Share this article

Garry Tan of YC: Why The Next Unicorns Are Built By AI | Frameworks for Growth
Accelerating security solutions for small businesses Tagore offers strategic services to small businesses. | A partnership that can scale Tagore prioritized finding a managed compliance partner with an established product, dedicated support team, and rapid release rate. | Standing out from competitors Tagore's partnership with Vanta enhances its strategic focus and deepens client value, creating differentiation in a competitive market. |
Description: In this episode of Frameworks for Growth, Vanta CEO Christina Cacioppo sits down with Garry Tan, President and CEO of Y Combinator, to explore how early-stage startups can find product-market fit in an AI age, when a startup idea is worth pursuing, and what it means to operate in “founder mode.”
Whether you're a founder, operator, or investor, this episode offers actionable startup advice and insight from one of the most influential voices in tech.
🔑 Topics covered (timestamps):
00:11 - Introduction
00:35 - What’s different about today’s tech landscape
02:15 - What does YC try to impress upon their founders
03:41 - Are there more pivots in YC
06:11 - Advice for founders building in AI
08:41 - Scaling with fewer employees
10:34 - What it means to be high agency
14:26 - Advising startups on design and taste
15:31 - Founders should work in call centers
17:24 - Vibe coding and knowledge work
18:42 - Will AI make it easier or harder to pick startups
23:01 - Are YC companies shrinking in size over time
24:29 - Running Initialized Capital vs. running YC
26:57 - Flow state at a startup vs. at big companies
27:30 - Why more billionaires is a good thing
28:23 - Frameworks and advice for startup founders
29:11 - Advantages of being a first-time founder
30:31 - Do things that don’t scale
31:51 - Knowing when you’ve found product market fit
32:38 - Garry on AI regulation
34:58 - Open source AI
36:31 - Garry on being a content creator
39:09 - What would a Garry Tan LLM get wrong
41:49 - Lightning round
43:43 - Letting people go at a startup
🔔 Subscribe for more startup strategy and founder stories: YouTube
👉 Follow us on all social media platforms: LinkedIn, X, Instagram, and TikTok
🎧 Follow Frameworks for Growth on Spotify and Apple Podcasts
Read the full transcript
Christina:
Welcome to Frameworks for Growth. I'm Christina Cacioppo, co-founder and CEO of Vanta, and I'm here today with Garry Tan, president and CEO of Y Combinator. Garry, you've started several companies. You started a venture firm called Initialized, you started a YouTube channel. You've started a movement around San Francisco politics, at least unofficially. Thank you so much for being here today.
Garry:
Thank you so much for having me.
Christina:
Kicking things off, YC's seen several cycles of booms and busts. This feels like a little boom timey, but what feels different about now than the past?
Garry:
Well, I mean, the obvious answer is AI, and the wildest thing is how much growth is happening in startup land and how much growth can happen with really super young teams that basically are starting out with nothing, and they can go from really zero to 10 million dollars a year in revenue, sometimes in the course of less than 12 months, and they can do it with less than 10 people. It's really sort of astonishing. The last three batches of YC have done this insane thing that we've never seen before. In the past, 2009 for Airbnb, the best company of a generation, they were able to grow 10% week on week. The last three batches in aggregate on average have grown their revenue 10% week on week. I think, when you went through YC, what was your demo day goal?
Christina:
Seared into my soul. It was 180k. Zero to 180K in 10 weeks.
Garry:
It was just incredible. And you nailed it.
Christina:
We did!
Garry:
Yes. Which is turns out quite predictive of what ends up happening with the business. These days, a lot of the companies are getting to half a million dollars and sometimes in rare scenarios, a million dollars a year in the course of 10 or 12 weeks, which is astonishing, has never happened before. It used to be the Vanta of the batch or the Airbnb of the batch would hit their goal and hit 10% week on week. And so AI is here, it's here to stay, and it's really wild.
Christina:
So in this age of abundance for founders, what's one thing you try to impress upon them in the 10 weeks or maybe months—call it the first six months, but the YC part and immediately afterward?
Garry:
I think if you run the retrospective on startups period, number one, by far and away, the reason why the startup doesn't work is they don't make something people want. And so either they make the wrong thing or they don't make anything at all, which is like this sort of the median startup. They just aren't that capable of building, which is just, that's sad. And even that's going away instead of having the technology get in the way or Oh, we just couldn't get the servers up or whatever it was. Now you can vibe code your way there.
Christina:
I saw that from Andrej's tweets about that.
Garry:
Yeah, exactly. And yeah, vibe coding is a thing that means a quarter of the current Y Combinator batch is vibe coding their way to ideally product market fit making something that people actually want. So the reasons for failure are going down. So in theory, what that means is the ability to be successful is no longer limited by technical ability. The only thing that's sort of the limit is can the founders get in the heads of customers and understand what they need and then create something that actually solves a problem and will they pay for it.
Christina:
And so in that, are you seeing more pivots? Do they feel like pivots? It sounds like they're happening faster. Any good pivot stories from more recent YC batches?
Garry:
The most common types of pivots are actually people going from things they feel like they should do things that sound like startups to things that they intimately know personally. One of my favorite ones recently is a company called Datacurve. They came into YC doing something wildly different. I think it was sort of a little bit undifferentiated AI workflow, and then they pivoted to AI for PM software. When they really looked down, they realized actually we haven't worked as PMs at software companies yet, so we could meet PMs, but we're not going to understand the role intimately enough to actually build software for those people. And then one of them was an intern at one of the top AI labs,
And so they turned around and took the thing that they were working on that summer, just the last summer, and created a startup that now does all kinds of data and support for training code gen models. And so they're off to the races. They basically went from zero to almost eight figures in about nine months. So I think the interesting thing about both the shape of startups and what the opportunities are changing really radically. I mean, the market for code-gen data for large language models was zero even two years ago because you didn't know that that was going to be something that people actually want to do. And so yeah, it's interesting in that the key insight is probably more important than ever. And it's usually lying in your own history or in your own backyard.
Christina:
As someone who once worked on an AI voice assistant for biologists and has never stepped foot in a biology lab, the things that sound like they make sense in fact, but aren't personally native or unique end up sounding, what does PG call them? Like sitcom startup ideas, those sort of things. Yeah,
Garry:
Yeah, totally. I think Jared calls it the hackathon startup ideas like you're at a hackathon, I need to hack something. But where the rubber hits the road is you actually go and talk to people and show them the demo. And if 10 people out of 10 people say, you know what? This isn't what I want. Maybe it's time to pivot, maybe sometimes a hundred people.
Christina:
So these startups that go from zero to eight figures and under a year, what advice do you have them for company building on this super fast treadmill on that piece too? So they have a product people want, you probably feel like they can't get it out to the market fast enough, and yet they also have this company now that they're trying to build at the same time. What advice do you have for them?
Garry:
Yeah, I think one of the things that is sort of surprising about this era of startups is I think that Blitzscaling might be dead, maybe eight, nine years ago, the type of startup that was happening, it was the Airbnbs and DoorDashs and the marketplaces of the world. And in that moment, it was so new, it was actually pretty resource-intensive. You often, you were scaling across 50 geographies at once or something.
So it actually made sense. You kind of need a 2000, 5,000, 10,000 person team for that. In those sort of scenarios, capital became a bludgeon. The more money you had, the more you could scale, you could make the graph go up like that. And so I think that there's an entire era of startups where trying to become a unicorn and trying to be blessed by this tiny group of maybe 10 or 15 different pre IPO names, late stage venture funds. They’re our friends now, but on the other hand actually that's just the popularity contest. As Buffett and Munger say, all these businesses are popularity contests, but in the long run they have to be weighing machines. Do we have gross margin? What's our retention? What's going to happen to the dynamics of these businesses? So that's probably the biggest change actually. There's a company called Salient that is growing super fast. One of our favorite companies right now, and I think they have six people, they got to eight figures in annualized revenue, super high retention, vertical AI, and seemingly on track to be a giant company. But they're going to be able to get there without having 5,000 people. They might be able to do it with 20 or 30 people. And we saw this before, I mean WhatsApp, I think WhatsApp is what, 30 some people. Instagram never grew that big.
Christina:
I think it was like 12 or 13. Yeah.
Garry:
Yeah. So I mean if you're a founder, I think it's sort of the golden age.
Christina:
I was going to say, do you see founders who like that you can do this with fewer people or do you still see founders that are like, oh, a part of how I think about my success is I go and I say, my company has 2000 people who work at it. And that's kind of a popularity contest metric.
Garry:
I think it's a little bit of a relief actually. And I think it's also, it'll change the nature of the firms themselves. The thing that I think is happening with knowledge work is that there are lots and lots of jobs that are actually awesome jobs. And then there are also a great many jobs that are rote and they're sort of repetitive. Do you know the meme and Rick and Morty?
Christina:
No.
Garry:
Where Rick's this mad genius scientist and he has a little robot on his table and the robot goes up to him and says, Rick, what is my purpose? And Rick says, you pass butter.
And the robot says, oh my God. And I think that there is the equivalent of that frankly in knowledge work that people shouldn't be in rote jobs that are not fun. That's my hope is that I think the classic example here is what Milton Friedman was in Panama looking at a bunch of people using shovels. He was like, well, why are they using shovels instead of heavy machinery? And the government person replied, well, it's sort of a jobs program. And Milton Friedman replied, well, if you wanted to be a jobs program, you should give them spoons. And so when I really look at knowledge work, I think that that's one of the most powerful mental models for how this is going to change. And what that hopefully means is basically there will be better jobs, the firms will be more profitable. That means they can actually invest into more things and solve more problems. Basically. That's how we create more abundance for everyone.
Christina:
Related in a lot of your recent talks and writing online, you've talked about high agency individuals. What does that mean? What do you Any specifics? Any examples?
Garry:
Yeah, I mean I remember working with Brian Armstrong at Coinbase and he was always had the clear intelligence. He was very, very logical, and some of it was just a matter of experience. I remember being a CEO coach right when he graduated from YC, but he was just learning how do I manage people? How do I hire engineers? How do I fire my first person? I think there's a misconception that agency is this thing that you're born with. And what we've seen at YC over and over again is that it's actually little changes day by day. And it sort of happens progressively as you actually build the company and as bad things happen, you must overcome them. So I think that high agency is something that can be learned and is learned quite frequently. And so today if you meet Brian Armstrong, you're like, this person is so formidable.
He was attacked by the SEC of all places, like a government agency. And instead of folding and saying, oh no, what do I do? I better shut down or we're going to give up crypto for all time. He said, you know what? We're going to fight it and we're going to talk to lawyers, we're going to lobby, we're going to figure out how to do this. And I think just today the SEC came back and said, you know what? We're dropping the charges against Coinbase. And so I think that those are all really powerful moments. It's like basically you go out there and the universe will smack you and then what do you do? You can take it and you can lie down or you can get up and you can be like, water. How do I move around this challenge and how do I figure this out? It requires will, but also can be learned.
Christina:
It's kind of some of my experience or kind of the bad things happen, not infrequently at Vanta, but each kind of bad, I don't mean to overstate it, but each bad thing that happens is nowhere near as bad as stuff that's happened in the past. And so in a relative sense, it's not that bad. We'll figure it out. It's fine.
From the outside it might look bad, but the inside you're like, we'll figure it out.
Garry:
Yeah, totally. And I think that that's extra important now and that people are really worried about AI. They're worried about where all the jobs going to go. And some of the things that we talk about is at dinners and a lot of us have kids and we're like, how do we actually teach our kids? And then I guess the two things that are most important when intelligence on tap is available is actually agency and taste, and then agency is just literally you can do things.
And what's funny is that maps to how the technology works agency is the prompting. The funniest thing that I've talked with lots of AI researchers, and one of the things that they mentioned is, well, it sort of seems like AI is, it's not that agentic yet. It sort of resembles a hyper-intelligent toaster. And for me, I'm like, that's great. Let's keep it that way. That would be great. This is the best possible scenario because I want as much agency in human beings as possible. And then the second part that clearly hasn't been solved yet, it's not clear to me it can be solved is taste. And then that maps to evals. If you're using a large language model, being able to do evaluations of what models and what prompts are good, does it actually work for all these scenarios? That's actually turning out to be the moat for many startups. So I don't know. I mean agency and taste are super, super important and humans are going to be a really irreplaceable piece of that, I think.
