For information security & assurance professionals, managing third-party relationships has never been more crucial. In an era of digitization and globalization, businesses across all sectors rely on third-party vendors to expand operations, enhance services, and streamline the supply chain. This complex ecosystem has created the need for a broad and all-encompassing risk management process known as third-party risk management (TPRM).
While TPRM encompasses more than security risks, today’s key risks relate to a third party’s ability to safeguard its customers’ valuable data. Managing these specific security risks requires its own unique and comprehensive process. This process is known as third-party security risk management (TPSRM). We’ll use these terms interchangeably throughout the guide.
Over half of organizations were breached through third parties in the last 12 months (2022)
According to a recent study, 54% of organizations were breached through third parties in the last 12 months, highlighting the critical role of TPSRM in today’s interconnected landscape. A single lapse in a service provider’s security can lead to significant data breaches.
Regulatory bodies worldwide are shifting their focus on TPRM from a nice-to-have to a primary business imperative. Beyond compliance and prevention of cyberattacks, TPRM, with TPSRM at its heart, aim at safeguarding business continuity, protecting sensitive data, preserving reputations, and ensuring cyber resilience.
This comprehensive guide from SaltyCloud provides information security professionals a structured framework for building a robust third-party security risk management program. It covers establishing security requirements, conducting security assessments, managing inventories, involving stakeholders, mitigating and tracking risks, planning incident response, and crafting effective policies. Whether you’re a seasoned practitioner or new to TPRM, it offers practical techniques and valuable insights to underscore the criticality of managing third-party security risks.
Although terms like TPRM, TPSRM, TPCRM, SCRM, and VRM are often used interchangeably, each has its specific meaning. Understanding the differences between these terms is key to building the right kind of program.
SCRM refers to the identification, assessment, and mitigation of risks present in the supply chain. While it may encompass third-party risks, its broader scope touches upon various facets of the supply chain—from procurement and vendor selection to distribution and delivery. The goal is to ensure business continuity, even when potential disruptions (like a supplier going bankrupt or geopolitical tensions affecting shipping routes) emerge.
TPRM is the process of managing all risks associated with third-party relationships. It includes but is not limited to operational, financial, compliance, reputational, and cybersecurity risks. It’s a holistic approach considering the full spectrum of potential hazards from third-party interactions.
VRM, in many ways, overlaps with TPRM and TPSRM but is oriented explicitly toward vendors. It covers the entire vendor lifecycle, from onboarding to offboarding. Vendor risk management entails evaluating the risks associated with employing a particular vendor, monitoring the vendor’s risk profile, and ensuring the vendor meets all compliance requirements, operational standards, and security benchmarks.
TPSRM casts a wide net over security-related risks stemming from third-party relationships. Beyond the realm of IT, TPSRM ensures that these affiliates not only have appropriate security controls and ratings but also strictly adhere to compliance benchmarks. The scope of TPSRM is comprehensive, addressing potential vulnerabilities in data storage, transmission, and even physical security measures.
Third-party cybersecurity risk management (TPCRM) is a nuanced variation of TPSRM. While both frameworks share a core objective, TPCRM emphasizes an autonomous approach to continuously monitoring the cybersecurity health of third-party vendors. This might involve more rigorous endeavors like ongoing penetration testing and vulnerability assessments.
Managing third-party risks has never been more crucial. Here’s why:
➤ The growing interdependence of global businesses. As the world globalizes, businesses lean more on third-party vendors to drive success. This means more connections, more data-sharing, and, unfortunately, more potential entry points for threat actors.
➤ The shadow of growing regulations and threats. No industry is immune from regulatory compliance. With the increasing cyber threats and a tighter regulatory environment, it’s predicted that soon every industry will be bound by strict third-party security risk management requirements. In fact, according to Gartner, by 2024, 75% of the global population will have its personal data covered under privacy regulations.
➤ The real-world impact of security incidents. Cybersecurity threats aren’t just hypothetical. Supply chain attacks, a cyber threat, have morphed into a sophisticated and insidious menace. These attacks target the intricate mesh of connections between businesses and their suppliers, vendors, and third-party service providers.
These real-world examples offer a sobering reminder that no sector is immune to such threats. Beyond the apparent reputational damage, organizations are entangled in lawsuits, burdened with hefty fines, and incurring unforeseen costs.
The global average cost of a data breach touched an alarming $4.45 million in 2023, and shockingly, half of the breached organizations showed reluctance in augmenting their security investments.
IBM’s recent findings shed further light on the gravity of the situation. The global average cost of a data breach touched an alarming $4.45 million in 2023, and shockingly, half of the breached organizations showed reluctance in augmenting their security investments. Given the rising sophistication of supply chain attacks, such hesitancy is concerning.
As a result of an increase in third-party-related incidents, regulatory bodies worldwide have implemented or are in the process of introducing stricter third-party risk management regulations. Today’s organizations are multifaceted, handling various data types that often straddle more than one industry. For example, an academic medical center may deal with ePHI data, making it subject to HIPAA regulations, while also having to comply with PCI-DSS for payment processing and possibly CMMC for any defense-related contracts.
