Security & Compliance
Direct experience initiating due diligence and securing third-party audits
I've directly initiated due diligence and secured third-party audits for each of the frameworks below. The path to compliance follows a common pattern across all of them: gap analysis against the applicable control set, risk assessment and treatment planning, policy and procedure development, cross-functional evidence collection, vendor and third-party reviews, internal audit, and coordination with an accredited certification body or regulator. The work is documentation-heavy, cross-functional, and time-sensitive. Done right, it ends with a signed audit report, an authorization, or a certification your customers and partners can rely on.
Compliance Frameworks
AICPA-defined examination across five Trust Service Criteria: Security, Availability, Processing Integrity, Confidentiality, and Privacy. A Type II report covers a 6-12 month operating period and is the standard enterprise buyers expect before signing contracts.
What securing this audit means
- ·Scope definition and Trust Service Criteria selection
- ·Readiness gap assessment against AICPA criteria
- ·Control implementation: access management, encryption, incident response
- ·Evidence collection across the full observation period
- ·Third-party CPA firm fieldwork and control testing
- ·Issued SOC 2 Type II report shared under NDA with prospects
U.S. federal law requiring covered entities and business associates to safeguard Protected Health Information (PHI). The Security Rule mandates administrative, physical, and technical safeguards for electronic PHI. Any vendor touching patient data must execute a Business Associate Agreement (BAA) and complete a formal Security Risk Analysis.
What securing this audit means
- ·HIPAA Security Risk Analysis covering all ePHI systems
- ·Policies and procedures for all 18 Security Rule safeguard standards
- ·BAAs executed with every subcontractor that touches ePHI
- ·Technical safeguards: encryption at rest and in transit, audit logging, access controls
- ·Workforce training and documentation
- ·Engagement with HIPAA compliance assessor for formal assessment
Required for any cloud service provider whose platform processes federal agency data. Standardizes security assessment, authorization, and continuous monitoring against NIST SP 800-53 controls. A Moderate baseline covers the majority of SaaS products and requires authorization from a sponsoring federal agency before the service can be deployed.
What securing this audit means
- ·Engagement with a FedRAMP-accredited Third Party Assessment Organization (3PAO)
- ·System Security Plan (SSP) documenting all controls (often 300-500+ pages)
- ·Security Assessment Report (SAR) with 3PAO
- ·Remediation of all High and Medium findings before authorization
- ·Authorization package submission to sponsoring agency
- ·Ongoing continuous monitoring: monthly reports, annual assessments, significant change reporting
U.S. federal law governing access to and use of student records. EdTech vendors operating under the School Official exception must limit data use to the original educational purpose, prohibit re-disclosure, and maintain security controls protecting student Personally Identifiable Information (PII). Many states layer additional requirements on top of FERPA.
What securing this audit means
- ·Data Processing Agreement (DPA) with each educational institution
- ·Data minimization: collect only what is necessary for the educational purpose
- ·No data selling, no targeted advertising using student data
- ·Security controls aligned with NIST or ISO 27001 to protect student records
- ·Contractual guarantees covering data deletion and breach notification
- ·Review of applicable state student privacy laws (SOPIPA in CA, NY Ed Law 2-d, etc.)
Private standard maintained by Visa, Mastercard, Amex, Discover, and JCB. Version 4.0 (effective March 2025) covers 12 requirements spanning network security, cardholder data protection, vulnerability management, and access control. Level 1 merchants and service providers require an annual QSA audit. Scope reduction through tokenization and network segmentation is the primary cost-reduction lever.
What securing this audit means
- ·Cardholder data environment (CDE) scoping and scope reduction strategy
- ·Engagement with Qualified Security Assessor (QSA) for Level 1 compliance
- ·Network segmentation to isolate CDE from broader infrastructure
- ·Tokenization and encryption of cardholder data
- ·Annual penetration testing and quarterly vulnerability scans
- ·Report on Compliance (ROC) or SAQ attestation
SOX Section 404 requires public companies to attest to the effectiveness of internal controls over financial reporting. Vendors whose platforms are part of a customer's financial close process (ERP, accounting, revenue recognition) must provide a SOC 1 Type II report (SSAE 18 standard) so customers can satisfy their external auditors. SOC 1 is the audit mechanism vendors use to support customer SOX compliance.
What securing this audit means
- ·SOC 1 Type II audit under SSAE 18 standard
- ·IT General Controls (ITGC) documentation: change management, access provisioning, backup and recovery
- ·Control mapping to financial transaction flows in scope for customer SOX testing
- ·Coordination with customer's external auditors during SOX testing periods
- ·Annual report cadence aligned to customer fiscal year-end
Applies to banks, credit unions, mortgage companies, insurance companies, financial advisors, and fintech vendors acting as service providers. The updated Safeguards Rule (effective June 2023) specifies technical requirements including designated Qualified Individual oversight, written information security program, access controls, encryption, MFA, annual penetration testing, and board-level reporting.