Christina:
And that taste piece, you've for a decade plus been a really outspoken and advocate of design. How do you advise startups now to think about taste?
Garry:
The great thing or the challenging thing is you can't just be a technical co-founder and just ignore all of that. Actually, what we find now, especially in the age of prompting and vibe coding, is that everyone's a PM now. You actually have to understand the product. That the most important part of design I think is actually the empathy for the user. You sort of have to be an ethnographer. You're going in and seeing what is this person like? What are their goals? What are their motivations? If you're selling enterprise software, the most important question is how do they get promoted? And so if you can actually do all of those things loaded into your head, whether it's having actually lived that life or being able to be around people all the time who live that life, only then can you design something that is appreciably 10x better than the thing that they were doing before
Christina:
To that. I know, I see. It's been at least public about advising founders or would be founders to go work in a call center, go do some of this.
Garry:
Oh yeah, go undercover.
Christina:
Exactly. Go undercover to develop that empathy. Are folks taking you up on that?
Garry:
Yeah, totally. I mean, there was a company recently, I mean this is one of the cool things about open source large language models. We had a medical billing company where one of the co-founders went and got a job as a medical biller on Zoom, and they were able to write software and write prompts and deeply understand what is it that a medical biller does.
They did it in a way that didn't violate anything because none of the data, it is sort of like they were just doing the job and instead of them using their wetware to do the job, they were writing software locally using I think the latest version of Meta’s Llama. And so I think that that was an incredible example. Obviously the best way is to deeply understand someone's problem or a space and go in and totally above board understand things. But sometimes you might not need to do that. You could go undercover and just do that job directly and then deeply understand it. From an IP perspective, you probably have to throw out the prompts at any code you write, but even doing that puts you ahead of absolutely everyone else who might be trying to do it. Can you imagine the alternative? It would be if you don't know a medical biller, you'd have to go and hang out in Starbucks or something and wait for a medical biller to show up. What would you do to understand that job as intimately as actually doing the job?
Christina:
Yep. Yeah, I think we will probably see a lot of more people come from outside of an industry outside of subject domain and then succeed, whereas that's been more rare in startup founders. Not unheard of, but just more rare in the last 10 years.
Garry:
I think that might be actually more and more common. People are a little bit worried right now for software engineering or computer science graduates especially. Then the funniest thing that I think I would do if I were in that situation is actually I'd get my computer science degree, I'd get really good with Cursor or Windsurf or Continue or any of the coding platforms that use AI, and then I might go get a knowledge work job and just intimately understand what is that job, how do I get promoted, what does my boss care about? What does that business care about? And then if you combine your intense ability to vibe code with your intense understanding of this thing.
Christina:
Tractor sales in Iowa.
Garry:
Yeah, exactly right. My favorite story is Ryan Peterson, our friend, he and his brother were actually some of the biggest importers of medical hot tubs
Christina:
Oh right.
Garry:
From China.
Christina:
I remember hearing that. It's such a good story
Garry:
That and apparently E-bikes even before E-bikes were big,
Christina:
But like 2013 when we needed more E-bikes.
Garry:
Yeah. And then that's through that they learned about bills of lading and global logistics. And so of course now Flexport exists.
Christina:
Do you think AI will make it easier or harder for YC to pick startups and pick founders?
Garry:
Oh, I mean some of it is, I hope it makes it easier, but ask me again in 10 years. So the outcomes take so long to figure out what's going on, but I'm super bullish on the technology and if anything, I think that that's a part of what has been true about Y Combinator for we're coming on 20 years. I remember Paul would always say before YC, you could basically get a job or go to grad school. And what he always wanted YC to be was something where you had a chance to instead go and start a startup. And then inherent to that is actually a very optimistic view, I think. That there aren't limitations on the number of startups that could exist. And I think all of that stuff is a good thing. Earlier we were saying instead of the 5,000 person startup, you're going to have the 10 or 20 person startup, and then the sort of dystopian version of that is believing, well, that means that where are all the other jobs or what are these other people going to do? There's an alternative view, which is sort of Coase’s theorem for the optimal size of a firm. And so what might happen, which I deeply hope is that, and I think you're already seeing it even within the Y Combinator community, the YC startups end up using each other's software, and they end up being best of breed software. Vanta is a great example of that, right? You just obviated the need for every YC company to have a compliance department. Which is awesome. So instead of having these giant companies and sort of full of butter passing jobs and then not enough companies actually addressing all the different needs that all the different types of companies might have, you could actually have thousands of flowers bloom. You should have thousands of companies making a billion dollars a year in annualized revenue or more.
And so this is actually a radically different view of how tech could come out into the world than what we have today. We have seven companies worth a trillion dollars, and we have many friends not to take away what they do. They're incredible operations. They're pushing forward the state of the global economy. I mean, all of our parents' retirement savings are probably all saved up in that. But at the same time, you could argue that some of these big companies are basically daycares for high IQ people. Are they really solving the problems or are they coming in and are writing a spec for a check mark in the settings pane of a thing that everyone uses, but it's just,
Christina:
And it will ship in maybe 24 months.
Garry:
Exactly. And it's like, are we slowing down the rate of innovation? Probably. I mean, if you have tens of thousands or hundreds of thousands of people who are in cushy daycares where they're not actually creating products or services that solve people's problems, that means that there are thousands, maybe tens of thousands of products and services that could exist that would solve problems faster. And certainly the world is full of problems. It's actually a very subtle kind of academic argument. The optimal size of a firm should come down, but what that results in is hopefully much more connection between labor and the actual fruits of that labor. And that's what I want.
Christina:
Higher marginal product of labor.
Garry:
Actually, we don't want people to have fake laptop jobs. We want people to have real jobs that actually someone on the other end is that saved my life or that allowed me to spend more time with my kids or these sort of real things in our economy and in our lives. And then the final point would be, I think if we do that, we're not going to have, maybe we still have the seven trillion companies, but we also have alternatives. Everyone's worried about Big tech has so much say over our lives, and that would be my pitch to you for Little Tech. We should have lots and lots of Little Tech, and it's the equivalent of small business, but with the scale of AI and software.
Christina:
It'd be interesting to look at of the companies, 2, 5, 10 years out of YC in different batches, are they getting smaller over time?
Garry:
Oh yeah.
Christina:
It seems like it'll almost certainly or looks like it'll be true now. I don't don’t know as true five years ago, but the 2020 batch versus the 2010 batch,
Garry:
Yeah, the batch sizes have definitely come down,
Christina:
But oh, I just mean how many people those companies employ on average. Are the firm sizes shrinking over time?
Garry:
We should track this. I mean, I would say almost certainly right now, I mean going back to the example of people just graduating the company that gets to $12 million ARR, I think what you would do 8 or 10 years ago is raise your splashy series A and then six months later raise your splashy series B and then hire your customer success, customer support. You hire your executive base, and then I think what we're starting to see is instead of doing that, you're hiring more cracked vibe coders, and then instead of hiring an entire team of a thousand people just to do that one function, you're trying to actually use the intelligence on tap, basically deliver a lot more with a lot fewer people.
Christina:
And the intelligence is doing a bunch of the old work. There's still people doing the edge cases
Garry:
Exactly.
Christina:
So you started Initialized and ran it and then decided to come back to YC. What's something you can do at YC that you couldn't do at Initialized?
Garry:
Oh, I mean, I'm super thankful for Initialized and the team I got to build there and they're doing awesome. What I realized is Initialized and a lot of our friends in venture when I was Initialized, we were the beneficiaries of Y Combinator’s tree of prosperity. And so when Paul and Jessica came and asked me to come back, I realized, oh, I'm needed at the tree of prosperity. And I deeply believe that what we're doing here, what we hope is to make these thousands of startups that maybe wouldn't have existed without YC. We want them to exist and we want them to both create jobs and solve problems. And so we want way fewer people to just blindly join a big tech company and play volleyball all day and work on a checkbox in the settings pane. We want them to go and create companies that actually are of great value.
And the wild thing is it's more possible now than ever and that's great. Maybe this is, I don't know, shoot, is this too controversial? You can decide whether you want to keep it. There's sort of this very deep invective against tech and tech billionaires and I even get attacked for it in San Francisco. People accuse me of being a billionaire. I am not. I've gone on record that I'm not yet a billionaire. I'm not a billionaire. If anything, I feel like our job at Y Combinator is to help people become billionaires certainly, and that we should make that much more accessible. I think what's more valuable even than that is actually to create companies that are actually of great value and that actually create really great jobs. And I think in aggregate, instead of thinking, oh no, there's not going to be 5,000 jobs. We should have thousands of these companies all employing 30, 50, a hundred people, and each job is actually really awesome. You're sitting there and operating at the limits of what you're capable of. And to me, that's the flow state actually. And I think that if you poll a hundred founders and people who work at startups and a hundred people who work in big companies period, the people who say they're in flow state, I mean, what do you think that percentage is at a big company versus at a startup?
Christina:
So much higher at the startup. Uncomfortably higher.
Garry:
Right. Is it like 1% versus maybe 50 or 80% for really great places? And so in my head, that's the world that we want to actually build and I think Y Combinator is uniquely the place where that could happen.
Christina:
Building off of that so controversial to some maybe not outside this neighborhood that more billionaires, more really successful companies is a net positive. Why is it something you believe in so strongly?
Garry:
I guess we see it. We have dozens of friends and hundreds of people in our community have actually gone from this state of having never started a company before, sometimes never having managed a person before, to now employing hundreds of people having thousands, tens of thousands of customers who come back and rely on your service every single day. There's nothing more gratifying than seeing something go from zero to one and one to billions. And so at some level we are witness to that and then I recognize it's like that's not a normal thing. People hear this story and they're like, doesn't seem real. How is that possible?
Christina:
If you think of the advice you've given startup founders over the years, maybe skewed more recently, but is there some framework or tool that you keep coming back to, keeps being important?
Garry:
I just think about the t-shirt that we give people on the first day of YC. It just make something people want and then embedded in that it's a mantra, honestly, it's a holy phrase and almost any problem can be solved by that set of things because maybe you're not making something, maybe it's not something people want. Maybe you're not doing it fast enough. I mean, maybe they just make something what people want now.
Christina:
Such a good phrase.
Garry:
You sort of really need that. Almost all the problems that people run into are related to that. Ultimately,
Christina:
You work with first time founders, second time founders, sometimes third time founders. What's something that second or third time founders actually don't get that first timers do more easily?
Garry:
I think the main thing is just the schlep blindness. The amazing thing about first time founders is they just have no biases, and actually that's sometimes very necessary. A good example might be this idea of vibe coding. If you've been coding for 20 years at this point and you hear about this, the initial reaction is this couldn't possibly be real until you try it and then you're like, wow, this is actually wild. The best thing that second and third timers can do is use their network, use their ability to gather capital and all the people they could possibly hire, but then when it comes to actually running the business, they have to do a beginner's mind again.
Christina:
To make something people want.
Garry:
And that's very, very hard.
Christina:
And so that's the advantage the first time people have?
Garry:
The beginner's mind is, well, you just start off with totally no biases.
Christina:
And then the second time it's the network, the access to capital.
Garry:
Yeah, and you have to pick a schlep to be blind to, I guess.
Christina:
And then you know what the hard parts could be
Garry:
But then you're going to do it anyway.
Christina:
Yep, that makes sense. The other mantra that YC is really known for is the do things that don't scale. Airbnb, great example to grow that 10% going to New York, taking really nice photos of people's homes, so then they get booked more. Any other really fantastic but less known do things that don't scale examples?
Garry:
I think it just happens sort of day to day in the batch. Actually, what's a good example? I mean, basically whenever you find yourself saying, in order to do X, in order to ship, I need to do it with these check boxes, do things that don't scale, basically says, you know what? There's an external dependency. You're waiting on getting it to be perfect. You're waiting on some process to be able to support scale, but that is a one to a billion phenomenon. And then going from zero to one is actually about just getting to one. If you need to build a lot of software or hire all these people or hire a mechanical Turk or do any of these things, just do it later. That first time you do it, you can do it or your team can do it, or you can figure out a way to do it in a totally unscalable way, and then it unlocks you from the 10,000 reasons why you can't do X, Y, or Z.