In the United States, several key data regulations require stringent information security standards and often necessitate TPSRM. These include but are not limited to, HIPAA, PCI-DSS, GLBA, Title 23 NYCRR Part 500, CCPA, VCDPA, GDPR, NERC CIP, FISMA, CMMC, ITAR, SOX, and FERPA. (These regulations are not confined to a single industry; instead, they often have overlapping domains, adding layers of complexity for organizations that must adhere to multiple regulatory frameworks.)
Regulatory compliance is overseen by various bodies, each with a unique focus and jurisdiction. These include agencies like the U.S. Department of Health and Human Services, PCI Security Standards Council, the Federal Trade Commission, the Federal Communications Commission, and federal banking regulators like the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the Federal Reserve Board, to name just a few. The landscape also extends to state-level entities such as the New York State Department of Financial Services or the California Attorney General’s Office and international bodies like the European Data Protection Board.
TPSRM is also an integral component of numerous security standards and certifications. This includes widely-recognized frameworks like FedRAMP, StateRAMP, TX-RAMP, SOC 2, ISO27001, NIST 800-53, NIST 800-171, NIST CSF, CIS, and more.
While it’s tempting to align regulations strictly with specific industries—like associating HIPAA with Healthcare or PCI-DSS with Retail—the reality is more nuanced. Regulations can and do cross industrial boundaries, affecting sectors as diverse as Healthcare, Financial Services, Energy, Telecommunications, Transportation, Higher Education, Government, Retail, Legal Services, Manufacturing, Insurance, Pharmaceuticals, Technology, Defense, Automotive, Real Estate, and Utilities.
Ultimately, the data management landscape and its regulatory oversight is complex and ever-changing. Organizations must be agile and proactive in their approach to third-party security risk management regardless of industry.
The complexity and nuance of TPSRM can be daunting. But ensuring your organization’s cyber resilience is too crucial to leave to chance. In practice, effective TPSRM is a meticulously coordinated operational endeavor— like a dance, it involves synchronizing various activities, protocols, and teams in harmony. Plus, a keen understanding of risk management practices, information security, regulations, and interpersonal skills to bring together each element seamlessly.
Breaking down TPSRM into manageable steps makes the task more achievable and thorough, and approaching this challenge one step at a time ensures that no detail is overlooked and that each stage is adapted to your specific needs.
Don’t set sail without a compass—turn to established industry standards and guidelines as your navigational guide.
NIST SP 800-161 offers the tactical playbook, while ISO/IEC 27036 sets the strategic direction.
While NIST 800-161 and ISO 27036 both offer frameworks for supply chain security, their approaches differ. NIST provides granular guidance for federal systems, with prescribed assessments and controls. ISO takes a principles-based approach that allows organizations to tailor implementation to their own suppliers and risk appetite. NIST focuses more on ongoing monitoring of existing supply chain controls, while ISO emphasizes evaluating and selecting secure suppliers from the outset. Together, the standards enable organizations to create comprehensive programs—NIST offers the tactical playbook, while ISO sets the strategic direction.
Identifying and establishing a policy that outlines clear minimum security requirements for your organization is vital. Your organization needs to determine—based on your regulatory obligations and information security standards—what requirements you want your third parties to adhere to, how different types of third parties might adhere to different requirements, and how you will verify those requirements. This ensures that efforts are directed effectively, resources are allocated judiciously, and potential security risks are addressed per the organization’s priorities.
Identifying the right stakeholders is another critical step. Stakeholders bring domain expertise, offer critical insights, and significantly, help ensure accountability and compliance throughout the process. Ultimately, information security and assurance teams aren’t as useful or accountable if their work is done in a void.
Timeliness matters: Engaging stakeholders at the right time is equally vital. For instance, IT teams might be more involved in the initial assessment stages, while legal teams become crucial when finalizing agreements. By mapping out a timeline of involvement, organizations can ensure smooth collaboration and that relevant parties are looped in when their expertise is most required.
Before you can manage third-party security risks, you have to know who your third parties are. Managing, monitoring, or measuring the risks associated with third-party relationships is almost impossible without a clear third-party inventory. A comprehensive inventory helps you gain a clear picture of your organization’s attack surface and potential vulnerabilities.
To build your inventory, you’ll need to determine the intake process for new vendors. How will your security team discover new third parties? And how does the team ensure that due diligence is performed for each new vendor? Answering these questions might mean connecting with existing platforms and teams (e.g., procurement).
Once all third-party vendors are identified, they shouldn’t be treated equally. Some vendors pose a higher risk than others. By classifying them based on the inherent risk they present to your organization, that is, the natural level of risk that exists without considering any controls or mitigations, you can allocate resources more effectively and prioritize your risk assessment efforts. Factors determining inherent risk could include:
But having an inventory of third parties is just the beginning. Tracking specific details about each third-party relationship is crucial to managing risks effectively. By understanding what to track and how to do it, organizations can stay ahead of potential vulnerabilities, ensuring that any changes in third-party risk are swiftly addressed. Whether it’s about data access, assessment timelines, or key contacts, each detail offers a piece of the bigger picture in the third-party risk puzzle. Here’s what to track:
Risk owners: Identify individuals or teams responsible for managing the risks associated with each third party. They are the go-to individuals for any concerns or queries about a vendor’s risk.
