New York

Software built for New York companies, with the record a review asks for written as the work runs

Three things before anything else.

  • When we are at our desks

    We work 10:00 to 19:00 IST, which is 04:30 to 13:30 UTC.That holds all year, because India does not change its clocks. North American teams sit outside that window for most of their day.

  • Where your code lives

    Your repositories and your cloud accounts, from day one.Our software engineers are in India.

  • Who is in New York

    Nobody on this team is in New York.If you need someone physically in the room, say so in the first message and we will tell you straight away that we are the wrong firm for it.

Tell us what you are building

We will reply within one business day with a technical person on the call.

Tell us what you are building

How we handle what you send is set out in our privacy notice.

Three situations we get called into

  • The team is already full

    You run technology and the people you have cannot absorb this build on top of what they already carry. The date has been said out loud in a room where you cannot un-say it.

  • The signature is yours

    You are the one who signs for this. Nobody in the building can tell you whether the choice is going well. Every question you ask, you ask knowing you cannot check the answer yourself.

  • Somebody else built it first

    An outside firm built the system you now run, and may still be running parts of it. You are answerable for all of it either way, including the parts nobody documented.

What you are actually buying

Handing out the work does not hand out the answerability

For part of the financial sector in New York, answerability for a software vendor is not a feeling. It is a filing.

The New York Department of Financial Services publishes a cybersecurity regulation, 23 NYCRR Part 500. It binds covered entities, which means firms licensed or registered with that department, rather than every company in New York. If you hold no such licence or registration, Part 500 does not reach you. None of this is legal advice about your situation.

Reading Part 500 as amended effective 1 November 2023: under section 500.17(b)(2) the annual filing is signed by the covered entity's highest-ranking executive and its chief information security officer. Two signatures, both personal, covering work an outside firm may have done most of.

Section 500.17(b)(3) adds a retention rule. Records supporting that filing are held for five years and made available to the department for examination on request. Nothing has to be scheduled for that request to arrive. Five years is longer than most engagements run, so the material has to still make sense to somebody who was never in the room when it was written.

A comment on Hacker News puts the same thing without the citation: in my experience, you are responsible, regardless. It doesn't matter who wrote the code originally.

Four questions the rule asks about a software vendor

Part 500 requires a written policy covering guidelines for due diligence and contractual protections relating to third party service providers. Section 500.11(b) then names four things for that policy to address, to the extent they apply. Every one of them is a question about the firm you hire. Put all four to us, and to whoever else is bidding, in the same form.

What section 500.11(b) asks about a software vendor, and who can answer each part.
What the rule asks aboutWho can actually answer it
Section 500.11(b)(1): the provider's access controls, including its use of multi-factor authentication.The provider, and nobody else. You cannot document a control that operates inside somebody else’s estate.
Section 500.11(b)(2): how the provider encrypts nonpublic information, in transit and at rest.The provider, in writing, before you sign anything.
Section 500.11(b)(3): notice to you of a cybersecurity event.The provider has to agree to it. Ask to see the exact wording.
Section 500.11(b)(4): representations and warranties covering the provider's own policies.The provider. A representation is a statement by the party you are relying on.

The third row moves fastest. Since 1 November 2023 an incident at a third party service provider can start your own 72 hour clock under section 500.17(a)(1), and that clock runs from the point you determine an incident has occurred, not from the moment it happened. It does not catch everything: 500.1(g) names the kinds that count, which are the ones requiring you to notify a supervisory body, or with a reasonable likelihood of materially harming a material part of your normal operations, or deploying ransomware in a material part of your systems. The amendment narrowed this to that defined set rather than widening it to every event. You cannot see inside a provider's systems, so the notice term in the contract is the mechanism you control. Ask for that wording before you sign, because after an event it is somebody's goodwill. Note also that the duty here is yours throughout. No provider, us included, is bound by Part 500 on your behalf. Part 500 binds covered entities, which means firms licensed or registered with the Department of Financial Services, not every company in New York. None of this is legal advice about your situation.

What written down work buys, measured

The DORA research programme at Google Cloud put this to 1,200 working professionals for its Accelerate State of DevOps 2021 report. Teams reporting high quality internal documentation were several times more likely to report each of these. Site Reliability Engineering is the discipline of running a system to a stated reliability target rather than to whoever is awake.

Show data table
1,200 working professionals worldwide, surveyed in 2021, self-reported. These are odds ratios against teams whose documentation is not high quality, drawn here as 1.0. An odds ratio is not a probability ratio. The report scores documentation quality on three stated dimensions rather than leaving it to taste.
Dimension Teams with high quality internal documentation Teams whose internal documentation is not high quality
Implement security practices 3.8 1
Implement Site Reliability Engineering practices 3.5 1
Fully use the cloud 2.5 1
Meet or exceed reliability targets 2.4 1

The report's own model runs one step at a time. Documentation quality predicts how well a team implements technical practices, and implementing those practices is what predicts improvement. About a quarter of those 1,200 people said their own internal documentation was good quality.

