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UpGuard:2023第三方风险管理全指南(英文版)(32页).pdf

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UpGuard:2023第三方风险管理全指南(英文版)(32页).pdf

1、A Complete Guide toThird-Party Risk MiiTable of ContentsIntroduction iiiGetting Started With Third-Party Risk Management 1What is a Third-Party?2What is Third-Party Risk Management?3Third-Party Risk Management vs.Vendor Risk Management 5Do you Need a TPRM and a VRM Solution?6The Third-Party Risk Man

2、agement Lifecycle 7The Third-Party Risk Management Lifecycle 8Integrating a Feedback Loop 12How to Evaluate Third-Party Risks 15Common Challenges of Third-Party Risk Management 18Integrating a TPRM with Your Existing Framework 21 iiiIntroductionIf youre currently outsourcing to third-party entities,

3、youre increasing your risk exposure to a data breach.Each of your vendors has some level of access to your internal systems,so if one of them suffers a data breach,they could quickly turn from a trusted partner into a critical attack vector.According to the 2022 Cost of a Data Breach report by IBM a

4、nd the Ponemon Institute,vulnerabilities in third-party software(one of many third-party risk categories)were the third most expensive data breach attack vector in 2022,resulting in damages of up to USD 4.55 million(an increase of 13%compared to 2021).An effective Third-Party Risk Management Program

5、 reduces vendor security risks leading to data breaches,which also reduces the risk of costly damages associated with these events.https:/ Started with Third-Party Risk M2What is a Third-Party?A third party is any entity that your organization works with.This includes suppliers,manufacturers,service

6、 providers,business partners,affiliates,distributors,resellers,agents,and vendors.Because third-party relationships are vital to business operations,Third-Party Risk Management is an essential component of all Cybersecurity programs.Whats the Difference Between a Third-Party and a Fourth-Party?A thi

7、rd party is a supplier,vendor,partner,or other entity doing business directly with your organization,whereas a fourth party is the third party of your third party.Fourth parties(or Nth parties)reflect relationships deeper in the supply chain that are potential avenues to your sensitive resources thr

8、ough your third parties.Getting Started with Third-Party R3What is Third-Party Risk Management?Third-Party Risk Management(TPRM)is the process of analyzing and minimizing risks associated with outsourcing to third-party entities,such as vendors,service providers,contractors,customers,etc.Third parti

9、es increase the complexity of your information security for several reasons:1.Third parties arent typically under your control,nor do you have complete transparency into their security controls.Some vendors have robust security standards and good risk management practices,while others leave much to

10、be desired.2.Each third party is a potential attack vector for a data breach or cyber attack.A vendor with a security vulnerability could be exploited to gain access to your organization.The more vendors you use,the larger your attack surface and the higher the risk of being impacted by third-party

11、breaches.3.General data protection and data breach notification laws like GDPR,CCPA,FIPA,PIPEDA,the SHIELD Act,and LGPD are increasing their inclusion of TPRM-related controls and standards,which means there are now financial repercussions for inadequate TPRM efforts.Insecure third-party vendors are

12、 common causes of data breaches.In 2014,Target suffered a data breach after its sensitive network credentials were stolen from an HVAC contractor working at several Target locations.The breach resulted in the theft of 40 million debit and credit card accounts between Nov.27 and Dec.15,2013.Getting S

13、tarted with Third-Party R4An increasing emphasis on third-party risk management in both regulations and cyber security frameworks is driven by increasing vendor-related security risks.Currently,approximately thirty percent of data breaches are caused by third parties.This concerning statistic will o

14、nly grow as these attacks evolve in complexity and further outgrow outdated TPRM models.To sustain businesses in 2023 and beyond,TPRM programs need to adapt to the fast-evolving third-party risk landscape.Organizations that implement such an innovative TPRM model invest,not only in their current sta

15、te of cyber threat resilience,but also in their future growth.With the impact of third-party data breaches gaining weight in risk analysis calculations,its the businesses with a proven TPRM program that will win the profitable partnership opportunities of the near future.88%88%of organizations have

16、low confidence in the quality of their TPRM process.30%30%of data breaches are directly caused by third parties.60%60%of organizations will use cybersecurity risk as a significant determinant in conducting business engagements by 2025.Getting Started with Third-Party R5Third-Party Risk Management vs