Christina:
How do you know when you've hit one and then zero to one?
Garry:
I guess when the product is probably getting pulled out of you? I mean when your servers are on fire, you know this feeling.
Christina:
Yeah, it's funny. It is pulled out of you, but I don't know how to explain it in some ways more than that.
Garry:
Yeah, I mean what I've heard, I mean many YC and non-YC founders, I think founders period who have experienced, I think they describe it as you're sitting with a customer and they give you 10 pages of notes on the things that they want and it's like, oh yeah, that's not being nice. Being nice is like, oh yeah, it looks useful, I'm going to send it to my friend. Exactly. And then product market fit looks like, oh yeah, this is awesome, but it would be even more awesome if you did X, Y, and Z.
Christina:
Yep. Going back to AI, if you were king of all AI regulations around the world, what would they look like?
Garry:
Oh, that's a good question. I was in DC I met French Hill who's a congressman, who's really quite a leader on crypto regulation and FinTech. What I suspect will end up happening, going back to our discussion about agency, the nightmare scenario, I think all of us share at some level is we don't want to be all below some sort of API line. If you just take all of knowledge work and you turn it into driving for Uber, I think everyone might be pretty worried that that would happen. And then what they do in FinTech and financial regulation is that, for instance, for approvals, they require human in the loop. And so I would suspect, and this is a wild guess, but in 3, 5, 10 years, what you're going to find is that the intelligence gets smarter and smarter and then there will be ultimately all the things that you can do today are still governed by laws that apply to corporations and people. And then the subtlety here is that there might be a moment where someone wants to put an AI in as CEO and what might that even look like? And in that crazy future, it wouldn't surprise me if the government or some entity came in and said, and this might be very different in different places, China versus a US versus Europe are going to all approach these things in very different ways. But it would not surprise me if a human in the loop type regulation that is already established in financial technology regulation comes over to technology broadly. And I think that that might be a good thing. We want human beings to be hand on the wheel and held to account, and as long as that can happen, what you don't want is this scenario where it's like, oh yeah, Wintermute, the AI did that, and how you make that accountable. You can't make sort of an infinitely smart toaster accountable. Ultimately the buck has to stop somewhere and it probably has to stop with people with their hand on the wheel.
Christina:
There's also a lot of talk around open source AI and is it safer or is it more dangerous? YC backs a lot of open source AI. Do you have strong thoughts here?
Garry:
Yeah, I mean I think maybe a year or two years ago we were a little bit worried that only one or two players would end up with this frontier AI and somehow there'd be takeoff and you'd be in some sort of Windows monopoly scenario.
Christina:
That the latest mission Impossible movie, if you saw that.
Garry:
Yeah, exactly. Right. And what I'm really excited about as of today, it feels like there may be eight or nine players, all of whom are competing in a fair way that is actually awesome. I mean, that gives all of our startups a lot of choice. And so I'm pretty white pilled at the moment, and a lot of that you can really directly trace to open source. If you are stuck with lock-in on certain platforms through closed APIs and closed source, then you know what? You can charge monopoly rents. You can do whatever you want. You can self preference, you can do all these things and power will just accrue to the next great big tech company. That will be, great, a new company worth a trillion dollars. And while that's not a bad thing, inherently, I think a much better version of that would be a lot more choice with a lot more companies, with a lot more prosperity spread out and smaller firm size.
Christina:
You built a popular YouTube channel. What's something non-obvious where people wouldn't expect that you've learned about being a creator?
Garry:
I guess I remember meeting Casey Neistat, who's sort of like one of the original creators. What made me think maybe I should do this is I had watched a lot of his videos, but seeing my interns interact with him was a very interesting thing because it felt like he walked in and they just started talking to him like he was an old friend and then he just reciprocated. So that was probably the most interesting thing that I think you should be prepared for.
Christina:
Do people come up to you now and feel like they know you?
Garry:
Yeah. And then at YC, my stated goal is we actually have 13 partners, and rather than one person being sort of the figurehead person, I actually want all 13 people to be like Paul Graham. Then it's starting to happen to a bunch of them now. People stop Diana who in the street, and she has her, Diana stans in the comments, which is awesome. That's great. And then I think on the one hand, I think there's a general critique about parasocial relationships and is that good or not? But at this point, I think it's actually probably good. I think if you can influence people, if you're helping them, if you are telling very authentic real stories about yourself, that's powerful. And I think it's in deep demand. The classic thing for VC content was always, I'm killing it. We're killing it. And then you look at those channels and it's like, oh yeah, 50 views, a hundred views. And then when I started doing YouTube, my most viral things were actually about my most horrible mistakes. My first viral video was called My $200 Million Mistake, which was when I turned down co-founding Palantir.
Christina:
It's even more expensive today.
Garry:
It's my 2.6 billion mistake.
Christina:
There we go.
Garry:
Yep. Yeah, I need to do inflation spin v2.
Christina:
There's been inflation, but not that much.
Garry:
That's right. Yeah. So yeah, being vulnerable, being real, and I mean that's probably the most important thing. Be a creator to uniquely tell your story and the story of people you find interesting and don't do it for any other reason. And I think anyone who does that will have an audience and do really well.
Christina:
And you've built one that way
Garry:
Trying to.
Christina:
So actually, if we took all that Garry Tan content that makes people feel like they really know you and fed it to an LLM, what would the LLM not know about you?
Garry:
I think the hardest part about success ultimately is learning to say no, and basically the Harvard longitudinal study of happiness. I think in the moment when you feel like you're in a powerful position and notoriety and power and all of these things, sometimes I have to remind myself of that study because it seems pretty clear that even after the YouTube channel is over, or even after all the investments are done and dusted and you return the money to your LPs or even after whatever.
Christina:
The hall of fame of people who return money to LPs, right?
Garry:
It's like you're still a human being, you still have your family, you still have your friends. And I think I had read about this, right? When you're younger, you're like, oh yeah, people lose their minds from money, power, and fame all the time, and I am not going to let that happen to me. And then it's just interesting to see, it's actually so hard to remind yourself of that and then also do the right things. You actually, you get this email out of the blue and it's like, well, do I go to my nine year old's baseball practice or do I take this meeting and it's this really big meeting? What do you do? And actually you have to carve out parts of your life.
Christina:
For the baseball practices, even though it seems like there's infinity of them, there's not.
Garry:
Yeah. So I don't know. I think I'm most surprised by that. And it's something that me and my friends who are parents, everyone has really crazy careers and it's just so hard. I know I didn't really expect that.
Christina:
The version of that, or there's people around me who deeply care about Vanta’s success, but also they don't, and it's not an at all malicious way, just that's not how they think about me at all, or they want it to be successful because I want it to be successful.
Garry:
Totally. When you're presented in the moment, you want it to have it all. And actually you just have to choose, and you're what nobody says is that actually it will hurt you on one side, but the other part is priceless. So the decision should just be made and you should live with it. There's not really another way.
Christina:
I have four rapid fire questions for you.
Garry:
Oh yeah, let's do it.
Christina:
Okay. What are you reading right now?
Garry:
Oh gosh. I'm spending a lot of time with OpenAI deep research lately.
Christina:
Any good prompting tips for that? You don't just get content marketing.
Garry:
The funniest thing is sometimes I go into o3 mini-high. I tell it who I am and why I care about a thing, and then I ask the question and then I ask it to prompt deep research, and then it actually does work very well.
Christina:
Oh, really? Okay. I'll try that.
Garry:
It's like having an assistant for your assistant.
Christina:
Exactly. Great at getting coffee tasks. If you could take a first time founder on a one day tour of the Bay Area, where would you go?
Garry:
Oh man. Let's see. My favorite place to eat is probably Swan Oyster Depot. Yeah, that's probably my jam. I think a shrimp and crab louie salad there is the best thing to eat in the world.
Christina:
Hardest you have laughed during a YC batch?
Garry:
I remember my first stint of YC, Kevin Hale was always the trooper, and someone came in with a sleep device that would measure how your sleep went, which is a super reasonable idea. But it was a really crazy prototype because the next morning we came in and Kevin had a red mark on his forehead that he had to have all day. I think it took a week to go away because it was a hardware prototype and they hadn't tested it, and it was too hot, and it actually left this sort of light burn mark on his forehead. So anyway, we've become much more careful about trying other people's hardware contraptions since
Christina:
They say YC partner isn't an arduous job. Yeah.
Garry:
Talk about putting your body on the line.
Christina:
Exactly. Something that seemed like a really big deal to you at the time, and in retrospect, it was fine.
Garry:
I always remember because we have to coach people through their first time letting someone go all the time. I always think about that. It's like the thing that's probably most surprising about organizations period is that nobody likes to do it. It's so unpleasant. If you like doing it, you're probably a sociopath, and all of that is true. And then simultaneously, people hate doing it so much that I think entire organizations become sclerotic and a mess and have bad culture actually, because they just don't let go people who obviously they should. It's just surprising, and I think it's everywhere. And so we're always just coaching people. It's going to be okay and tomorrow will be fine. And actually the thing that I think is most surprising to people is we will walk them through it and then we'll tell them, after you do it, you will feel so relieved. And then afterwards, of course, every time they're like, you were right. I didn't expect that. I thought it was going to be terrible after. And instead it got so much better. And yet it just happens all the time and we all do it.
Christina:
Yeah. I was going to say, what sort of coaching works? It sounds like you're talking someone through, here's what you're going to feel along the way, but what works for a founder?
Garry:
I think the biggest thing is just being resolute, right? It's such an unpleasant thing to do that halfway. It's like, oh, maybe we should let them stay. Oh, maybe we'll change your role. And it's like, my advice is just write it down. If you have to read from it, you're better off just being resolute. This decision has been made. And then immediately try to figure out how can we be helpful? What's the next thing for you? Helping people focus on the future and genuinely caring about what happens to them after is the basic thing to do once you do that? Actually, honestly, I think it's setting people free in some way. Yeah, I mean, I think everyone's seen this before. It's like, oh, this was so not working, and now they can actually go and find the thing that allows them to enter the state of flow, and that's what I think everyone deserves.
Christina:
Yeah. Yeah. It very much resonates. I think for me, it feels the worst right before you do it, not right after, which isn’t intuitive and however bad I feel, the other person probably feels worse, and that is the thing to focus on, not how I feel.
Garry:
That's very true.
Christina:
It doesn't matter how I feel. I'll be fine. We'll both be fine.
Garry:
Not only is it something that people really try to avoid, but it's also really important for people to learn how to say goodbye in a way that respects the people who are moving on. Because ultimately, especially for startups that are starting out, you really want to become a place where it is a great place to be from.
You want other people to say, oh, they came from that company. They must be really great. And the only way that can happen is from having and learning to have good and gracious goodbyes.
Christina:
That's a really good way to put it. Thank you so much. That was the end of my questions, but I so appreciate the time you spent with us today.
Garry:
Thanks so much for having me. It's such an honor to be one of the first guests.




Determine if you need to comply with GDPR
Not all organizations are legally required to comply with the GDPR, so it’s important to know how this law applies to your organization. Consider the following:
Do you sell goods or services 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?
Document the personal data you process
Because GDPR hinges on the data you collect from consumers and what your business does with that data, you’ll need to get a complete picture of the personal data you’re collecting, processing, or otherwise interacting with. Follow these items to scope out your data practices:
Identify and document every system (i.e. database, application, or vendor) that 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, including:
Determine whether your documentation meets the GDPR requirements for Records of Processing Activities, that include information on:
Determine whether your documentation includes the following information about processing activities carried out by vendors on your behalf:
Determine your legal grounds for processing data
GDPR establishes conditions that must be met before you can legally collect or process personal data. Make sure your organization is meeting the conditions listed below:
For each category of data and system/application, determine the lawful basis for processing based on one of the following conditions:
Review and update current customer and vendor contracts
For your organization to be fully GDPR compliant, the vendors you use must also maintain the privacy rights of your users’ and those rights should be reflected in your contracts with customers:
Review all customer and in-scope vendor contracts to determine that they have appropriate contract language (i.e. Data Protection Addendums with Standard Contractual Clauses).