Figure 1,200 working professionals worldwide, surveyed in 2021, self-reported. These are odds ratios against teams whose documentation is not high quality, drawn here as 1.0. An odds ratio is not a probability ratio. The report scores documentation quality on three stated dimensions rather than leaving it to taste. DORA and Google Cloud, Accelerate State of DevOps 2021, page 2.

The order the work happens in, and what each step leaves behind

  1. Discovery

    We agree what the system has to do, and what it must not do. The constraints your own review will apply get written down here, rather than found later.

  2. Business requirements

    The business intent written down, in a business requirements document. Our business analysis team writes it.

  3. Functional requirements

    A functional requirements document: what the software does, feature by feature.

  4. Software requirements

    The software requirements specification, which is what the finished build gets measured against.

  5. Technical requirements

    The Technical Requirements Specification. Architecture decisions are documented here, so your compliance team can verify the design intent. The technical team carries it forward into delivery.

  6. Milestone planning

    Every milestone gets exit criteria, written down, before anyone starts on it.

  7. Execution

    Every change goes through code review by a senior software engineer. We use GitFlow, a branching model for releases, and unit tests, integration tests and continuous integration gate every merge.

None of that is written afterwards to satisfy a review. It is what the work leaves behind while it runs. Answering a questionnaire is then mostly a matter of finding the right file.

Ownership

Where your code lives, starting on the first day

From day one, every line of code is your intellectual property.

Code lives in your repositories. Deployments live in your cloud accounts. Any documentation we produce is yours to keep. If you offboard us, you keep everything, including the operational runbook. The reason for putting that on day one is the case nobody plans for, which is an engagement that ends early.

If you already have your own Git hosting, cloud accounts and storage, we work inside them. If you do not have them, we provision them, set them up, and hand you the keys. The accounts are yours either way, so there is nothing to negotiate about access later.

After launch there are two ways to keep going. An annual maintenance contract covers ongoing maintenance and growth work. A lean mode arrangement covers lighter ongoing support. Both run through the same change note process as the build.

One thing this is not. Neither Part 500 nor the SHIELD Act says anything about who owns the code, about source escrow, or about assigning intellectual property. Nothing above is required of us by New York. It is how we choose to work, and you should hold us to it on that basis rather than on a regulator's.

That is how we choose to work, and it is worth being exact about why. Neither Part 500 nor the New York SHIELD Act says anything about who owns source code. This is a commercial arrangement we offer, not a rule anyone imposed on us.

Who answers when something breaks, and how fast

  • Business hours are Monday to Friday, 10:00 to 19:00 IST.
  • The most urgent issues, the ones we log as P1: four working hours.
  • The tier below that, P2: twenty-four working hours.
  • Everything else: seventy-two working hours.
  • Those targets are for acknowledgement by a named person who engages with the issue, not for resolution. How long a fix takes depends on what the issue turns out to be. We do not commit to that.

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What it does not prove: no New York regulatory review is a variable in our records of that work. Neither is a transition away from a previous vendor. It says nothing about how long the work took, in what order it ran, or what was built alongside it. It is evidence that the way of working above produces a system a business depends on, and nothing beyond that.

What to send the person who has to approve it

Forward this part

Atyantik Technologies

  • What the firm does. Atyantik Technologies builds and rebuilds software systems.
  • Where the people are, and when. The software engineers are in India and work 10:00 to 19:00 IST, which is 04:30 to 13:30 UTC.
  • Where the code lives. Client code lives in the client's own repositories and cloud accounts from the first day of work.
  • What happens next. An answer comes back within one business day, with a technical person on the call.

There are two shapes of engagement. A dedicated cross-functional team working inside your sprints, for multi-month work whose scope keeps moving. Or team formation on demand, for a specialist capability gap, a scale-up, or a vertical you cannot staff internally.

Scope is agreed in writing before anything starts. Every change after that goes through a documented change note, with time, effort and cost laid out before approval. Nothing in the build moves on a re-scope you have not explicitly accepted.

Four things move the size of the work. Which shape it is, how long it runs, what mix of skills it needs, and what the review on the other side asks for. Name those four in the first message and the first answer can be specific.

Send the first message

One business day, and a technical person on the call.

How we handle what you send is set out in our privacy notice.

When this is the right arrangement, and when it is not

  • The work is a build or a rebuild you want done, rather than seats you want filled.