17、.Vendor Risk ManagementTPRM and VRM are often used interchangeably,but there are key differences.Vendor Risk ManagementVendor Risk Management focuses on mitigating security risks associated with vendors.Third-Party Risk ManagementThird-Party Risk Management extends the scope of risk mitigation beyon

18、d vendors to include all third-party entities such as business partners,contractors,customers,service providers,etc.TPRM is an overarching category of third-party risk mitigation that covers VRM and other disciples,including supply chain risk management,compliance risk management,and contract risk m

19、anagement.While TPRM could address all third-party risks(similar to a Digital Risk Protection Service),this effort is commonly concerned with third-party security risks.Getting Started with Third-Party R6Do You Need a Third-Party Risk Management and a Vendor Risk Management solution?A third-party cy

20、bersecurity program should include both a TPRM and VRM component since each discipline focuses on a specific scope of risk management.Vendors,with their ongoing access to sensitive systems,require a unique degree of risk monitoring,both on an attack surface and regulatory compliance levels.Contracto

21、rs,customers,and other third parties introduce a more nuanced set of security risks that can only be effectively managed with a dedicated risk management program.By applying tailored risk mitigation efforts across two primary categories of third-party attack vectors-vendors and third-party entities,

22、the combination of a TPRM and VRM program gives organizations the most comprehensive protection against third-party breaches and other forms of cyberattacks involving third 7The Third-Party Risk Management L8The Third-Party Risk Management LifecycleTo ensure the ongoing efficacy of third-party risk

23、management efforts,a TPRM strategy must be capable of adapting to the increasing complexity of third-party vendor relationships.The Changing Roles of Third-Party VendorsPercentage of legal and compliance leaders agreeing with each statement.80%Third-party vendors are performing new technology servic

24、es.66%Third-party vendors are increasingly providing services outside of the companys core business model.Source:2019 Gartner Third-Party Risk Management ModelThe Third-Party Risk Management L9TPRM LifecycleOngoing management of evolving third-party security risks is possible with the following 5-st

25、age TPRM lifecycle.1.Risk Planning Evaluate your third-party risk appetite-Based on acceptable inherent and residual risks.This risk appetite will likely be modified after onboarding when applicable regulatory and compliance requirements are considered in greater detail.After such considerations,fin

26、al alignment with your risk threshold could be measured with resultant residual risk ratings.Evaluate and determine how to best tier your vendors-This is an important step thats often overlooked.Tiering vendors based on the information they will have access to,the product/service theyre providing,or

27、 their regulatory/compliance requirements will help you determine the level of risk monitoring and due diligence each vendor requires.Intelligent vendor tiering will also help you track the reassessment(or recertification)schedules of each vendor grouping.Confirm the validity of due diligence proces

28、ses-All due diligence risk assessments should be confirmed with a security rating scoring system based on multiple attack vectors.The Third-Party Risk Management L102.Due Diligence Determine critical due diligence questions-Multiple data sources should be referenced when designing these questionnair

29、es,including previous quarterly risk reports,internal audit reports,industry standards/regulations,and previously completed risk assessments.Evaluate each vendors inherent risk score-Before considering any third-party security controls that will be required in a partnership arrangement,a security ri

30、sk baseline should be established through a simple risk assessment or questionnaire.This will help you determine the level of controls needed to keep each vendors risk exposure within your risk appetite limits.Confirm the validity of due diligence processes-All due diligence risk assessments should

31、be confirmed with a security rating scoring system based on multiple attack vectors.3.Contract Negotiations Establish security standards in vendor contracts-This will depend on the jurisdiction you operate in.Consider relevant data breach notification periods-Depending on your region and the regulat

32、ions that apply to your organization,you may have minimal third-party vendor breach notification timeframes your vendors should agree to.Complete internal security breach clauses-Include a contract stipulation to report any minimal internal security incidents not classified as public data breaches(i

33、ts better to be overinformed about the security posture of your vendors than underinformed).These events could be communicated in a General Incident Report.Complete ESG clause-Compliance with specific environmental,social,and governance standards is becoming an increasingly important inclusion in su

