You Can’t Avoid This Forever
There’s a moment in every SaaS company’s growth when compliance shifts from “something we’ll deal with later” to “the thing blocking our biggest deal.” A prospect sends a security questionnaire. An enterprise customer asks for your SOC 2 report. A partner requires ISO 27001 certification before integration.
If you’re at that moment, the good news is that building a compliance program doesn’t have to be overwhelming. The bad news is that the longer you’ve waited, the more technical debt you’ve accumulated, and the more painful it’ll be to retrofit security practices into an organization that grew without them.
Here’s how to approach it methodically.
Step 1: Understand What You Actually Need
Before you start implementing anything, figure out what your market requires:
What are customers asking for? Talk to your sales team. What comes up in procurement? SOC 2? ISO 27001? HIPAA? The answers tell you which frameworks to prioritize.
What does your product handle? If you process health data, HIPAA matters. If you process payment data, PCI DSS matters. If you process personal data of EU residents, GDPR matters. Your data determines your regulatory obligations.
Where are you selling? US enterprise buyers want SOC 2. International buyers want ISO 27001. Government buyers want FedRAMP or StateRAMP. Your market determines your framework priority.
Most early-stage SaaS companies need SOC 2 first, followed by ISO 27001 as they expand internationally. Start there unless your specific market demands something different.
Step 2: Assess Where You Stand
Before building anything new, inventory what you already have. Most SaaS companies have more security in place than they realize; it’s just informal and undocumented.
Ask yourself:
- Do you use SSO and MFA for your internal tools?
- Is your production infrastructure in a managed cloud environment (AWS, GCP, Azure)?
- Do you have code reviews and a CI/CD pipeline?
- Is your data encrypted in transit (TLS) and at rest?
- Do you have any access control policies, even informal ones?
- Do you log production access and changes?
If you answered yes to most of these, you have a foundation. The work is formalizing it, filling gaps, and documenting everything.
Step 3: Build Your Policy Foundation
Policies are the documented commitments that your compliance program is built on. You don’t need dozens. Start with the essentials:
- Information Security Policy: Your overarching commitment to security, roles, and responsibilities
- Access Control Policy: How you manage and review access to systems and data
- Change Management Policy: How changes to production systems are reviewed, approved, and deployed
- Incident Response Policy: How you detect, respond to, and learn from security incidents
- Data Classification and Handling Policy: How you categorize and protect different types of data
- Acceptable Use Policy: What employees can and can’t do with company systems
- Vendor Management Policy: How you evaluate and monitor third-party security
- Business Continuity/Disaster Recovery Policy: How you maintain operations during disruptions
Write policies that describe what you actually do (or will do). Aspirational policies that nobody follows are worse than no policies at all, because they create audit findings.
Step 4: Implement Your Core Controls
With policies as your guide, implement the controls that every SaaS compliance program needs:
Identity and Access Management
- Enforce MFA on all internal systems and production access
- Implement SSO where possible
- Follow least-privilege: give people access only to what they need
- Conduct quarterly access reviews
- Offboard access promptly when people leave
Change Management
- Require code reviews for all production changes
- Use CI/CD with automated testing
- Separate development and production environments
- Log all production changes
Encryption
- TLS for all data in transit
- Encryption at rest for all datastores containing sensitive data
- Manage encryption keys properly (use your cloud provider’s KMS)
Logging and Monitoring
- Log access to production systems
- Log security-relevant events (authentication, authorization failures, configuration changes)
- Set up alerts for suspicious activity
- Retain logs for at least one year
Vulnerability Management
- Run regular vulnerability scans on your infrastructure
- Keep dependencies up to date
- Have a process for triaging and remediating vulnerabilities by severity
Incident Response
- Document your incident response process
- Define severity levels and escalation procedures
- Practice your response (tabletop exercises)
- Have a communication plan for customers and regulators
Vendor Management
- Inventory your critical vendors (especially those with access to customer data)
- Review their security practices (SOC 2 reports, security certifications)
- Include security requirements in contracts
Step 5: Establish Evidence Collection
Compliance requires evidence that your controls are operating. Start collecting it from day one:
- Automated evidence where possible: screenshots from your cloud console, audit logs, CI/CD records, access review exports
- Recurring processes on a schedule: quarterly access reviews, annual risk assessments, regular vulnerability scans
- Organized storage: keep evidence organized by control and time period so it’s easy to retrieve during an audit
The biggest mistake companies make is building controls without evidence collection. When audit time comes, you spend weeks scrambling to prove that controls you’ve been operating for months actually existed.
Step 6: Conduct a Risk Assessment
Every compliance framework requires some form of risk assessment. Your first one doesn’t need to be elaborate:
- Identify your assets (systems, data, people)
- Identify threats and vulnerabilities relevant to each asset
- Assess likelihood and impact of each risk
- Document your current controls and their effectiveness
- Determine residual risk and decide on treatment (accept, mitigate, transfer, avoid)
This exercise forces you to think systematically about what could go wrong and whether your controls address the most important risks. It also produces a documented artifact that auditors will want to see.
Step 7: Prepare for Your First Audit
Once your controls have been operating for a reasonable period (3-6 months for SOC 2 Type II), you’re ready to engage an auditor:
- Select an auditor experienced with SaaS companies
- Share your control framework and evidence repository
- Conduct an internal readiness review to identify any gaps before the formal audit
- Coordinate with your auditor on scope, timeline, and evidence requirements
Your first audit will have findings. That’s normal. The goal isn’t perfection; it’s demonstrating a functioning security program with a commitment to improvement.
Common Mistakes
Buying a tool before building a program. GRC platforms are useful, but they don’t tell you what controls to implement or how to design your security program. Build the program first, then decide if automation helps.
Over-engineering from the start. You don’t need enterprise-grade GRC processes at 30 employees. Build what’s appropriate for your size and complexity, then grow it.
Writing policies nobody follows. Policies must reflect reality. If your policy says you do quarterly access reviews but you’ve never done one, you have a compliance finding, not a policy.
Ignoring the human side. Security awareness training, clear procedures for common situations (onboarding, offboarding, incident reporting), and leadership buy-in matter as much as technical controls.
Treating compliance as a one-time project. Your compliance program is ongoing. Controls need maintenance, evidence needs collection, risks need reassessment, and the program needs continuous improvement.
Building for Scale
The smartest move you can make when building your first compliance program is designing it to scale. That means:
- Build controls that satisfy multiple frameworks simultaneously
- Use a common control framework that maps to SOC 2, ISO 27001, and other standards
- Collect evidence in formats that work for multiple audits
- Document your processes in a way that supports framework expansion
This multi-framework approach saves enormous time and cost as your compliance requirements grow.
At Concerto, we help SaaS companies build compliance programs from the ground up, designed to satisfy immediate customer requirements while scaling to support future frameworks. Whether you need your first SOC 2 or a comprehensive multi-framework program, we build the foundation that grows with you. Schedule a consultation to get started.
