The Security Program You Actually Need (Not the One Vendors Are Selling You)

A $50 million fintech startup and a $2 billion community bank walk into my office.

Both are convinced they need the same security program as JPMorgan Chase.

They don’t. Neither do you.

Most security advice assumes you’re an enterprise. Multi-million dollar budgets. Dedicated security teams. Infrastructure across 47 countries.

You’re not that. You’re trying to grow your business, meet compliance requirements, and not lose customer data. You need security that works at your actual size.

Here’s how to build it.

The Problem: One-Size-Fits-All Security

Every vendor pitch sounds the same.

“Enterprise-grade security.” “Industry-leading protection.” “Comprehensive visibility across your entire infrastructure.”

Cool. You have 40 employees and three people in IT.

The SOC 2 audit firm wants you to implement 127 controls. The compliance consultant sends you a 400-page framework assessment. The managed security provider quotes you $15K/month for 24/7 monitoring.

Meanwhile, you’re trying to figure out if you can afford to hire another developer.

This is the gap. Security guidance comes from people who think “small” means 5,000 employees instead of 50,000.

Let me tell you what you actually need.

What Actually Matters at Your Size

I’ve built security programs for organizations at every stage. From 10-person startups to multi-billion dollar enterprises.

Here’s what moves the needle when you’re not Fortune 500:

1. Know What Data You Have (And Who Can Access It)

Most breaches happen because organizations have no idea:

• What sensitive data they actually have
• Where it lives (cloud, laptops, that file share nobody’s looked at in three years)
• Who has access to it
• Whether that access still makes sense

You don’t need a $200K data discovery platform. You need a spreadsheet that lists:

• Customer data locations
• Employee data locations
• Financial data locations
• Who has access
• When you last reviewed that access

Update it quarterly. Actually do the access reviews.

This beats 90% of organizations. For more on why this matters, read about shifting from system-centric to data-centric security.

2. Control Who Gets In

Identity and access management isn’t sexy. It’s also the difference between “minor incident” and “catastrophic breach.”

Minimum viable IAM:

• Multi-factor authentication (MFA) everywhere. No exceptions.
• Single sign-on (SSO) for as many apps as possible
• Password manager for the team (1Password, Bitwarden, whatever)
• Clear process for adding/removing access when people join or leave

You can do this for under $10/user/month. If you can’t afford that, you can’t afford to be in business.

For community banks: Yes, examiners care about this. It’s in every single assessment framework. Do it right once, document it, reference it forever.

For fintech startups: Enterprise customers will ask about your authentication in every security questionnaire. Get this right before you chase big deals.

3. Have a Plan When Things Break

Not if. When.

Every organization gets hit eventually. Ransomware. Phishing. Vendor breach. Doesn’t matter how good your security is.

What matters: do you know what to do when your CEO clicks the wrong link at 2am?

Your incident response plan doesn’t need to be 100 pages. It needs to answer:

• Who do we call first?
• How do we contain the damage?
• What do we tell customers?
• What are we legally required to report (and to who)?

Three pages that everyone’s actually read beats a binder nobody’s opened since 2019.

Test it once a year. Tabletop exercise. Pizza and hypotheticals. Takes two hours.

I wrote about why most IR plans fail - don’t let yours be one of them.

4. Vet Your Vendors (But Don’t Go Crazy)

You’re not going to security-review every SaaS tool. You don’t have time and it’s not worth it.

Smart vendor risk management:

Critical vendors (access to customer data, financial systems, core infrastructure):

• Get their SOC 2 report
• Review their security documentation
• Document why you trust them

Everything else:

• Check if they have basic security (HTTPS, reasonable privacy policy)
• Document why they’re low risk
• Move on

Most questionnaires ask if you have a vendor risk program. “Yes, we review critical vendors and document our risk acceptance for others” is a valid answer.

For more on responding to these requests, read how to handle security questionnaires.

5. Back Up Your Data (And Actually Test Restores)

Backups are boring until you need them.

Then they’re the only thing that matters.

Minimum viable backup strategy:

• Automated daily backups
• Offsite/cloud storage (separate from your primary systems)
• Test restores quarterly
• Document what you’re backing up and why

The backup you’ve never tested is the backup that will fail when you need it.

6. Train Your Team (Without Making Them Hate You)

Security awareness training has a reputation problem. Usually because it’s terrible.

Hour-long videos about phishing. Annual compliance modules everyone clicks through while checking email. Pointless.

Better approach:

• Monthly 5-minute security tips (relevant to your actual threats)
• Phishing simulations with coaching, not punishment
• Clear guidance on who to contact when something seems weird
• Make it easy to report problems without fear

Your team is your first line of defense. Treat them like partners, not problems.