Conducting a risk assessment on a third-party vendor is more than just a single activity; it’s an ongoing project aimed at thorough due diligence. The goal is to identify, measure, and prioritize risks to clearly understand the third-party’s security posture. Various techniques and activities can make up an assessment, each contributing valuable insights to help your organization make more informed security decisions.
Leading the assessment toolkit is the control-based questionnaire. This systematic method translates complex cybersecurity standards into measurable questions. By tailoring these to specific security frameworks, assessments become more standardized, facilitating easier vendor risk comparisons. As vendors respond, they can also offer contextual clarifications and evidence. Several industry frameworks stand out in their popularity and efficacy:
Other key assessment activities for a holistic evaluation of third-party vendors:
The combination of these activities make up your third-party vendor assessment, providing insights into their gaps and strengths. Based on your findings, your security team can make informed decisions and recommendations. Identified risks can also be published to a risk register.
Risk identification is just the first step. The core of third-party security risk management is effective management and active mitigation. Utilizing a risk register can significantly streamline this process, helping your organization make timely, well-informed decisions that can differentiate between secure operations and a costly breach.
Every risk you identify should be documented in a risk register and assigned an owner—either an individual or a team responsible for managing that particular risk.
Every risk you identify should be documented in a risk register and assigned an owner—either an individual or a team responsible for managing that particular risk. Assigning ownership is critical for accountability and swift action. The risk register serves as a tracking tool, clarifying who is responsible if something goes wrong.
Your risk register should also include a section for exception protocols. While most risks will fall into predefined categories, some won’t. Document how you’ll handle these anomalies in the risk register. Define who has the authority to deem something an exception and lay out the criteria for what qualifies as an exception versus a rule.
Based on the outcomes of your comprehensive risk assessments, your risk register will guide the next steps for mitigation, tailored to each specific risk:
The digital landscape is ever-evolving, with new threats emerging daily. Given this, a one-and-done approach to third-party risk management simply won’t suffice. Continuous monitoring ensures an organization remains ahead, catching and addressing vulnerabilities before they escalate into full-blown crises.
Relying on manual checks or periodic assessments isn’t feasible in today’s fast-paced environment. Organizations should consider the following:
Third-party security risk management isn’t a project with a start and end date; it’s an ongoing commitment. The relationship with a vendor is dynamic, as are the risks they might introduce. Regularly revisiting the vendor’s security practices and conducting updated risk assessments ensures that the organization’s defenses remain solid. This isn’t just about identifying risks but also about affirming that previous mitigation strategies remain effective and adjusting them as necessary.
The last, and often-underemphasized, element in third-party security risk management is preparing for security incidents. Despite what vendors may claim, using their products doesn’t guarantee immunity from risks. Security incidents are not a matter of “if” but “when.” A meticulously designed incident response plan can distinguish between a brief setback and a catastrophic failure that damages your reputation.
Effective incident response is closely tied to comprehensive inventory management. Knowing which third parties have access to what data or services allows you to quickly assess the potential impact of a breach. It enables you to rapidly identify the critical contacts you’ll need to contact in case of a third-party security incident.
By incorporating inventory management into a detailed incident response plan, organizations can act swiftly and efficiently when faced with a third-party security incident. This is not merely a good-to-have element but an absolute necessity in third-party security risk management.
A comprehensive TPSRM policy is the front-page summary for your entire TPSRM program. This policy outlines what each stakeholder, whether internal or external, needs to know about their responsibilities and the overarching processes. It’s where all the steps and strategies articulated in previous sections find their formal expression. Below are the key subprocesses that give life to an effective TPSRM policy:
Crafting a TPSRM policy requires thoughtful attention to detail and a thorough understanding of the organization’s risk landscape. It’s more than just a document—it’s a strategic asset that, when properly implemented, fortifies an organization’s security posture across its extended ecosystem.
An effective and collaborative Third-Party Security Risk Management (TPSRM) Program is essential for defending an organization’s most critical data against escalating supply chain attacks.
But it’s about more than just security—it’s about building trust in your partnerships and empowering internal and external stakeholders to participate.
Isora empowers Information Security & Assurance teams to create a collaborative workspace where their VRM program can thrive and scale.
By centering GRC around people, Isora not only facilitates risk reduction and regulatory compliance but also promotes program adoption, participation, and, most significantly, a risk-aware culture.
With Isora, Information Security & Assurance teams of all sizes can:
✔ Build a data-focused, organization-wide third-party inventory, where assessments, documents, and risks are centralized and metadata details like data classification, owners, users, contacts, and risks can be tracked.
✔ Launch custom or prebuilt security questionnaires (e.g., SIG, CAIQ, HECVAT, and others) where internal teams and third-parties can answer questions, collaborate, collect evidence, and sign attestations.
✔ Produce insightful risk reports and scorecards based on completed questionnaires that help you identify compliance gaps and perform statistical comparisons.
✔ Connect with any other platforms, including existing procurement, risk intelligence, and GRC platforms to enable the flow of information.
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