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Everything you should know about continuous controls monitoring (CCM)
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Continuous controls monitoring (CCM) is a crucial aspect of making GRC processes more automated, accurate, and actionable through technology. It helps organizations transition from inefficient point-in-time checks to automation-driven compliance controls that provide a real-time view into their security posture. That’s why many proactive risk management teams are already prioritizing control automation for their GRC program.
This article will cover the in-depth information you need to embed CCM in your security and compliance program. We’ll discuss its main benefits and use cases, as well as offer some practical steps for implementing it within GRC operations.
What is continuous controls monitoring? Definition and importance
Continuous controls monitoring refers to using technology-based solutions to support the practice of automated, ongoing (or highly frequent) tracking of the compliance, risk management, and security controls you’ve put in place. A control, in this context, is a safeguard or countermeasure used to detect, prevent, and minimize vulnerabilities around an organization’s data, infrastructure, and other assets.
A journal published by ISACA explains CCM as a subset of “continuous assurance, alongside continuous data assurance (verifying the integrity of data flowing through systems) and continuous risk monitoring and assessment (dynamically measuring risk).”
The need for CCM arose from various challenges of traditional control monitoring, such as:
- Delayed detection of control failures and compliance breaches due to point-in-time checks.
- Loss of time and resources due to manual and complex processes, which often leaves room for task fatigue, human error, and inconsistencies.
- Inability to keep up with changes in the regulatory landscape.
- Limited scope to track the volume and complexity of data that follows organizations expanding to new geographies, products, and technologies.
CCM effectively resolves these issues, leveraging technology to help teams keep relevant information updated and accessible and maintain a firm grasp of all GRC controls.
Benefits of continuous controls monitoring
Like any form of GRC automation, CCM brings numerous benefits, most notably:
- Increased efficiency of compliance and audit processes: CCM significantly reduces the need for manual evidence gathering and documentation at regular intervals. Using the right tools, you get a centralized repository of all the data necessary for testing and monitoring controls, which drastically reduces painstaking compliance and audit processes.
- Cost reduction: CCM lets you remove inefficient processes and control deficiencies before they get out of hand, which cuts remediation costs. It also helps achieve timely compliance and avoid the risk of penalties. Finally, since teams can monitor controls more efficiently, they get more time to spend on higher-impact projects.
- Better strategic and operational decision-making: Continuous controls monitoring gives executives and department heads a comprehensive overview of the risks associated with strategic and operational decisions, ensuring clear, data-backed decision-making.
- Reduced risk of outages and data breaches: With continuous monitoring, you can proactively identify data and infrastructure vulnerabilities before they’re exploited, and remediate them faster to fortify your organization’s security.
- Streamlined incident response efforts: Besides preventing incidents from escalating, CCM informs the best actions you can take as a part of incident response plans.
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Continuous controls monitoring: Common use cases
CCM’s agile and responsive framework makes it useful for organizations in any industry. It’s particularly important in the IT, financial, and health sectors that deal with an ever-expanding profile of data privacy, regulatory, and security threats.
Here are four prominent use cases of a CCM system:
- Risk quantification and monitoring: CCM helps your organization assess its risk posture on a more granular level. With automated configurations, you can gather the data you need to quantify risks and monitor them ongoingly. When a control fails, pre-configured alerts empower you to remediate it quickly.
- Identification of control gaps and tracking performance: If implemented properly, CCM helps you track control gaps without laborious legwork. The consistent data availability allows for near real-time reporting.
- Access management: Traditional access management is inefficient because it typically involves manual cross-referencing of human resource information system (HRIS) data with employee roles and permissions. CCM fixes this by performing automated tests that flag employees with roles that don’t have a corresponding access level.
- Change management: Continuous monitoring systems integrate with device management platforms to enable secure changes in hardware and other configurations. Additionally, CCM supports upscaled operations following the pursuit of new frameworks and ongoing audits.
How to implement continuous controls monitoring workflows
The exact process of continuous controls monitoring implementation depends largely on your existing processes, risk exposure, and compliance requirements. We have outlined four standard steps you can expect below:
- Identify the key processes and controls.
- Define control objectives.
- Set up automated tests.
- Ensure adequate monitoring and reporting.
Step 1: Identify the key processes and controls
Continuous monitoring doesn’t yield the same benefits to all processes, so the first step is to identify the most critical processes that can be automated, as well as their corresponding controls.
One way to do it is to pull historical data from previous internal audits, control breakdowns, and self-assessments. You can then combine your findings with the controls from established frameworks, such as:
After you have your list of controls, you need to define clear priorities. You can use various criteria to do so—for instance, you may decide it’s worth implementing CCM for controls with:
- High risk scores calculated based on risk assessments
- Complicated sub-processes that can lead to human error
- Abundant data availability from the tools used to implement that control
Due to all these considerations, process and control identification can take quite a bit of time and effort. Still, it’s crucial to give this step the attention it deserves as having a list of control priorities will make further decisions easier.