Determine if you need a Data Protection Impact Assessment
A Data Protection Impact Assessment (DPIA) is an assessment to determine what risks may arise from your data processing and steps to take to minimize them. Not all organizations need a DPIA, the following items will help you determine if you do:
Identify if your data processing is likely to create high risk to the rights and freedoms of natural persons. Considering if your processing involves any of the following:
Clearly communicate privacy and marketing consent practices
A fundamental element of GDPR compliance is informing consumers of their data privacy rights and requesting consent to collect or process their data. Ensure your website features the following:
A public-facing privacy policy which covers the use of all your products, services, and websites.
Notice to the data subject that include the essential details listed in GDPR Article 13.
Have a clear process for persons to change or withdraw consent.
Update internal privacy policies
Ensure that you have privacy policies that are up to the standards of GDPR:
Update internal privacy notices for EU employees.
Have an employee privacy policy that governs the collection and use of EU and UK employee data.
Determine if you need a data protection officer (DPO) based on one of the following conditions:
Review compliance measures for external data transfers
Under GDPR, you’re responsible for protecting the data that you collect and if that data is transferred. Make your transfer process compliant by following these steps:
If you transfer, store, or process data outside the EU or UK, identify your legal basis for the data transfer. This is most likely covered by the standard contractual clauses.
Perform and document a transfer impact assessment (TIA).
Confirm you comply with additional data subject rights
Ensure you’re complying with the following data subject rights by considering the following questions:
Do you have a process for timely responding to requests for information, modifications, or deletion of PII?
Can you 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 an EU-based representative
Depending on how and where your organization is based, you may need a representative for your organization within the European Union. Take these steps to determine if this is necessary:
Determine whether an EU representative is needed. You may not need an EU-rep if the following conditions apply to your organization:
If the above conditions do not apply to you, appoint an EU-based representative.
Identify a lead data protection authority (DPA) if needed
GDPR compliance is supervised by the government of whatever EU member-state you’re operating in. If you’re operating in multiple member-states, you may need to determine who your lead data protection authority is:
Determine if you operate in more than one EU state.
If so, designate the supervisory authority of the main establishment to act as your DPA.
Implement employee training
Every employee in your organization provides a window for hackers to gain access to your systems and data. This is why it's important to train your employees on how to prevent security breaches and maintain data privacy:
Provide appropriate security awareness and privacy training to your staff.
Integrate data breach response requirements
GDPR requires you to create a plan for notifying users and minimizing the impact of a data breach. Examine your data breach response plan, by doing the following:
Create and implement an incident response plan which includes procedures for reporting a breach to EU and UK data subjects as well as appropriate data authorities.
Establish breach reporting policies that comply with all prescribed timelines and include all recipients (i.e. authorities, controllers, and data subjects).
Implement appropriate security 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 measures ensure that, by default, only personal data that are necessary for each specific purpose of the processing are processed?
Streamline GDPR compliance with automation
GDPR compliance is an ongoing project that requires consistent upkeep with your system, vendors, and other factors that could break your compliance. Automation can help you stay on top of your ongoing GDPR compliance. The following items can help you streamline and organize your continuous compliance:
Explore tools for automating security and compliance.
Transform manual data collection and observation processes via continuous monitoring.
Download this checklist for easy reference
GDPR compliance FAQs
In this section, we’ve answered some of the most common questions about GDPR compliance:
What are the seven GDPR requirements?
The requirements for GDPR compliance are based on a set of seven key principles:
- Lawfulness, fairness, and transparency
- Purpose limitation
- Data minimization
- Accuracy
- Storage limitations
- Integrity and confidentiality
- Accountability
These are the seven requirements you must uphold to be GDPR compliant.
Is GDPR compliance required in the US?
GDPR compliance is mandatory for some US companies. GDPR compliance is not based on where your organization is located but whose data you collect, store, or process. Regardless of where your organization is based, you must comply with GDPR if you are collecting or processing data from EU residents.
What are the four key components of GDPR?
The four components of GDPR include:
- Data protection principles
- Rights of data subjects
- Legal bases for data processing
- Responsibilities and obligations of data controllers and processors
Safeguard your business with GDPR compliance
If your organization collects data from EU residents, GDPR compliance is mandatory for you. It’s important to follow the steps listed above to protect your business from heavy fines and to respect the data privacy rights of consumers.
Vanta provides compliance automation tools and continuous monitoring capabilities that can help you get and stay GDPR compliant. Learn more about getting GDPR compliance with Vanta.
Pre-work for your SOC 2 compliance
Choose the right type of SOC 2 report:
A SOC 2 Type 1 report assesses how your organization aligns with the security controls and policies outlined in SOC 2
A SOC 2 Type 2 report has all the components of a Type 1 report with the addition of testing your controls over a period of time
The correct report will depend on the requirements or requests of the client or partner that has requested a SOC 2 report
from you
Determine the framework for your SOC 2 report. Of the five Trust Service Criteria in SOC 2, every organization needs to comply with the first criteria (security), but you only need to assess and document the other criteria that apply. Determining your framework involves deciding which Trust Service Criteria and controls are applicable to your business using our Trust Service Criteria Guide.
Estimate the resources you expect to need. This will vary depending on how closely you already align with SOC 2 security controls, but it can include several costs such as:
Compliance software
Engineers and potentially consultants
Security tools, such as access control systems
Administrative resources to draft security policies
Auditing for your compliance certification
Obtain buy in from your organization leadership to provide the resources your SOC 2 compliance will need.
Work toward SOC 2 compliance
Begin with an initial assessment of your system using compliance automation software to determine which necessary controls and practices you have already implemented and which you still need to put in place.
Review your Vanta report to determine any controls and protocols within the “Security” Trust Service Criteria that you do not yet meet and implement these one by one. These are multi-tiered controls across several categories of security, including:
CC1: Control Environment
CC2: Communication and Information
CC3: Risk Assessment
CC4: Monitoring Activities
CC5: Control Activities
CC6: Logical and Physical Access Controls
CC7: System Operations
CC8: Change Management
CC9: Risk Mitigation
Using Vanta’s initial assessment report as a to-do list, address each of the applicable controls in the other Trust Services Criteria that you identified in your initial framework, but that you have not yet implemented.
Using Vanta’s initial assessment report, draft security policies and protocols that adhere to the standards outlined in SOC 2.
Vanta’s tool includes thorough and user-friendly templates to make this simpler and save time for your team.
Run Vanta’s automated compliance software again to determine if you have met all the necessary criteria and controls for your SOC 2 report and to document your compliance with these controls.
Complete a SOC 2 report audit
Select and hire an auditor affiliated with the American Institute of Certified Public Accountants (AICPA), the organization that developed and supports SOC 2.
Complete a readiness assessment with this auditor to determine if you have met the minimum standards to undergo a full audit.
If your readiness assessment indicates that there are SOC 2 controls you need to address before your audit, complete these requirements. However, if you have automated compliance software to guide your preparations and your SOC 2 compliance, this is unlikely.
Undergo a full audit with your SOC 2 report auditor. This may involve weeks or longer of working with your auditor to provide the documentation they need. Vanta simplifies your audit, however, by compiling your compliance evidence and documentation into one platform your auditor can access directly.
When you pass your audit, the auditor will present you with your SOC 2 report to document and verify your compliance.
Maintain your SOC 2 compliance annually
Establish a system or protocol to regularly monitor your SOC 2 compliance and identify any breaches of your compliance, as this can happen with system updates and changes.
Promptly address any gaps in your compliance that arise, rather than waiting until your next audit.
Undergo a SOC 2 re-certification audit each year with your chosen SOC 2 auditor to renew your certification.
Download this checklist for easy reference
Prioritizing Your Security and Opening Doors with SOC 2 Compliance
Information security is a vital priority for any business today from an ethical standpoint and from a business standpoint. Not only could a data breach jeopardize your revenue but many of your future clients and partners may require a SOC 2 report before they consider your organization. Achieving and maintaining your SOC 2 compliance can open countless doors, and you can simplify the process with the help of the checklist above and Vanta s compliance automation software. Request a demo today to learn more about how we can help you protect and grow your organization.
Pre-work for your ISO 42001 compliance
Understand ISO 42001 requirements
Decide on what is the scope of the AIMS
Familiarize yourself with key AI concepts, principles, and lifecycle based on ISO frameworks
Determine if you are a provider, developer, or user of AI systems
Perform initial gap analysis
Using Vanta, asses your in-scope ISO 42001 controls
Identify areas of requirement, development, or adjustment
Secure top management support
Present a business case highlighting the benefits of ISO 42001 certification
Define roles and responsibilities for top management in AIMS implementation
Involve various department heads in the analysis to ensure comprehensive coverage
Work for your ISO 42001 compliance
Appoint a Project Manager
Designate an owner for the ISO 42001 implementation project
Develop a project plan
Outline steps, timelines, and resources needed for AIMS implementation
Integrate the AIMS implementation project within existing organizational processes
Establish the AIMS framework
Define the scope and objectives of the AIMS within the organization
Develop and document AI policies and risk management processes
Based on gap analysis, implement necessary controls for AIMS
Ensure integration of AIMS with other management systems and requirements
Create an AIMS statement of applicability (SOA)
Promote competence and awareness
Conduct training for stakeholders on AI concepts and ISO 42001 requirements
Raise awareness about the importance and benefits of AIMS
Implement AIMS controls
Create an AI policy
Define the process for reporting concerns about AI systems
Identify, document, and manage resources for AI systems
Ensure tooling and computing resources for AI systems are adequately documented
Conduct an AI system impact assessment exercise
Ensure that objectives are documented for the design and development of AI systems
Create a process for responsible design and development of AI systems
Ensure that AI system deployment, operation, and monitoring are documented and executed according to your AIMS
Define and implement data management processes for AI systems
Assess and document the quality of data for AI systems
Ensure that system documentation and information for users is provided and accessible
Document and follow the processes for the responsible use of AI systems
Clearly allocate and document responsibilities with third parties
Conduct internal audits
Regularly assess compliance with ISO 42001 and the effectiveness of AIMS
Management review
Review AIMS performance and compliance with top management
Address any non conformities and areas for improvement
Prepare for your external audit
Work with A-LIGN as your ISO 42001 certification body
Engage A-LIGN, a leading ISO certification body, to conduct your audit
Prepare documentation
Ensure all AIMS documentation is up to date and accessible
Pre-audit meeting
Prepare a list of questions and clarifications regarding the audit process
Initial sales process
Discuss the scope of the audit in detail to ensure full preparedness
Conduct a pre-certification audit (optional)
Consider a pre-certification audit to identify any remaining gaps
The ISO 42001 audit
Engage in the certification audit
Collaborate with A-LIGN auditors, providing necessary information and access
Designate a team member as the point of contact for auditors to streamline communication
Organize walkthroughs to discuss your AIMS processes and procedures, including facilities (if applicable)
Address audit findings
Plan for immediate, short-term, and long-term corrective actions based on the audit report
Celebrate the audit success with your team and publicly promote your certification
Continuous improvement
Establish a continuous improvement team to oversee progress post-certification
Continuously improve the AIMS, leveraging lessons learned and feedback
Integrate ISO 42001 compliance metrics into regular management reviews
Keys to success
Leverage Vanta s readiness capabilities and A-LIGN s expertise for an efficient and high-quality audit experience from
readiness to report
Incorporate AIMS within the business strategy and daily operations
Apply continuous improvement to enhance AIMS over time
Avoid integrating new technologies during the initial AIMS implementation
Engage interested parties and maintain their support throughout
Highlight the completion of the audit to demonstrate trust with customers, partners, and other key stakeholders
Download this checklist for easy reference
Demonstrating secure AI practices with ISO 42001
The rapid adoption of AI has driven innovation and opportunities for growth — and with it, new risks for the companies that manage the data that power these technologies. These companies have not had a way to demonstrate trust to their customers and show that they are deploying AI securely and safely. Achieving ISO 42001 compliance helps to demonstrate this trust through a third-party verifiable way and opens the doors to time-savings, more deals, and expedited sales processes. The above checklist simplifies the process of becoming ISO 42001 compliant by leveraging the power of Vanta's continuous compliance software. Request a demo today to learn more about how Vanta can help you streamline the path to ISO 42001.