What securing this audit means
- ·Gap assessment against updated Safeguards Rule requirements (June 2023)
- ·Designation of Qualified Individual (QI) to oversee information security program
- ·Written information security program and risk assessment
- ·Implementation of required technical safeguards: MFA, encryption, access controls
- ·Annual penetration testing and vulnerability assessments
- ·Board-level annual reporting cadence
NAIC model law adopted by most U.S. states, modeled closely on NY DFS Cybersecurity Regulation (23 NYCRR 500). Requires insurance carriers and their service providers to maintain an Information Security Program, conduct annual risk assessments, oversee third-party vendors, and report material cybersecurity events within 72 hours. NY DFS amendments (2023) added CISO accountability, MFA mandates, and ransomware controls.
What securing this audit means
- ·Regulatory gap analysis against applicable state adoption of NAIC model
- ·Information Security Program with CISO or equivalent oversight
- ·Annual risk assessment and penetration testing
- ·Third-party vendor security assessment program
- ·Incident response plan with 72-hour regulatory notification procedures
- ·Annual certification of compliance to state insurance commissioner
The leading international standard for establishing, implementing, and maintaining an Information Security Management System. Certification requires a two-stage audit by an accredited certification body and demonstrates systematic control over information security risks across an organization.
What securing this audit means
- ·Scoping ISMS boundaries across the organization
- ·Risk assessment and risk treatment plan
- ·Control selection from Annex A
- ·Internal audit and management review
- ·Stage 1 and Stage 2 audits with accredited certification body
- ·Ongoing surveillance audits to maintain certification
ISO 27701 builds on ISO 27001 to add privacy-specific controls and requirements aligned with GDPR, CCPA, and other privacy regulations. Organizations establish roles as data controllers, data processors, or both. Certification provides third-party evidence of privacy governance maturity.
What securing this audit means
- ·Mapping data flows and data subject roles (controller vs. processor)
- ·Gap analysis against GDPR and CCPA obligations
- ·PIMS policy development and integration with existing ISMS
- ·Data subject rights procedures and consent management
- ·Surveillance audit schedule to maintain certification
ISO 42001 (published 2023) establishes requirements for an AI Management System (AIMS), covering the responsible development and use of AI. Directly relevant for AI product companies, it addresses transparency, bias controls, human oversight, and AI-specific supplier due diligence. Certification demonstrates organizational accountability for AI risk.
What securing this audit means
- ·AI risk classification and impact assessment
- ·Transparency and explainability documentation
- ·Bias and fairness controls
- ·Human oversight mechanisms for AI decisions
- ·AI-specific supplier due diligence
- ·Conformity assessment with accredited certification body
ISO 9001 specifies requirements for a Quality Management System focused on consistently meeting customer and regulatory requirements. Certification requires documented processes, measurable quality objectives, and periodic internal and external audits. It is widely required by enterprise customers as a baseline quality assurance credential.
What securing this audit means
- ·Process mapping and quality manual development
- ·Measurable quality objectives and performance indicators
- ·Corrective action procedures
- ·Internal audit program
- ·Management review cadence
- ·Certification body selection and Stage 1 and Stage 2 audits
The EU GDPR applies to any organization worldwide that processes the personal data of EU residents. It mandates lawful bases for data processing, enforceable data subject rights, Data Protection Impact Assessments for high-risk processing, and a 72-hour breach notification requirement. Non-compliance carries fines up to 4% of global annual revenue.
What securing this audit means
- ·Lawful basis documentation for each processing activity
- ·Data subject rights workflows: access, erasure, portability, and rectification
- ·Data Protection Impact Assessments (DPIAs) for high-risk processing
- ·Data Processing Agreements (DPAs) with all processors
- ·Breach notification procedures (72-hour requirement)
- ·Records of Processing Activities (RoPA) maintained and current
The CCPA (effective 2020) and its 2023 update, the CPRA, give California residents rights to know, delete, correct, and opt out of the sale or sharing of their personal information. The CPRA added rights to limit use of sensitive personal information and created the California Privacy Protection Agency (CPPA) as a dedicated enforcement body.
What securing this audit means
- ·Consumer rights workflows: know, delete, opt-out, correct, and limit
- ·Data inventory mapping all personal information categories collected
- ·Privacy notice updates reflecting current data practices
- ·Opt-out mechanism implementation for sale and sharing of personal information
- ·Sensitive personal information opt-out and processing limitations
- ·Contractor agreement updates for CPRA compliance
Need a consultant who understands your compliance environment?