34、pply chain relationship contracts.The Third-Party Risk Management L11 Consider adding a Right to Audit clause in vendor contracts-This will give you the right to review each vendors internal security processes,audits,self-assessments,and controls.Review stipulated SLAs-To ensure the standards meet y

35、our business and compliance requirements.Seek TPRM platform onboarding approval-Confirm the vendors approval of being onboarded onto your companys TPRM platform.Segregate each TPRM project-Designate an internal primary business owner of each TPRM relationship.4.Ongoing Monitoring Implement continuou

36、s attack surface monitoring-Implement systems that track the performance and status of all third-party security controls that are in place.Establish internal monitoring triggers-Monitoring systems triggered during critical security events,such as weakening security postures and deviations from regul

37、atory compliance standards.Implement service level agreements compliance tracking-Track and assess alignment with stipulated service standards.Follow a reassessment schedule-performing routine reassessments of all current vendors based on internal policy and regulatory requirements.Account for new r

38、isk exposures-Following strategic direction changes or any changes to digital products and services,security postures should be re-evaluated to detect new risk exposures.The Third-Party Risk Management L125.Termination Revise user access list after offboarding and contract termination-Revoke all dat

39、a access and perform a final review of security policy and regulatory standard compliance.Implement data deletion processes-In some jurisdictions,data deletion and proof of this action is required.Check your regulation requirements to confirm the need for data deletion and a certificate of deletion

40、confirmation.Integrating a Feedback LoopTo further optimize adaptation to changing third-party risks,a feedback loop is added to the TPRM lifecycle to ensure remediation efforts always address emerging risks.Linear TPRM LifecycleTPRM Lifecycle with Feedback LoopThe Third-Party Risk Management L13Add

41、ing a feedback loop creates an iterative model that can adapt to any changes in risk appetites,security policies,regulatory compliance standards,and business relationships.The updated TPRM lifecycle model can also consider special third-party risks falling outside of the cybersecurity category,also

42、known as special categories of risk.Special categories(or non-traditional categories)of risk include entities that have the potential of becoming third-party breach attack vectors despite not commonly being targeted by cybercriminals.The management of special third-party risks is especially an impor

43、tant capability for financial institutions.Regulators are increasing third-party risk scrutiny in the financial sector,and this trend is likely to continue as digital transformation deepens indirect relationships with sensitive financial data.The Third-Party Risk Management L14Common examples of spe

44、cial third-party risk categories are listed below:Insurance agents Reinsurers Brokers Third-party administrators Powers of attorney Indirect lenders Correspondent lenders Data marketing firms Utilities Corporate law firms Foreclosure and bankruptcy law firms Regulated entities Financial market utili

45、ties Lobbying firms AffiliatesThird-Party Risk Management doesnt have a destination.Its an ongoing process of learning and adjusting to each vendors emerging security risks.The Third-Party Risk Management L15How to Evaluate Third-Party R16How to Evaluate Third-Party RisksThere are various solutions

46、and methods that exist for evaluating third parties.Generally,senior management and the board will decide on the best methods to choose,depending on your industry,number of vendors,and information security policies.Security RatingsSecurity ratings are an increasingly popular part of third-party risk

47、 management.They can help with the following:Security QuestionnairesSecurity questionnaires(or third-party risk assessments)are designed to help you identify potential weaknesses among your third-party vendors,business partners,and service providers that could result in a data breach.Understanding t

48、he scope of third-party and fourth-party risks in a supply chain and vendor network.Cyber insurance underwriting,pricing,and risk management by allowing insurers to gain visibility into the security program of those they insure to better assess and price their insurance policies.Investment in or acq

49、uisition of a company by providing organizations with an independent assessment of an investment or M&A targets information security controls.Enabling governments to better understand and manage their vendors cybersecurity performance.How to Evaluate Third-Party 17Penetration TestingPenetration test

50、ing(also known as pen testing and ethical hacking)is the practice of testing a computer system,network,or web applications cybersecurity to discover exploitable security vulnerabilities.Pen-testing third-party vendor solutions could uncover overlooked third-party risks.Virtual and Onsite Evaluations