Develop a roadmap for your ISMS implementation and ISO 27001 certification
Implement Plan, Do, Check, Act (PDCA) process to recognize challenges and identify gaps for remediation
Consider the costs of ISO 27001 certification relative to your organization’s size and number of employees.
Use project planning tools like project management software, Gantt charts, or Kanban boards.
Define the scope of work from planning to completion.
Determine the scope of your organization’s ISMS
Decide which business areas are covered by your ISMS and which ones are out of scope
Consider additional security controls for processes that are required to pass ISMS-protected information across the trust boundary.
Communicate the scope of your ISMS to stakeholders.
Establish an ISMS team and assign roles
Select engineers and technical staff with experience in information security to construct and implement the security controls needed for ISO 27001.
Build a governance team with management oversight.
Incorporate key members of top management (senior leadership and executive management) and assign responsibility for strategy and resource allocation.
If you have a large team, consider assigning a dedicated project manager to track progress and expedite implementation.
Align the team on the following:
The planning steps you’ve already taken
The scope of the ISMS
Which team members are responsible for which aspects of the project
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
Meet with your team to discuss this inventory and ensure that everyone is aligned.
Perform 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 that you identified during your risk assessment.
Summarize each identified risk
Indicate the impact and likelihood of each risk.
Rank risk scenarios based on overall risk to the organization’s objectives.
Document a risk treatment plan
Design a response for each risk, known as a risk treatment.
Assign an owner to each identified risk and each risk mitigation activity.
Establish target timelines for completion of risk treatment activities.
Implement your risk mitigation treatment plan and track the progress of each task.
Complete the Statement of Applicability
Review the 93 controls listed in Annex A.
Select the controls that are relevant to the risks you identified in your risk assessment.
Complete the Statement of Applicability listing all Annex A controls, justifying inclusion or exclusion of each control in your ISMS implementation.
Implement ISMS policies, controls and continuously assess risk
Assign owners to each of the security controls to be implemented.
Figure out a way to track the progress and goals for each control.
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
- All of the Annex A controls that you have selected
Establish employee training and awareness programs
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.
Make security training part of the onboarding process for new employees.
Conduct regular training to ensure awareness of new policies and procedures.
Conduct regular management reviews
Plan reviews at least once per year. Consider a quarterly review cycle if your organization is large or if your infrastructure is changing frequently.
Ensure the ISMS and its objectives continue to be effective.
Verify that senior management stays informed.
Ensure risks or deficiencies can be promptly addressed.
Assemble ISO 27001 required documents
Review the ISO 27001 Required Documents and Records list.
Customize policy templates with organization-specific policies, process, and language.
Perform an ISO 27001 internal audit.
Examine each of the requirements from Annex A that you deemed applicable in your ISMS' Statement of Applicability and verify that you have each in place.
Assign in-house employees to conduct the internal audit, specifically employees who were not involved in the ISMS development and maintenance or hire an independent third party.
Share internal audit results, including nonconformities, with the ISMS team and senior management.
Address any issues your internal audit identified before proceeding with the external audit.
Verify compliance with the requirements from Annex A deemed applicable in your ISMS' Statement of Applicability.
Undergo external audit of ISMS to obtain ISO 27001 certification.
Select an independent ISO 27001 auditor.
Complete the Stage 1 Audit consisting of an extensive documentation review; obtain the auditor’s feedback regarding your readiness to move to the Stage 2 Audit.
Complete the 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 addressed.
Ensure your organization is following the processes that it has specified and documented.
Ensure your organization 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.
Plan for subsequent ISO 27001 audits and surveillance audits.
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
Prioritizing your security and opening doors with ISO 27001 compliance
Information security is a vital priority for any business today from an ethical standpoint and from a business standpoint. Not only could a data breach jeopardize your revenue, but many of your future clients and partners may require an ISO 27001 report before they consider your organization. Achieving and maintaining your ISO 27001 compliance can open countless doors, and you can simplify the process with the help of the checklist above and Vanta’s compliance automation software.
Request a demo today to learn more about how we can help you protect and grow your organization.
Develop a roadmap for your ISMS implementation and ISO 27001 certification
Implement Plan, Do, Check, Act (PDCA) process to recognize challenges and identify gaps for remediation
Consider the costs of ISO 27001 certification relative to your organization’s size and number of employees.
Use project planning tools like project management software, Gantt charts, or Kanban boards.
Define the scope of work from planning to completion.
Determine the scope of your organization’s ISMS
Decide which business areas are covered by your ISMS and which ones are out of scope
Consider additional security controls for processes that are required to pass ISMS-protected information across the trust boundary.
Communicate the scope of your ISMS to stakeholders.
Establish an ISMS team and assign roles
Select engineers and technical staff with experience in information security to construct and implement the security controls needed for ISO 27001.
Build a governance team with management oversight.
Incorporate key members of top management (senior leadership and executive management) and assign responsibility for strategy and resource allocation.
If you have a large team, consider assigning a dedicated project manager to track progress and expedite implementation.
Align the team on the following:
The planning steps you’ve already taken
The scope of the ISMS
Which team members are responsible for which aspects of the project
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
Meet with your team to discuss this inventory and ensure that everyone is aligned.
Perform 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 that you identified during your risk assessment.
Summarize each identified risk
Indicate the impact and likelihood of each risk.
Rank risk scenarios based on overall risk to the organization’s objectives.
Document a risk treatment plan
Design a response for each risk, known as a risk treatment.
Assign an owner to each identified risk and each risk mitigation activity.
Establish target timelines for completion of risk treatment activities.
Implement your risk mitigation treatment plan and track the progress of each task.
Complete the Statement of Applicability
Review the 93 controls listed in Annex A.
Select the controls that are relevant to the risks you identified in your risk assessment.
Complete the Statement of Applicability listing all Annex A controls, justifying inclusion or exclusion of each control in your ISMS implementation.
Implement ISMS policies, controls and continuously assess risk
Assign owners to each of the security controls to be implemented.
Figure out a way to track the progress and goals for each control.
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
- All of the Annex A controls that you have selected
Establish employee training and awareness programs
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.
Make security training part of the onboarding process for new employees.
Conduct regular training to ensure awareness of new policies and procedures.
Conduct regular management reviews
Plan reviews at least once per year. Consider a quarterly review cycle if your organization is large or if your infrastructure is changing frequently.
Ensure the ISMS and its objectives continue to be effective.
Verify that senior management stays informed.
Ensure risks or deficiencies can be promptly addressed.
Assemble ISO 27001 required documents
Review the ISO 27001 Required Documents and Records list.
Customize policy templates with organization-specific policies, process, and language.
Perform an ISO 27001 internal audit.
Examine each of the requirements from Annex A that you deemed applicable in your ISMS' Statement of Applicability and verify that you have each in place.
Assign in-house employees to conduct the internal audit, specifically employees who were not involved in the ISMS development and maintenance or hire an independent third party.
Share internal audit results, including nonconformities, with the ISMS team and senior management.
Address any issues your internal audit identified before proceeding with the external audit.
Verify compliance with the requirements from Annex A deemed applicable in your ISMS' Statement of Applicability.
Undergo external audit of ISMS to obtain ISO 27001 certification.
Select an independent ISO 27001 auditor.
Complete the Stage 1 Audit consisting of an extensive documentation review; obtain the auditor’s feedback regarding your readiness to move to the Stage 2 Audit.
Complete the 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 addressed.
Ensure your organization is following the processes that it has specified and documented.
Ensure your organization 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.
Plan for subsequent ISO 27001 audits and surveillance audits.
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 NowPlan strategically when scheduling and timing your audit
Sometimes, the biggest roadblock to scheduling an audit is knowing where to start. Here are a few tips for taking your first big step in the audit process.
Check into your chosen firm’s availability. Small auditing firms tend to have more limited time and need more advance notice, while larger firms have more resources and, therefore, more availability. However, larger firms can cost more to hire.
Give yourself enough time before the audit. In many cases, audits don’t just check to see if you’ve done an activity once; they look for evidence of continuous controls. Plan to collect consistent evidence over at least three months to demonstrate this.
Choose a dedicated team or team member who will be available throughout the audit. Your auditor will need a go-to person to provide all the proper information and be available for any follow-up questions. Check calendars of others stakeholders involved with the audit controls to ensure they’ll be present when you schedule your audit on-site or live sessions.
Be aware of commitments and deadlines. You will likely sign a statement of work (SOW) when you schedule an audit. Your team is responsible for meeting all the deadlines outlined in this SOW. The auditor will need the correct information from your team in a timely manner to do their job.
Pro tip: Make sure your team understands the difference between the “audit window” or “review period” and the length of the audit itself. The “audit window” is the timeframe the auditors will use to gauge if you’ve been consistent with your controls. Typically, they require three months or more. This time period is different from the 1-4 weeks that the auditor will be inside your organization, conducting the audit itself.
Prepare your team in advance
Once you’ve scheduled your audit, it’s time to work with your team and assign tasks to the appropriate owners. An audit requires participation from several teams, from engineering to IT to sales. Here are a few ways to prepare these teams for audit-related activities:
Know which framework(s) you’re working towards and communicate the requirements to your team. If you’re going to work towards multiple frameworks simultaneously, identify overlaps so you don’t duplicate work. A tool like Vanta helps break down requirements and map them to action items.
Understand which evidence each team needs to provide. Next, communicate requirements and deadlines to each department. It’s a good idea to use a central hub that can show all preparation activities and who is responsible for each one.
Inform your team why this is an important activity so they understand that the time and commitment are worthwhile for them. Connect it to outcomes and KPIs that matter to their teams whenever possible. Audits ultimately prove your company’s commitment to security and trust, and meeting a framework can be the difference between growing your business and missing out on opportunities.
Communicate to your team that the goal is progress, not perfection. If it’s your first time getting audited against a particular framework, you probably won’t get a perfect score, and that’s okay! Instead, make it your goal to set a baseline for meeting the framework, then find ways to improve your controls over time.
Pro tip: As you and your team prepare for the audit, remember to do your due diligence before the auditor even arrives. Get to know exactly how your controls align with the framework and be realistic about which shortcomings you expect the auditor will likely find. That way, you won’t be surprised by the audit’s findings.
Manage your evidence
As your team prepares for an audit, collecting evidence of your activities is just as important as completing the activities themselves. For example, you will likely need to draft formal security policies and protocols (for example, this is one of the requirements for SOC 2). But you can’t just say, “We have the required security policies.” You’ll need to provide your auditor with a hard copy of your policies. And this is just one of the many controls they will require you to prove with documentation.
Managing evidence gets complicated quickly, considering how many documents your auditor will require. So, it’s your job to make sure that evidence is organized and ready as soon as the auditor asks for it. Here are a few tips for compiling the proper evidence to be fully prepared when the auditor arrives:
Ensure your evidence shows consistency —not just point-in-time or static documentation. You should be able to prove that you’ve maintained the proper controls throughout your audit window. A tool like Vanta that supports continuous controls monitoring can help with this.
Compile and store your documentation in a way that simplifies sharing the relevant evidence with the auditor. You want to spend as little time as possible chasing down specific documents or screenshots during the audit. Getting organized beforehand means far less stress for your team when the auditor begins their assessment. Vanta can help you stay on top of your documentation by storing all documents in a centralized location and automatically updating data with real-time changes.
Get to know your evidence inside and out. You shouldn’t be surprised by anything that your auditor finds. It helps to use a governance, risk, and compliance (GRC) automation tool to parse through the documentation and summarize findings. This way, you have a consolidated view of evidence rather than a bunch of disparate documents and files that are hard to consume at once.
Be transparent and upfront with your evidence. Don’t try to shape a specific story or alter the truth by showing more or less documents to an auditor. Honesty is always the best policy in these cases, especially considering the potential consequences of lying in an audit. Altering the truth can significantly impact the integrity of your company, or even prevent you from requesting audits in the future.