What You Can Skip (For Now)

Here’s what enterprise security teams have that you don’t need yet:

Security Operations Center (SOC). Those 24/7 monitoring teams cost $10K-30K/month. You probably don’t generate enough security events to justify it.

Instead: Get basic monitoring (cloud provider logs, endpoint detection) and review alerts weekly. Escalate to an outside team if something looks serious.

Penetration testing every quarter. Once a year is fine. More if you’re growing fast or handling high-risk data.

A 400-page security policy manual. Nobody reads it. Write 10 pages of clear policies that people will actually follow.

Dedicated security team. Fractional CISO or security consultant works fine until you’re past Series B or $1B in assets. (Here’s how to tell if you actually need security leadership.)

The latest “AI-powered” security tool. Most of you don’t need AI in your security stack. You need consistent implementation of basic controls.

Red Flags That It’s Time to Level Up

How do you know when you’ve outgrown “good enough” security?

For community banks:

• Examiner findings that aren’t going away
• Acquisition target (buyers will rip apart your security)
• Moving to $5B+ in assets
• Launching new digital banking services
• M&A activity (buying or selling)

For fintech startups:

• Losing deals because of security gaps
• Series B+ funding (investors want real security)
• Enterprise customers requiring SOC 2 Type II
• Handling regulated data (health, financial, PII at scale)
• Security incidents becoming a pattern, not a one-off

If you’re hitting these milestones and still running on basic security, you’re taking real risk.

The Community Bank Reality Check

Community banks get security advice written for Chase and Wells Fargo.

You’re not Chase. You have:

• 200-500 employees (not 200,000)
• $500M-$5B in assets (not $500B)
• 3-10 people in IT (not 3,000)
• One vendor relationship (core banking system) that dictates most of your tech stack

Your examiners don’t care if you have the same tools as Chase. They care if you:

• Know your risks
• Have controls that match those risks
• Actually follow your own policies
• Can prove it

That’s it. Everything else is negotiable.

For more on dealing with examiner expectations, read about handling risk assessments without panic.

The Fintech Startup Reality Check

Startups get different (but equally useless) advice.

“Move fast and break things” doesn’t work when “things” includes customer financial data. But “implement enterprise security before you have product-market fit” will kill you just as dead.

Here’s the balance:

Pre-Series A: Basic hygiene (MFA, backups, access controls). Document what you’re doing. Don’t overthink it.

Series A-B: Get SOC 2 if customers are asking. Build your foundation. Plan for scale.

Series B+: Hire security leadership. Build the program for real. You can’t fake it anymore.

The mistake I see: startups treating security like homework they can catch up on later. You can’t. The time to fix security is before the breach, not after.

Need help figuring out what “good enough” security looks like for your stage? That’s literally what fractional CISOs do.

What to Do If You’re Already Drowning

Maybe you’re reading this thinking: “We’re past the basics and still underwater.”

Here’s the triage:

Week 1: Stop the bleeding

• Enable MFA everywhere (seriously, do this today)
• Change all shared passwords
• Review who has admin access to critical systems
• Document your biggest security gaps

Week 2-4: Build the foundation

• Get your data inventory started
• Write a basic incident response plan
• Set up automated backups
• Schedule vendor reviews for critical systems

Month 2-3: Create sustainable process

• Quarterly access reviews
• Monthly security check-ins with leadership
• Annual testing (IR plan, backups, vulnerabilities)
• Pick one thing to improve each quarter

You can’t fix everything at once. Pick the biggest risk, fix it, move to the next one.

The Bottom Line

You don’t need Fortune 500 security.

You need security that:

• Actually works with your resources
• Scales as you grow
• Satisfies auditors and customers
• Doesn’t slow down the business

Start with the basics. Get them right. Add complexity only when you need it.

And whatever you do, don’t let vendors convince you that “good enough” security requires six figures and a dedicated team.

It requires clear thinking, consistent execution, and knowing the difference between security that matters and security theater.

Everything else is negotiable.

Need Help Right-Sizing Your Security Program?

Most organizations waste money on security they don’t need while ignoring gaps that actually matter.

I help community banks and fintech startups build security programs that work at their actual size and stage. No enterprise nonsense. No vendor theater. Just practical security that passes audits and protects your business.

Let’s talk about what you actually need →

Related Articles

For more on building practical security programs:

• Stop Protecting Systems, Start Protecting Data - Why data-centric security matters more than infrastructure
• When Your Bank Examiner Says ‘Risk Assessment’ - Reality check for community banks
• How to Get SOC 2 Certified - What startups actually need
• You Think You Might Need a CISO? - When security leadership matters

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