51、Virtual and onsite evaluations are typically performed by an outside entity and can include policy and procedure reviews and physical reviews of security controls.How to Evaluate Third-Party risksHow UpGuard Helps?UpGuard can help you evaluate third-party risks with:An industry-leading questionnaire

52、 library based on popular regulations.A custom questionnaire builder for highly-targeted risk evaluations.A complete third-party risk assessment workflow for seamless risk remediation.An industry-leading security rating feature offering instant,accurate insights into vendor security postures.A quest

53、ionnaire risk-mapping feature identifying regulatory compliance gaps.A proprietary vendor data leak detection engine reviewed by world-class cybersecurity analysts to remove false 18Common Challenges of Third-Party Risk M19Common Challenges of TPRMThere are several common difficulties most organizat

54、ions face when implementing and running a third-party risk management program.Lack of understanding of the need for a TPRM programThird-party risk management is still a relatively new field of cybersecurity,and as such,many organizations have a limited understanding of how it fits within an existing

55、 cybersecurity program.This poor awareness results in an inadequate risk mitigation framework and risk appetite consideration,feeding increasing exposure to third-party security events.Lack of SpeedIts no secret that getting a vendor to complete a security questionnaire and processing the results ca

56、n be a lengthy process.A process that is made worse when questionnaires come in the form of dense spreadsheets with no version control,resulting in an error-prone,time-consuming,and impractical process that doesnt scale.Lack of DepthMany organizations make the mistake of believing they dont need to

57、monitor low-risk third parties,such as marketing tools or cleaning services.But in a threat landscape thats quickly evolving towards third-party cyberattacks,all vendors-even the most innocuous-are potential attack vectors,either through direct cyberattack methods,like security vulnerability exploit

58、ations,or indirect methods,such as phishing emails purporting to come from trusted vendors.Common Challenges of TPRM20Lack of VisibilitySecurity questionnaires alone reveal the effectiveness of a given vendors security controls for a single point in time.However,IT infrastructures are in constant fl

59、ux,and the positive results of a given security assessment may not accurately reflect that vendors security posture a few months into the future.This is why security ratings are usually used alongside traditional risk assessment techniques.This combination provides third-party risk management teams

60、with objective,verifiable,and always up-to-date information about a vendors security controls.Lack of ConsistencyAd-hoc third-party risk management processes mean that not all vendors are monitored,and when they are,they are not held to the same standard as other vendors.While its recommended to ass

61、ess critical vendors more heavily than non-critical vendors,its still important to assess all vendors against the same standardized checks to ensure nothing falls through the cracks.Lack of TrackabilityKeeping track of which vendors have been sent security questionnaires and completion rates across

62、a network of hundreds or thousands of third parties is a considerable challenge.Lack of EngagementContinuously reminding vendors to complete their risk assessments is probably the most frustrating component of third-party risk management,especially when these reminders keep getting lost within ever-

63、expanding inboxes.Common Challenges of TPRM21Integrating a TPRM with your Existing Cybersecurity F22Integrating a TPRM with your Existing Cybersecurity FrameworkA common misconception amongst first-time TPRM adopters is that a TPRM program needs to replace an organizations existing cybersecurity fra

64、mework.When Implementing a TPRM program,the objective isnt to replace previous cybersecurity investments but instead to augment TPRM with your existing cybersecurity program to broaden its risk management capabilities.The following 8-step process will help you map your existing risk controls to a TP

65、RM program.This generic process is compatible with most cybersecurity frameworks.Step 1:Map the lifecycle of all of your most crucial dataAn essential prerequisite to implementing a TPRM is identifying all of your critical data,how its classified,where its stored,and its movements across processes.T

66、his mapping effort must extend to the third-party attack surface,identifying all of the vendors accessing your crucial data and their level of access.The flow of your sensitive data through third-party processes,and each vendors level of sensitive data access,can be evaluated with risk assessments.I

67、ntegrating a TPRM with your Existing Cybersecurity F23Step 2:Review your Enterprise Risk Management(ERM)FrameworkYour ERM framework should be updated to align with the increasing emphasis on third-party risk controls across regulations and compliance standards.Updating your ERM framework should trig

68、ger an update of all your risk registers across each department.Every business unit across most industries utilizes some degree of third-party service,so every business unit should have a risk register.If you come across any risk registers that have recently been updated,check to make sure their ris