Pro tip: Be transparent without embellishing the truth when the auditor arrives. Let your evidence speak for itself. You might think this goes without saying, but the temptation to overshare or embellish can get the best of anyone when the audit actually begins.
Work closely with your auditor
Many organizations enter the auditing process with concerns about their relationship with the auditor. Fortunately, in most cases, the process will be less like a test proctored by an intimidating professor and more of a back-and-forth conversation with an industry expert who knows best how to get you to your goals.
Here’s some advice for working with your auditor and making it a better experience for both of you:
Look for specialization. Find an auditor specializing in the framework(s) you’re working toward. You can start by asking for recommendations within your industry—Vanta’s network of trusted auditors is a great place to start.
Help your auditor understand your business. You will need to guide them through the ins and outs of your organization, including where your controls reside and which insights they provide to your business. They won't know where to start assessing your controls if they don’t understand your organization or GRC processes and tools.
Treat the audit like a conversation. In most cases, your auditor will be inside your organization for a few weeks to months, and during that time, it should become a back-and-forth working relationship. The auditor will likely ask you for specific evidence over time, and you will work with them directly to provide each piece of information they need, and so on.
Maintain the relationship with your auditor afterward. They can serve as a helpful resource as you build out your GRC initiatives and continuously maintain and improve compliance over time. While auditors can’t give direct advice on how to do something, most are more than willing to help wherever they can. For example, if you plan to change your tech stack, employee policies, etc., consider asking your auditor how these changes will impact future audits before committing to the change.
Pro tip: Keep in mind that it’s common practice to switch your auditor every few years to avoid bias. But once you’ve found a firm and auditor you like, you can always ask them for recommendations and referrals to find your next auditor.
Take your audit results to the next level
An audit isn’t just a one-and-done activity—it’s the beginning of a journey toward a stronger security posture over time. To get the most out of your audit findings, prepare your team to work on the following initiatives after the audit is done:
Share your new compliance status with the right audiences. Many businesses rely use a public-facing site (like Vanta Trust Center) to display their real-time GRC efforts. Your prospective customers can then use this data to expedite security questionnaires and provide proof points to key decision-makers.
Track KPIs that show your response to the gaps that your auditor finds. The specifics of these KPIs will depend on your particular business, priorities, etc. In general, they should center around risk reduction and remediation efforts. For instance, if you have any findings, opportunities for improvement (OFI), or nonconformities listed in your report, track the response to these insights over time. How are you changing processes? What new tools have you implemented?
Consider conducting a readiness assessment between formal external audits. Businesses will typically either hire a third party or pick a team member who isn’t involved in any GRC activities to perform this type of audit. The best way to incorporate readiness assessments into your processes without causing business disruption is to use continuous monitoring to get an instant snapshot of all existing controls.
Treat your audit like a jumping-off point for security initiatives. Meeting a particular framework doesn’t necessarily equate to bulletproof security. For example, a compliance framework often doesn’t account for emerging threats. Still, consistently meeting the controls listed in a framework is a great starting point for establishing a strong security culture throughout your organization.
Foster a strong security culture. As you respond to your audit findings and implement stronger GRC controls, your team members need to understand why specific controls exist and how to play a role in meeting them. Ultimately, this is all about fostering a strong security and risk management culture throughout your organization. Consider rolling out security training and tracking KPIs such as phishing drill click-through rates and training completion rates. This will help demonstrate progress for future audits as well as improving your organization’s security posture.
Pro tip: Keep in mind that it’s common practice to switch your auditor every few years to avoid bias. But once you’ve found a firm and auditor you like, you can always ask them for recommendations and referrals to find your next auditor.
Anatomy of an audit report
Knowing what to expect when you finally get that audit report can help you set expectations for internal and external stakeholders ahead of time. Here’s what the typical audit report should contain:
- Executive summary: A high-level recap of the report’s purpose, the standard/framework in question, etc.
- Scope: An in-depth description of the scope that the audit covered. For example, was it a corporate-wide evaluation, a test on a specific application, or something else?
- Testing information: A detailed list of all tests the auditor ran, such as policy reviews, artifact evaluations, and on-site observations.
- Testing results: A report on the results of these tests, including any exceptions.
- Management responses: The management team’s explanations as to why an exception exists and how they will respond to it in the future.
- Conclusion: The auditor’s opinion on the assessment. Keep in mind that this area of the report will rank the company by maturity, not as a pass or fail.
While compliance audits can feel overwhelming because of the time and resources that they require, they offer your team the unique opportunity to start a journey toward stronger security and deeper customer trust. Plus, tasks like scheduling, managing evidence, and working with your auditor don’t have to feel so daunting if you go into your next audit with the right expectations and preparation.
Confirm which CMMC level your business needs
The first step of the CMMC program and becoming CMMC certified is confirming what CMMC level you’re on. Here are a few ways you can confirm what level your business needs.
Determine the type of data you handle. If you handle FCI, you’ll likely fall under level 1, whereas if you handle CUI, you will be under level 2 or 3. If you handle a variety of FCI and CUI information, you must be certified at the level encompassing all the information you handle.
Check your contract. If you currently have a contract, reach out to your contracting officer. They can help determine your level and the requirements to remain compliant. As you bid on future contracts, the DoD will specify the required CMMC level and assessment type for eligibility in the solicitation and resulting contract.
Perform a self-assessment. If you don’t currently have a contract, but hope to in the future, the best thing you can do is perform a self-assessment of your systems. This ensures you meet the necessary security requirements and have implemented proper controls to protect sensitive information. It will also give you an idea of what level you’re at.
Establish your FCI and CUI boundaries
Once you confirm what level of certification you need, your next step is to figure out what systems, processes, and data—referred to as assets—fall under CMMC requirements. The DoD refers to this process as establishing your boundaries for FCI and CUI.
Review boundaries and assessment scope guidelines for your CMMC level. Each level has set boundaries and assets based on the information that’s handled. Once you know your level, you can review general guidelines for assessment scope.
Identify in-scope assets. For each level, there will be set assets that are considered in scope. Depending on the certification you’re seeking, you’ll need to identify all assets that process, store, or transmit FCI or CUI data. This includes all people, technology, facilities, and external service providers. For levels 2 and 3, this also includes specialized assets, security protection assets, and contractor risk managed assets.
Document in-scope assets. Once you’ve identified all assets in scope, you’ll need to document them. Documentation includes creating an asset inventory and providing a network diagram, which will be a part of your official assessment.
Pro tip: At each level, any asset that isn’t in scope is considered out-of-scope, meaning it doesn’t need to be documented during an assessment. For more information on what assets are considered in and out of scope, the DoD has scoping guidelines for each level.
Perform a gap assessment
Once you’ve established your CUI and FCI boundaries and your organization’s current status, you’ll want to conduct a gap assessment, also known as a CMMC gap analysis, to identify areas where your organization is falling short. A good gap assessment helps reduce the stress of prepping for CMMC certification since it’ll show you any areas or processes you need to focus on to pass level assessments and get certified. To perform a gap assessment, you’ll want to:
Identify and document existing controls. Map your current security controls to the objectives outlined in the CMMC framework. This includes documenting asset treatment in a system security plan (SSP).
Identify and document controls not yet satisfied. Identify and review controls that you haven’t yet satisfied. You’ll want to pay close attention to this step as these controls need to be addressed and satisfied to pass certification during an official assessment.
Pro tip: As you complete your gap assessment, you’ll likely need to collaborate with stakeholders across the business to ensure you have up-to-date information. Improper documentation or oversight of required controls could result in your organization not meeting CMMC certification requirements.
Create and execute a plan of action and milestones
As you work through the steps of planning and preparing for CMMC certification, you’ll also need a Plan of Action and Milestones (POA&M).
Create a POA&M. A POA&M allows companies to create a roadmap for improvement with details on what to prioritize, steps for action, who’s responsible for them, resources needed, and deadlines. Any company seeking CMMC certification can complete a POA&M after their gap assessment.
Execute your POA&M. The actions and steps outlined in your POA&M should make the process easier. But, take it step by step. Attempting to remediate every action at once makes it hard to track progress. It could also result in accidentally overlooking important steps, security gaps, or unresolved issues, which can impact your official assessment.
Regularly monitor progress and gather evidence. As you begin implementing new controls, document and monitor progress. This includes validating control design and regularly reviewing your progress against milestones. You’ll also want to gather evidence surrounding them. Evidence should include steps you’ve taken to implement controls and any results from it. If controls result in new policies and procedures, document those as well.
Pro tip: Along with completing a POA&M, you should document your Supplier Performance Risk System (SPRS) score. An SPRS score ranges from -230 to +110 and helps the DoD understand how well a contractor is protecting sensitive data and government information. Determining your SPRS score can ensure you focus on the right areas when working towards CMMC certification.
Conduct assessment
If you’ve completed steps one through six, conducting the assessment should go smoothly. Ideally, you’ve addressed all security gaps and areas of improvement in your POA&M, so there shouldn’t be any surprises during the official assessment. Like most of the CMMC certification process, the type of assessment you conduct will depend on your level.
Level 1
Conduct a self-assessment against level 1 security requirements. Level 1 only requires a self-assessment.
Gather and prepare evidence. A self-assessment requires the submission of documents and evidence, such as policy and process documents, training materials, and planning documents. It also requires interviews with employees and testing to ensure processes are followed.
Ensure all level 1 security requirements are met or marked as “not applicable.” To achieve level 1, all security requirements must be met or not applicable, with results entered into the SPRS.
Level 2
Determine which assessment is required. Level 2 has two types of assessments, a self-assessment or a certification assessment. Self-assessments for level 2 are the same as level 1. For a certification assessment, a C3PAO must complete it.
Gather and prepare evidence. The documents, interviews, and testing laid out in level 1 are required for level 2 certification.
Determine if you’re eligible for a conditional or final level 2. A level 2 assessment can result in a conditional or final level 2. A conditional level 2 will require a POA&M. To achieve level 2, all security requirements must be met or not applicable.
Update your POA&M for final certification if you receive a conditional level 2. To achieve a final level 2, you must complete or close out your POA&M within 180 days.
Level 3
Achieve final level 2 certification with a C3PAO. Level 3 requires two assessments. Both must be completed to achieve level 3 certification. The first assessment is achieving final level 2 with a C3PAO.
Complete an assessment with the Defense Contract Management Agency (DCMA) DIBCAC. This assessment is based on level 3 requirements. The DCMA DIBCAC assessment can result in a conditional or final certification.
Update your POA&M for final certification if you receive a conditional level 3. To achieve final level 3, you must complete or close out your POA&M in 180 days.
Pro tip: Keep in mind that it’s common practice to switch your auditor every few years to avoid bias. But once you’ve found a firm and auditor you like, you can always ask them for recommendations and referrals to find your next auditor.
Maintain certification
After putting in the work to officially become CMMC certified, you’ll need to maintain your certification. Due to the quickly evolving nature of cybersecurity, the DoD requires CMMC-certified organizations to review their controls and affirm compliance annually. Depending on your level, assessments take place annually or every three years.
Level 1
Complete a self-assessment annually. Similar to initial certification, you must complete the self-assessment and enter it into the SPRS every year.
Complete an annual affirmation. The annual affirmation verifies compliance with the 15 basic safeguarding requirements in FAR clause 52.204-21, Basic Safeguarding of Covered Contractor Information Systems.
Level 2
Complete an annual affirmation. For both self and C3PAO certifications, an annual affirmation verifying compliance with the 110 security requirements in NIST SP 800-171 Revision 2, Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations needs to be completed and entered into the SPRS.
Complete a self- or C3PAO assessment every three years. Results of a self assessment must be entered into the SPRS. C3PAO results must be entered into the CMMC Enterprise Mission Assurance Support Service (eMASS).
Level 3
Complete an affirmation annually. An annual affirmation must be completed to verify compliance with the 24 identified requirements from NIST SP 800-172 and entered into the SPRS.
Complete a DIBCAC assessment every three years. Results of a DIBCAC assessment must be entered into CMMC eMASS.
