’re opening yourself up to more work, higher rates of human error, and a larger attack surface that needs to be secured.
2. Keep secrets secret
Get a password manager
Look into getting a team plan for a password manager. Your team will inevitably need to create, store, and share passwords to get their job done. If you want them to do so with minimal risk of using insecure passwords, and inadvertently leaking them, you want them to use a password manager. When someone joins your company, set them up with a license on your team plan to ensure effortless security.
Know your vendors
Vendor management can be a big rabbit hole, so keep this one simple. The goal here is to create a list all of the companies you share important things with, and to do some basic due diligence on those companies. You should set up a system to accomplish those goals with simplicity in mind. Here’s what an efficient system might look like:
- You keep a spreadsheet called “Vendors”
- Vendors that receive customer data or have some control over your production environment should be labeled “High” risk
- Label them “Medium” risk if they receive intellectual property or metadata about your customers (e.g. contract details, communications, etc.)
- Label them “Low” risk if they’re only getting metadata about your company (e.g. a payroll provider)
For all High and Medium risk vendors, ask a few security questions before going forward with them:
- Who are the people responsible for your company’s security program? What are their roles/responsibilities?
- Have you had a security incident in the last three years? If so, please share what happened, how you responded, and what you changed as a result.
- What kind of tools are you using to secure your product and your company?
When they answer these questions, ask yourself “Do I trust these people with my customers’ data? Do I believe they will keep it safe?” When it comes to High risk vendors, ask for documentation as proof of their security. SOC 2 and ISO 27001 are commonly used to satisfy this query. It’s also normal to ask for their most recent penetration testing results. They’ll usually have a report ready for external distribution, but you’ll likely need to be under a non-disclosure agreement to acquire these documents.
3. It’s harder to hack two things than it is to hack one
Use MFA everywhere you can
Your team probably has a lot of accounts to manage for a variety of tools. Not all of them will support SSO. If you have to use a password somewhere, you should require a second factor as well. Passwords aren’t perfect, so having a good second authentication factor makes it incredibly unlikely that someone will gain unauthorized access. To really lock this down, avoid using SMS-based MFA. It’s known to be relatively easy to bypass in a targeted attack, because phone companies aren’t very resilient against SIM swapping attacks. Still, it’s better than nothing if it’s your only option.
Use protected branches
Source control hosts like GitHub and GitLab allow you to designate certain branches as protected and limit the circumstances under which code can be merged to them. Combined with a CI/CD pipeline, this can enforce secure workflows like requiring approval on a pull request before code can be merged to production. It also means that even if an engineer has some level of access taken over or abused by an attacker, they still have to get through an additional layer of protection before they can modify production code.
4. When software tells you it’s insecure, believe it
Update your browser and OS
When it comes to laptops, the most important software to keep up to date are your browser and operating system. These are going to be your biggest defenses against malware, and new security issues are regularly discovered in both types of software.
Update your infrastructure
On the server, the details depend on what your production environment looks like. If you rely heavily on containers, make it a point to use secure base images and do some basic scanning for known vulnerabilities in the software you use. On the server, you should update packages with known security vulnerabilities using something like “yum update --security”. You don’t have to go overboard here and desperately avoid using any out of date software, but set up your infrastructure to regularly move things forward, and try to avoid having software installed that you don’t need.
Note: This seems like a reasonable place to mention that your servers should only support TLS 1.2 and 1.3. All prior versions of TLS and SSL are considered insecure for various reasons at this point.
5. It’s better to find security bugs before the bad guys
Get an annual penetration test
The annual penetration test is a time-honored tradition in the information security world, and for good reason. The “bad guys” will be looking for security bugs, so you should have some “good guys” looking too. This can cost a bit of money, but the benefits of stronger security and your ability to sell to larger customers (if you’re in the B2B space) is invaluable.
There are almost certainly security bugs in your application. More will be introduced over time as well. Having professionals dig deep to find them each year greatly reduces the risk of a vulnerability being found and exploited by a malicious actor.
Create a means for responsible disclosure
There are many people who enjoy finding security bugs without any promise of compensation. If they come across something that looks suspect, they’ll dig in and report it. You can encourage this activity by promising rewards for good bugs with a bug bounty program, but for most early-stage startups this isn’t a high priority.
You should have a way for people to report bugs when they find them though. This can be as simple as setting up firstname.lastname@example.org and making sure it gets routed to the right people. You might get a bit of spam, but you’d be amazed at what sorts of genuinely impressive security findings make their way into that inbox. Try to be courteous, calm, and collected with the people who submit findings.
Warning: Be wary of people reporting security bugs but demanding payment before sharing information. That’s not how these types of programs work.
6. It’s easier to see with your eyes open
Keep an eye on security alerts
Bigger companies have dedicated teams filtering the signal from the noise in all of the security data they collect from their systems.
You may not be ready to build a full-on Security Information and Event Management system (SIEM), but you don't need to fly blind. It’s very likely that the tools you’re already using have some security alerting features. They won’t always be the most sophisticated, but they can give you some visibility into malicious activity directed at your company.
Some good examples of these tools are AWS GuardDuty or Google’s Alert Center. Make it a point to regularly review new alerts coming from these services. Make use of the tools available to you, especially with critical systems like your identity provider and cloud platform.
Alerts should be actionable. For example, a good alert might be “Jennifer, your coworker, just signed into Google from an unusual country.” It should be rare, and you can go ask Jennifer if she’s in that country. A less actionable alert would be “Jennifer, your coworker, just signed in.” Without any additional filtering you’re going to be staring at logs all day and bugging your coworkers all the time. The more likely scenario is that you’ll just end up ignoring them.
Warning: Watch out for alert fatigue. Find a way to silence alerts that provide no information or value. When you see an alert, you want to have the mental bandwidth to give it a good look before assuming it’s nothing.
About the author: Rob leads Vanta's internal security program. He has spent almost 8 years in the security industry, including time as a penetration tester, an early hire on Robinhood's security team, and a Y Combinator backed founder. Rob enjoys camping with his wife and two dogs, cooking, and drinking good bourbon.
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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