Step 2: Define control objectives
Objectives outline the primary function of your controls and act as reference points to help you determine their performance. Much like the controls themselves, you can define objectives based on internal data and specific frameworks.
In the former case, you need to make sure your control objectives are aligned with your overarching business objectives. It pays to factor in your risk appetite, as one of the primary purposes of your controls is to mitigate risks.
As you expand your scope, focus on compliance with relevant frameworks when defining objectives. For example, if you’re working with ISO 27017 to protect your cloud infrastructure, your security control objectives may include the following:
- Ensure adequate monitoring of cloud services.
- Remove customer assets when a cloud service is terminated.
- Align virtual and physical cloud networks.
The goal here is to have a baseline structure for CCM relationships—for example, X control is supposed to work for Y objective—which may make configurations easier.
Step 3: Set up automated tests
Automated tests are the essence of continuous controls monitoring, and you can start implementing them after mapping out your critical controls and objectives. Such tests are typically conducted in the pass/fail format and serve a simple but important purpose—outlining what happens if a control objective isn’t met.
You can carry out various types of tests, such as:
- Asset management queries
- Security posture checks
- Policy adoption status
- Onboarding/offboarding task progress
- Security setting configuration checks
- Observational tests
The specific tests you’ll implement mainly depend on your processes and controls. For example, cybersecurity controls can be tested using asset management queries. If one of your controls is to ensure all assets are protected by encryption, you can use queries to get the percentage of protected assets within a given time frame.
Testing frequency is a crucial consideration when setting up automated tests. Remember that continuous compliance and security are among the key purposes of CCM, so your test should run frequently, preferably at hourly intervals, to serve your GRC program needs.
Step 4: Ensure adequate monitoring and reporting
The final step of CCM implementation is to track your control performance. You’ll do this through key risk indicators (KRIs) and other metrics, which should alert you of any control deficiencies and help you take timely corrective action.
When defining KRIs, make sure they meet the following criteria:
- Alignment with controls and objectives
- Specificity and focus on a clear signal
- Sensitivity and timeliness that enable early warning signals
- Quantifiability to ensure precision
After outlining KRIs, set up a system for managing alerts and addressing control weaknesses. Brainstorm remediation plans beforehand—or leverage those provided to you by your CCM tool—so that you can react proactively to any potential deficiencies uncovered.
Prerequisites for implementing a CCM system
The first prerequisite for implementing a CCM system is a centralized hub for managing data, documents, and controls. Access to control and compliance reports is an added benefit, as it further reduces the amount of time spent interpreting data generated from scattered controls.
Additionally, see that your system allows for high-frequency checks—risk experts consider hourly tests to be the most aligned with CCM best practices.
The most obvious requirement for implementing a CCM system is having a capable automation-enabled GRC solution. Depending on your workflow specifics, you can use one or more platforms to automate data imports, control tests, and report generation and connect everything into one cohesive system.
Ideally, CCM-friendly tools should support control monitoring across security frameworks and business domains. It also needs to integrate seamlessly with your existing system to present a holistic view of your GRC posture.
Set up continuous controls monitoring with Vanta
If you need a robust solution that streamlines numerous aspects of monitoring GRC programs, Vanta is a perfect choice. It offers an end-to-end, automation- and AI-enabled GRC suite with several features focused on continuous monitoring, most notably:
- Automated hourly tests with real-time alerts and actionable remediation instructions.
- Bi-directional integrations with ticketing systems to streamline collaboration with system owners.
- Hundreds of pre-built controls and the ability to create and import custom controls.
- Automated gap assessments that test entire sets of controls.
- Pre-built content to support 20+ security and compliance frameworks like:some text
- NIST CSF
- ISO 27001
- ISO 27017
- SOC 2
- GDPR
- Role-based access controls and automated reviews.
- Framework-specific control mapping as well as cross-mapping of controls to accelerate implementation of multiple frameworks.
Vanta goes beyond control monitoring and offers a dedicated Risk Management solution with features for automated risk scoring and reporting. The idea is to use a single solution to automate a chunk of your GRC processes, ensuring better productivity. With Vanta, you can seamlessly integrate risk management with CCM, ensuring a consistent view of the relationship between risks and controls.
Additionally, with Vanta’s Trust Center solution, you can build a centralized platform to demonstrate your compliance and security efforts to stakeholders. It helps you translate all your CCM work into demonstrable results.
Want to see Vanta’s practical CCM applications specific to your company? Schedule a custom demo.
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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
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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
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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
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