How Vanta makes CMMC certification easier
While CMMC certification can feel overwhelming, having tools to help you prepare for and maintain certification is key.
Vanta makes it easier to meet CMMC requirements across all three levels. Through a centralized platform, Vanta can guide you through the step-by-step process of obtaining and monitoring your CMMC implementation.
Additionally, Vanta’s extended partner network offers hands-on support to ensure you can successfully implement CMMC and conduct assessments to renew contracts and win new business.
A note from Vanta: Vanta is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.
Starting your healthcare compliance program
Starting a healthcare compliance program may seem complex, particularly if you’re new to security and compliance. But with the right approach, it can become a clear and manageable process. Investing in building a strong foundation now will set your organization up for future scale and success.
Evaluate your business needs: Start by assessing your organization’s compliance drivers including the following questions:
- Do you collect or process PHI? If yes, HIPAA compliance is mandatory.
- Have clients or prospects ever asked you about compliance with HIPAA or other industry security standards?
- Do your competitors maintain HIPAA compliance or other security standards such as SOC 2, ISO 27001, or HITRUST?
Confirm your PHI scope and data flows: Map out how PHI is collected, processed, transmitted, and stored. You’ll want to minimize PHI exposure across systems and vendors and implement the principle of least privilege and minimum necessary use, in alignment with both HIPAA and broader information security best practices to help reduce risk.
Engage legal counsel and define key roles: As noted above, HIPAA compliance is a legal obligation if your organization handles PHI in any way. You’ll want to review and define your role as a Covered Entity or Business Associate and involve legal counsel early in the process to help guide your regulatory compliance scope and strategy.
Get HIPAA-ready: To prepare for HIPAA compliance, start by implementing baseline technical and administrative safeguards, such as enabling automatic session timeouts and screen locks, encryption at rest and in transit, multi-factor authentication (MFA) enforcement, and least privilege access configurations. Next, establish policies covering various domains such as access control, incident response, breach notification, mobile device management, as well as patient privacy, rights, and related disclosures. From a third-party perspective, ensure you sign Business Associate Agreements (BAAs) with all third parties that handle PHI, and conduct vendor risk assessments to validate their HIPAA compliance posture.
Layer additional frameworks for audit assurance: To strengthen your healthcare compliance program and meet growing customer expectations, consider additional frameworks such as SOC 2 or ISO 27001/27017. These standards provide a more structured and auditable foundation for your compliance practices, and when paired with HIPAA, they enhance your security and privacy posture while also signaling to customers and prospects that you’re prepared to meet their expectations for trust.
Accelerate compliance with the right technology: Instead of relying on manual processes and spreadsheets, choose a platform that streamlines and automates your path to audit readiness—especially if you're working with a lean team. To accelerate sales conversations, build an external-facing trust center to proactively showcase your security posture and healthcare compliance to prospects. You can enhance your trust center by automating security questionnaires with AI-powered responses.
Pro tip: Vanta simplifies your healthcare compliance journey by outlining exactly what’s needed to get audit-ready. Vanta identifies gaps, shows you how to fix them, and automates the process.
Scaling your healthcare program
As your business grows, your compliance program needs to scale with it. Whether you're expanding your team, adding new systems, or selling to larger customers, complexity increases—and so does the need for a more mature and efficient approach to security and compliance. This phase is about operationalizing your program with the right frameworks, tools, and processes to stay ahead of risk while maintaining velocity.
Identify efficiency gaps: Growth introduces new challenges: more people, more tools, and more moving parts. As your business scales, your current compliance processes may not be able to keep up with the additional complexity and operational overhead. Assess your maturity needs by asking the following questions:
- Is your company expanding rapidly or pursuing enterprise clients?
- Are you adding more tools or systems to your environment?
- Is it becoming harder to track compliance status across teams or frameworks?
If you answered yes to any of these questions, then it's time to shift from a foundational program to a scalable and more integrated model.
Mature your program with more prescriptive frameworks: While HIPAA is a necessary baseline, it’s not designed to provide the depth of guidance needed for large-scale or highly regulated operations. As expectations increase, consider layering in additional frameworks that provide further structure, auditability, and credibility.
- HITRUST: Offers tiered, prescriptive certification paths (e1, i1, r2) tailored to healthcare use cases and often required by enterprise customers, such as large health providers.
- NIST CSF: Helps align with cybersecurity risk management best practices, especially if you plan to work in the public sector.
- NIST AI RMF or ISO 42001: If you're incorporating AI, these frameworks support responsible AI governance and risk management.
Centralize and automate compliance workflows: As complexity grows, fragmented workflows and manual tracking break down. Implementing a trust management platform can help you reduce operational overhead and improve visibility by:
- Enabling cross-mapping of controls, so you only have to test once across multiple frameworks, such as between HIPAA, SOC 2, HITRUST, ISO 27001, etc.
- Running automated tests to continuously monitor your controls for failure risks and streamline year-round audit readiness.
- Sending alerts when gaps are identified, and providing clear remediation steps.
Strengthen vendor risk management: Your risk surface grows with every third-party vendor you add. Taking a proactive approach to vendor management not only protects your sensitive data, such as PHI, but also signals maturity to your customers and partners. This includes:
- Building a centralized inventory of all vendors that handle PHI or your sensitive and critical systems.
- Tracking BAAs, SOC 2 reports, and other security and privacy documentation
- Automating vendor risk reviews and renewal cycles to ensure continuous oversight.
Stay ahead of emerging regulation: The healthcare regulatory environment continues to evolve, especially with the rise of AI and ongoing threats to PHI. To stay compliant over time, keep an eye on:
- Updates to regulations, such as HIPAA. Examples include the upcoming Security Rule update.
- New laws such as Healthcare Cybersecurity Act, which may introduce new federal expectations for providers and vendors.
Additionally, build time into your roadmap for regular gap assessments and policy reviews. Staying proactive helps you reduce risk, avoid fire drills, and respond to change with confidence.
Build trust and drive growth with Vanta
Vanta automates HIPAA, HITRUST, SOC 2, and 35+ other frameworks to help you simplify compliance, strengthen security, and boost efficiency—all in one place. Reduce manual work and monitor compliance continuously, reducing the hassle of screenshots and spreadsheets. And as your business grows, Vanta scales with you, helping you save time on evidence collection with 375+ integrations and automatic cross-mapping between frameworks.
Learn more about Vanta for Healthcare.
A note from Vanta: Vanta is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.
Understand your risk level
The first step to becoming AI Act compliant is to understand your risk level. The AI Act specifies four categories to determine this:
Unacceptable: This class of AI is considered a clear threat to those who use it, with harmful features aimed at manipulation and exploitation. It is prohibited as a result.
High: High-risk AI poses serious safety and health risks, and potentially interferes with people’s fundamental rights. However, these cases can reach the market if they meet strict security obligations.
Limited: This category covers AI with specific transparency requirements, e.g. chatbots that must inform users that they are interacting with AI.
Minimal (no risk): This AI poses minimal or no risk to people with the majority of AI use cases across Europe falling into this category.
Understanding your risk level isn’t just about your organisation though – it’s about those you work with. You should therefore extend your AI risk categorisation to the third-party vendors you work with.
Understand the AI risk level of your third-party vendors and the AI they’re using.
Understand the AI risk level AI of your AI-driven vendors, such as LLM providers
Meet regulation requirements and establish AI risk management
The next step is to work on the AI Act regulation requirements as per your risk level to ensure you are compliant. You must ensure this covers best practices around:
- User research
- System architecture related to your AI system
- Data collection and model training to insure integrity and quality of your AI systems are maintained
- Documentation to be able to explain your AI risk management system
- Feedback mechanisms
Comply with the NIST AI RMF: Regardless of your risk level, you should establish and maintain an AI risk management system–one that includes mitigation strategies. An effective method of doing this is to follow the NIST AI Risk Management Framework. As part of this, you should leverage technical measures for risk mitigation and human-performed activities such as risk management software, automation and even AI itself. But you should also establish human oversight mechanisms for risk management to ensure you are bringing human oversight and accountability.
Obtain the right technical documentation
It is important to obtain the right documentation to support compliance assessment. A good place to start is with an Information Security Management System (ISMS). This establishes a systematic approach to managing your organization’s information security, and a structured approach to integrating information security into your business processes.
Helping to manage and minimise risks to acceptable levels will increase your organization’s resiliency against evolving security threats and ensures the confidentiality, integrity, and availability of organizational and customer information. The scope of an organization’s ISMS can be as small or as large as is necessary. The ISO 27001 standard defines which documents must exist at a minimum.
Plan your ISMS: Put a team and a roadmap together to implement ISMS policies and controls, and continuously assess risk.
Meet the ISO 27001 standard: ISO 27001 is a go-to standard that aligns with global and EU-specific data protection regulations like the GDPR. You can find our ISO 27001 Compliance Checklist here.
To become AI Act compliant, you should establish an Artificial Intelligence Management System (AIMS). ISO 42001 is a great place to start as it is the international standard for establishing, implementing and maintaining an effective AIMS:
Plan your AIMS: Assign a project leader and put a team and roadmap together to implement your AIMS. Our ISO 42001 checklist is a great place to kick this off in the right way.
Earn ISO 42001 certification: ISO 42001 certification demonstrates to customers, partners and regulators that you’re using AI responsibly, ethically and transparently.
To truly demonstrate trust, companies should go beyond the standard. For fintechs, and other financial institutions, this might look like compliance with the Digital Operational Resilience Act (DORA) framework.
Comply with the DORA framework: Not strictly part of the AI Act, the DORA is a relatively new EU framework for ensuring enhanced cybersecurity and operational resilience of financial entities operating in the Union.
Pro tip: You can find out more about DORA and how Vanta can help fintechs scale trust in our free guide–Fortifying Fintech: Security must-haves for Europe’s trailblazers.
Establish data governance
Data governance is essential to maintaining trust and companies must ensure the confidentiality, availability and integrity of the information they handle.
The data used by AI is not just about quality, however–it is about the transparency surrounding how you use it. More and more organisations are training AI models on a mix of customer and synthetic data. What’s more, without a formal data processing agreement (DPA) that prohibits vendors from using customer data to train their AI models, companies risk threats coming from third-parties too.
Ensure you have a formal DPA with your third-party vendors.
Ensure the quality of your data for training, validation, and testing of AI systems.
Ensure your data is accurate, representative and complete.
Ensure customers are given an opt-out option for training AI with their customer data.
Build with trust and transparency
In the AI era, trust and transparency are essential. Customers must have easy access to appropriate information about your company and products, e.g. characteristics, capabilities, limitations, potential risks.
This can be an all-consuming process for security teams, which is why we launched Trust Center – a hassle-free way for companies to demonstrate trust in real-time. Because earning security credentials is only half of the job–to demonstrate trust, you have to communicate them too.
Set up a process to collect evidence to demonstrate compliance: Demonstrating compliance can come with a lot of chaos. But Vanta can help you to automatically gather the evidence you need – taking the strain off your security team.
Communicate security credentials: Use Vanta’s Trust Center to communicate your security credentials to customers, demonstrate trust and turn good security into good business.
Embrace continuous compliance
Forward-thinking organisations won’t stop at the AI Act. They’ll go beyond point-in-time checks towards a holistic and continuous approach to monitoring. This is the practice of ensuring that you’re properly meeting compliance standards you’ve committed to on an ongoing basis – not just at the time of an audit. This approach is integral to establishing appropriate levels of cybersecurity, accuracy and robustness.
Embrace continuous compliance: The path to continuously monitoring your systems looks like checking for compliance gaps on a daily basis – and relying on automation to cut the amount of manual work this involves.
Continuous compliance will ensure you are in a good position to monitor for updates from the European Commission and that you remain agile to the broader risk landscape. But it will also bring reputational benefits and a welcome boost to your bottom line.
Streamline your EU AI Act compliance with Vanta
Vanta is the fastest way to become AI Act compliant, strengthen your cybersecurity posture, and build trust. Vanta’s trust management platform provides organisations with the capabilities and guidance required to efficiently and effectively achieve AI Act compliance. It provides a centralised view of your compliance and security posture by continuously monitoring the critical tools and services your business runs on. Get in touch with our team today.
