SOC 2 Accelerator : Red Flags

This week, I’m diving into the highlights and results from last week’s gap assessment with three companies. If you’re new to this series, check out last week’s issue to review the SOC 2 security questions and try the assessment yourself.

The “Data Company” Case Study

This week’s spotlight is on the “Data Company.” They rely entirely on a third-party development company, with no in-house developers. While this setup helps them stay lean, it’s challenging for SOC 2 compliance. Why? Because all development-related processes and assets are managed externally.

To tackle this, we redefined their processes and policies, putting control of critical SOC 2 controls back in the company’s hands.

The Importance of the SDLC

One essential policy we implemented was a Software Development Life Cycle (SDLC) document. This is the backbone of SOC 2 compliance for software development. It defines how to handle development, infrastructure, testing, and maintenance effectively.

Like many startups, this company initially focused on building features and finding traction (as they should!) but hadn’t prioritized processes. Once you hit traction, though, investing in security isn’t optional—it’s essential.

The Red Flags I Found

The gap assessment uncovered some significant issues:

• 🚩 Single Branch Development: Developers were working directly on the main branch without any version control or reviews.

• 🚩 No Infrastructure as Code (IaC): Server changes were made manually, with no records of what was done.

• 🚩 No Backups: For a data company, this is particularly risky.

• 🚩 Live = Dev Environment: Development, testing, and debugging were all happening in the live environment, while users actively used the system.

• 🚩 No Documentation: Neither the code nor processes were documented. (Apparently, the “clean code” philosophy means no comments either!)

Why I’m Excited About This?

At first glance, this might seem like a disaster—but I see a huge opportunity. Over my 15+ years in software projects, I’ve learned that companies like this stand to gain the most from creating tailored processes and implementing the right tools.

This is what I specialize in: building practical solutions that work for your business (not just consulting! I can also implement). No compliance automation tool can replicate this level of customization and understanding, and I love helping companies like this transform their approach.

Lightweight SDLC and Tooling for a Small Startup

For this small startup, implementing a heavy CI/CD pipeline would strain both their budget and agility. Instead, I designed a lightweight yet SOC 2-compliant pipeline that balances efficiency with affordability. Here’s the approach:

Proposed SDLC and Tooling

1. Simple CI/CD Pipeline

   • Separate dev, staging, and live branches for code management.

   • Strictly segregated Dev and Live environments to avoid overlap.

2. Repositories

   • A dedicated code repository for application development.

   • An IaC (Infrastructure as Code) repository to manage infrastructure configurations.

3. Change Control

   • No direct changes in the live environment: All code and infrastructure modifications must go through the CI/CD pipeline. No “hotfixes” allowed!

4. Documentation

   • Establish a single source of truth for all documentation (e.g., Confluence Wiki).

5. Access Control

   • Enforce Strict Role-Based Access Control (RBAC) to manage permissions effectively.

6. Security Enhancements

   • Integrate static code scanning with tools like SonarQube.

   • Implement daily backups and conduct regular backup testing.

   • Vulnerability scanning using AWS Inspector.

   • Track all vulnerability issues in GitHub.

7. Approval and Review Policies

   • Require two developer reviews for all code and infrastructure changes.

   • Releases from staging to live can only proceed with explicit company approval.

8. Monitoring and Logging

   • Set up centralized logging and monitoring with AWS CloudTrail and CloudWatch for audit trails and debugging.

   • Implement uptime monitoring and alerting using Datadog and AWS CloudWatch.

What’s Next?

Next week, I’ll share more details on implementing these changes, specific tools, and how this revamped SDLC put the company on a secure and compliant path. Stay tuned!