  • A written handoff is already normal where you work, so documents are not extra effort imposed on anybody.

  • You want the material a review will ask for to exist before it asks.

  • The live time you need is a sync you can name. A project coordinator can host it, or an overlap shift can be arranged on request. Ask at scoping and it is part of the arrangement.

Where we are the wrong call

  • You want developers hired directly onto your own team, working under your own management. That is a different arrangement, and it is the one to ask us about instead.

    See how hiring developers directly works

  • You need a vendor that holds the certification itself. We do not hold SOC 2, GDPR, or HIPAA certifications ourselves. We engineer systems that pass your audits. We document architectural decisions in the Technical Requirements Specification, so your compliance team can verify the design intent. If your engagement needs a certified vendor, we will tell you upfront and refer where appropriate.

    Ask us for a referral

  • You need someone physically in the room in New York. Nobody on this team is, and we would rather say that now.

    Tell us in the first message

  • Your busiest hours need continuous cover rather than a scheduled sync. Ours end at 19:00 IST. If your busiest hours are a New York afternoon, our working day has already finished by then, in either half of the year.

    Tell us the hours the work needs

Questions that come up before the first call

What hours does Atyantik actually work?
Monday to Friday, 10:00 to 19:00 IST, which is 04:30 to 13:30 UTC, all year. India does not change its clocks, so that window never shifts with daylight saving. North American teams sit outside it for most of their day. Work gets scheduled around that rather than pretending otherwise.
Who answers when something breaks, and how fast?
Atyantik works business hours, Monday to Friday, 10:00 to 19:00 IST. The targets are four working hours for the most urgent issues, and twenty-four working hours for the tier below that. Everything else is seventy-two working hours. Those targets are for acknowledgement by a named person who engages with the issue, not for resolution. How long a fix takes depends on what the issue turns out to be, and is not committed to.
Who owns the code, and what does a client keep if the arrangement ends?
From day one every line of code is the client's intellectual property. Code lives in the client's repositories. Deployments live in the client's cloud accounts. Any documentation Atyantik produces is theirs to keep. On offboarding they keep everything, including the operational runbook. A client with no Git hosting or cloud accounts of their own gets them provisioned and set up. The keys are handed over.
What happens when the scope changes?
Scope is agreed in writing before work starts. Every change after that goes through a documented change note, with time, effort and cost laid out before approval. Nothing in the build moves on a re-scope the client has not explicitly accepted.
Does Atyantik hold SOC 2 or similar certifications?
No. Atyantik does not hold SOC 2, GDPR, or HIPAA certifications itself. It engineers systems that pass its clients' audits. It documents architectural decisions in the Technical Requirements Specification, so a compliance team can verify the design intent. Where an engagement needs a certified vendor, Atyantik says so upfront and refers where appropriate.
What can a client hand to their own security review?
A build here produces four documents, in order. First a business requirements document, then a functional requirements document. Then a software requirements specification. Last, a Technical Requirements Specification, which carries the architecture decisions. Each milestone has documented exit criteria. Every change goes through code review by a senior software engineer. Unit tests, integration tests and continuous integration gate every merge. The code sits in the client’s own repositories from day one, so the evidence is already on their side of the line. Where a review is driven by 23 NYCRR Part 500, that regulation binds covered entities, meaning firms licensed or registered with the New York Department of Financial Services, and the duty under it stays with them rather than moving to a provider. None of this is legal advice about any particular situation.
Is anyone from Atyantik in New York?
No. Nobody on this team is in New York and Atyantik has no office there. The software engineers are in India. Where a project needs somebody physically in the room, say so in the first message. It gets answered before anything is agreed.
Does the New York cybersecurity regulation apply to every company here?
No. 23 NYCRR Part 500 binds covered entities. That means firms licensed or registered with the New York Department of Financial Services, not every company in the state. Section 500.19(a) grants some smaller entities a limited exemption, and limited is the operative word. It exempts an enumerated list of sections. Section 500.11, the third party service provider policy, and section 500.17, the annual filing and its five year records, are not on that list. This is not legal advice about any particular situation.

Tell us what you need

We will reply within one business day with a technical person on the call.

Name the work, the date you are working to, and what your own review will ask you for. Then the first answer can be specific instead of general.

If we are not the right firm for it, you will hear that in the same reply.

Tirth Bodawala, Chief Technology Officer of Atyantik Technologies
Tirth BodawalaChief Technology Officer
  • From day one, every line of code is your intellectual property.
  • Code lives in your repositories. Deployments live in your cloud accounts.
  • Business hours are Monday to Friday, 10:00 to 19:00 IST.

How we handle what you send is set out in our privacy notice.