Pre-work for your Cyber Essentials certification
Evaluate your need for Cyber Essentials. You can assess whether you need a Cyber Essentials certification based on the following criteria:
Do you collect or process sensitive or personal data from UK residents?
Have you ever been asked about Cyber Essentials by clients or prospects?
Do your competitors have Cyber Essentials certification?
Are you working with companies that provide public services in the UK?
Choose the right Cyber Essentials certification. Although both versions of the Cyber Essentials frameworks have the same requirements, Cyber Essentials Plus involves a third-party audit and technical testing. As a result, Cyber Essentials Plus provides an extra layer of security validation beyond the self-assessment in the standard Cyber Essentials certification.
Do you need Cyber Essentials or Cyber Essentials Plus?
Here are some helpful considerations for deciding whether to pursue the Cyber Essentials certification or Cyber Essentials Plus:
Determine your budget. Cyber Essentials Plus is more expensive than Cyber Essentials because of the external audit and higher security assurance. Pricing for Cyber Essentials ranges from £320 to £600 (plus VAT). Cyber Essentials Plus does not have a fixed pricing structure, but estimates start at £1,499 (plus VAT) and increase based on your organisation’s size and complexity. Learn more about Cyber Essentials costs.
Assess your time and team resources. Cyber Essentials Plus requires more time and bandwidth and takes longer to complete, especially for smaller companies (or security teams) with limited internal resources.
Understand your stakeholders’ concerns. The Cyber Essentials Plus third-party audit requirement enables you to demonstrate your commitment to enterprise-wide data security and assure stakeholders who may have security concerns.
Define customer requirements. Cyber Essentials Plus is required to win UK government contracts. It may also be required to conduct business with certain companies in the UK, such as those looking to prevent potential supply chain-related cyber threats from impacting their operations.
Evaluate your infrastructure size and complexity. Larger, more complex entities whose interconnected assets and operations are at high risk of being disrupted by cyber threats may benefit from Cyber Essentials Plus. Its rigour ensures reliable safeguards protect this infrastructure.
Estimate the volume and sensitivity of stored data. Companies that handle vast amounts of sensitive data (such as PHI in healthcare) may gain higher assurance with Cyber Essentials Plus.
Prepare for your Cyber Essentials certification
First, identify your Cyber Essentials requirements.
Obtaining a Cyber Essentials certification requires you to implement controls across five categories:
Firewalls: All firewalls deployed to system boundaries, endpoints, servers, cloud services, and other critical infrastructure entry points should have the correct security configurations, access controls, and security rules.
Secure configurations: All configurations applied to endpoints and networked services should reduce exploitable vulnerabilities while enabling the completion of business-critical services.
User access controls: Access to all user accounts should require authorisation, and only the people who need access to specific endpoints, services, or applications to complete business tasks should have access. Consider using time-bound or just-in-time access and implementing the principle of least privilege (PoLP) to tighten user access controls.
Malware protection: Administrators should establish the appropriate security mechanisms to prevent malware intrusion via known and unknown sources. They should also educate employees and third parties on the risks of malware and ransomware and how to avoid social engineering scams.
Security updates: All devices and software at risk for security flaws should be updated regularly to ensure their configurations are secure and in alignment with recommended industry/manufacturer security standards.
Gap analysis and remediation
Conduct a gap analysis. Evaluate IT infrastructure for gaps in the above control categories.
Document gaps and develop a remediation plan. Documenting the gaps identified and proposing actionable steps to rectify them is critical.
Address gaps that could lead to security vulnerabilities. Following a gap analysis, you may need to remediate sources of exploitable vulnerabilities.
Examples of remediation steps include:
Changing default administrative passwords into stronger, unique ones
Deactivating unnecessary user accounts that are not currently in use
Scheduling automatic system and network security updates
Implementing multi-factor authentication for all user accounts
Installing anti-malware software on all devices
Test all applicable controls. It’s critical to monitor devices and networks to verify the effectiveness of implemented controls in preparation for assessment. Test your controls and make sure they are functioning properly.
Document findings from system monitoring. It’s also helpful to record all the information from monitoring in an organised, shareable report format to keep track of it. Doing so manually is a challenge for any organisation, which is where automation solutions, like Vanta, help reduce these burdens and enable organisations to scale their security monitoring capabilities as they grow.
Complete the self-assessment (for Cyber Essentials)
After you’ve identified the Cyber Essentials requirements that apply to your organisation and remediated any security gaps, the next step towards becoming Cyber Essentials certified is to complete the self-assessment, which is required even when you’re aiming for the Cyber Essentials Plus certification. Here are the steps our team of compliance experts recommend taking:
Prepare for the Cyber Essentials self-assessment. Train all parties involved in the certification process so they are on the same page regarding Cyber Essentials documentation. Building and maintaining a security awareness culture is crucial for your organisation to fully comply with Cyber Essential security guidelines during its day-to-day operations beyond preparing for the Cyber Essentials self-assessment (or audit, if you choose to pursue Cyber Essentials Plus).
Conduct the self-assessment questionnaire. (SAQ). When ready, you can complete an online SAQ and have a senior team member validate it to get the Cyber Essentials certificate. It’s essential to be accurate and truthful when answering questions to ensure alignment with the necessary standards for obtaining the certificate.
Use online readiness tools to prepare for the test. Tools like the IASME Cyber Essentials Readiness Tool provide free questions to help you assess the posture of your company’s controls and their impact on your business operations. These questions are designed to inform you about your current readiness so you can develop a tailored action plan for the Cyber Essentials audit.
Decide whether you need the Cyber Essentials Plus audit. You can choose to obtain the Cyber Essentials Plus certification immediately after the Cyber Essentials self-assessment or in the following months. While you must complete just the self-assessment to obtain the Cyber Essentials certification, you’ll also need to complete and pass an external audit to receive the Cyber Essentials Plus certification.
Complete the external audit for Cyber Essentials Plus
Prepare for the Cyber Essentials Plus audit. If you want to obtain a Cyber Essentials Plus certification, you should ensure your SAQ was certified within three months of applying for the Cyber Essentials Plus.
Identify an independent assessor: Work with a highly-trained assessor to verify that all currently implemented controls align with the Cyber Essentials Plus requirements.
Review audit findings and implement remedial actions (if any): Address any gaps identified during the independent assessment within a set period.
Obtain Cyber Essentials Plus certification: A successful Cyber Essentials Plus certification provides a certificate valid for 12 months following the assessment pass date. Then, you can become designated as a CE-certified company, opening new business opportunities in the private sector or with the UK government.
Maintain ongoing Cyber Essentials or Cyber Essentials Plus certification
Monitor your IT infrastructure regularly. Organisations need continuous internal assessments to verify adherence to the Cyber Essentials security guidelines. As systems and networks age, they are exposed to more vulnerabilities. So, you need to review your existing security configurations and ensure they still match the rigorous standards of the Cyber Essentials or Cyber Essentials Plus program.
Renew your Cyber Essentials certification.The Cyber Essentials and Cyber Essentials Plus certifications expire after 12 months and must be renewed yearly. Renewing these certifications helps you maintain your designation as a Cyber Essentials-certified company and provides assurance to current and future stakeholders.
Implement zero-trust principles. As the cyber risk environment becomes more complex, consider implementing zero trust across systems and networks to keep your data safe. New technologies are constantly emerging, meaning cybercriminals are also looking for the easiest gaps to exploit to access sensitive data for malicious gain.
Streamline Cyber Essentials certification with Vanta
A strong security posture will enable organisations to build customer trust and expand business to or within the UK. However, it’s cumbersome to manually keep track of all the processes necessary to obtain Cyber Essentials or Cyber Essentials Plus certification.
Fortunately, Vanta automates up to 70% of the UK Cyber Essentials process (including evidence collection), dramatically simplifying the compliance process. This enables teams to focus on strengthening their security programs without redundancy.
Plus, with Vanta, you don’t need to duplicate your compliance efforts across multiple frameworks. UK Cyber Essentials has significant overlap with frameworks like ISO 27001. If you’re already compliant with ISO 27001, you don’t need to reinvent the wheel; Vanta automatically cross-references other frameworks and surfaces any overlapping controls that you already have in place.
Vanta’s trust management expertise can help startups and early-stage companies in the UK build and optimise their security programs to obtain the Cyber Essentials certification. Thousands of global customers rely on Vanta’s real-time, transparent trust management platform to demonstrate their focus on security and privacy to stakeholders.
Learn more about how Vanta automates Cyber Essentials compliance.
Pre-work for your HITRUST certification
Align your goals: Ensure that pursuing a HITRUST certification aligns with your business goals and programs
Find internal stakeholders: Identify key stakeholders within your organization, such as champions who can drive internal buy-in, and a project owner to drive the certification process
Educate leadership: Educate your team, executives, and the board on the HITRUST process, implied changes, and the added value to your organization of attaining certification
Work for your HITRUST certification
Understand the HITRUST CSF: Familiarize yourself with the control requirements of the HITRUST CSF
Identify compliance needs: Determine your organization's specific compliance requirements
Select appropriate HITRUST assessment type: Choose between e1, i1, or r2 assessment, according to needs of your business and your risk profile
Use Vanta to streamline the assessment: Use Vanta to identify and remediate gaps in your compliance program
Find an external assessor: Work with Vanta to select a HITRUST Validated Assessor—A-LIGN, Prescient Assurance, or Insight Assurance—to guide you through and to conduct your Readiness assessment
Purchase MyCSF subscription: Work with Vanta to initiate the procurement process for your Validated Assessor, MyCSF subscription, and report credit (if required)
Attend the HITRUST course: Gain insights and guidance through HITRUST’s New Customer Orientation
Define assessment scope: Identify the areas and systems to be included in the assessment and communicate the intended timeline of certification to your chosen Validated Assessor
Perform initial assessment: Work with your external assessor to identify gaps using Vanta
Initiate inheritance plans: Create plans for internal or external inheritance of controls
Make inheritance requests: Submit inheritance requests via the MyCSF platform
Secure QA date: Schedule a date for post-submission HITRUST QA review
Remediation
Resolve gaps: Use Vanta to identify and remediate any evidence gaps identified during the readiness assessment
The Validated Assessment
Provide evidence: Collect and submit necessary evidence to your external assessor
Finalize inheritance: Confirm all inheritance plans
Support External Assessor: Be available for any additional validation requests
Address issues: Resolve any issues noted during the pre-submission QA
Submission and Review
Submit assessment: Submit the relevant evidence to your chosen Validated Assessor to input into MyCSF for HITRUST to review
Support QA process: Be available to assist your external assessor with any QA queries
Certification
Review certification report: Check and approve the draft certification report
Ensuring compliance over time and beyond
Ongoing Monitoring
Remediate gaps: Use Vanta to continue to monitor your state of compliance and continue to close gaps
Plan for the next assessment
Future planning: Prepare for your next HITRUST assessment to maintain compliance, manage risks, and enhance security —
leveraging inheritance where appropriate
Advancing your assessment: Consider expanding your security posture by exploring the different levels within the HITRUSTecosystem — from e1 to i1 and i1 to r2
Leverage the business benefits of HITRUST certification, including
Commercial compliance: Satisfy customer, contractual requirements or preferences for HITRUST certification
Market access: Gain access to new or additional markets that require or prefer HITRUST certification
Market differentiator: Demonstrate the highest level of security posture as a vendor or partner
Risk mitigation: Adopt proven, repeatable, and measurable methods ensure significant risk reduction in certified environments
(only 0.64% of experienced breaches over two years)
Value creation: Improve potential valuation with investors and shareholders
Liability reduction: Protect yourself and your organization by using a prescriptive, complete, and proven framework to plan,
build, execute, and validate your cybersecurity program instead of building your own
Regulatory compliance: Reuse and restate HITRUST validated controls using HIPAA, SOC 2, ISO 27001, GDRP, and others to reduce compliance efforts
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 Now
FEATURED VANTA RESOURCE
The ultimate guide to scaling your compliance program
Learn how to scale, manage, and optimize alongside your business goals.