69、k data is based on the most updated list of third-party vendors and products in use.Step 3:Update Your Corporate Risk Appetite StatementUpdate your risk appetite statement to address all third-party risks threatening the achievement of business goals and include plans for identifying and managing th

70、ose risks.Your updated risk appetite should be defined at an organizational level and feed into every business unit.This will set an objective risk threshold that every business register is measured against,allowing critical third-party risks at a department level to be easily identified.After updat

71、ing a risk register,always confirm its alignment with the risk appetite outlined in your ERM framework.Integrating a TPRM with your Existing Cybersecurity F24Step 4:Draft TPRM security policiesCreate TPRM policies to align the cybersecurity objectives of your entire organization against processes ou

72、tlined in the TPRM lifecycle.Besides an overarching TPRM that you include in your risk appetite statement,TPRM policies should be drafted for each business unit in the context of each units unique risk profile.When writing each TPRM policy,its important to consider your internal third-party risk req

73、uirements(as outlined in your ERM framework)and the compliance requirements of any relevant regulatory standards.Relevant regulatory standards include those that pertain to your industry and the industries of each of your vendors.A list of popular compliance standards to support your TPRM policy wri

74、ting efforts:Cybersecurity Maturity Model Certification(CMMC)European Banking Authority(EBA)Cloud Security Alliance(CSA)Financial Conduct Authority(FCA)General Data Protection Regulation(GDPR)Federal Financial Institutions Examination Council(FFIEC)ISO 27001 ISO 27002 ISO 27018 ISO 27036-2 ISO 27701

75、 Health Insurance Portability and Accountability Act of 1996(HIPAA)North American Electric Reliability Corporation Critical Infrastructure Protection(NERC CIP)NIST 800-53 NIST 800-161 NIST Cybersecurity Framework(CSF)Stop Hacks and Improve Electronic Data Security(SHIELD)Act SOC 2 OCC Bulletins PCI

76、DSSIntegrating a TPRM with your Existing Cybersecurity F25Step 5:Select a TPRM frameworkSelect a TPRM framework that best unifies your TPRM policies,calculated risk appetites,and ERM framework.Your selected framework should be capable of the following:Highlighting the risks within your appetite and

77、those falling outside of the threshold.Identifying all of the security controls your third-party vendors are expected to implementStep 6:Design Third-Party Vendor Onboarding Contracts and Due Diligence ProcessesAt this point,youll have enough personalized third-party risk data available to create se

78、curity contracts for new third-party vendors and establish your due diligence processes.For an outline of the vendor security contract creation process,refer to stage three of the TPRM lifecycle(add page number).Vendor due diligence processes include the questionnaires and assessments required to ac

79、curately describe each vendors security posture.Your choice of questionnaire depends on your unique compliance and cyber threat mitigation requirements outlined in your ERM framework.The terms Security Questionnaire and Security Assessment are often used interchangeably because they both refer to th

80、e same due diligence processes.Integrating a TPRM with your Existing Cybersecurity F26Step 7:Identify all of the Regulations that Apply to You and Your VendorsIdentify all of the regulations that apply to you and your third-party vendors.To support this effort,the list below identifies all of the th

81、ird-party security controls for popular cybersecurity frameworks and regulations.Payment Card Industry(PCI)8.3 9.9.3 12.3.9 12.3.10 12.8 12.8.1 12.8.2 12.8.3 12.8.4 12.8.5The Office of the Comptroller of the Currency(OCC)OCC Bulletin 2013-29ISO/IEC 27001 15.1 15.2Sarbanes-Oxley Compliance(SOX)APO10.

82、01/APO10.02 APO10.03 APO10.04HITRUST CSF 5.02 External Parties 05.i Identification of Risks Related to External PartiesIntegrating a TPRM with your Existing Cybersecurity F27Step 8:Implement a Vendor Tiering PolicyFor your TPRM program to be effective,it should prioritize vendors with the highest po

83、tential of negatively impacting your security posture.A vendor tiering policy supports this requirement by grouping critical vendors in the same tier,making their cybersecurity impact the primary focus of attack surface monitoring efforts.Integrating a TPRM with your Existing Cybersecurity Framework

84、Level Up Your Third-Party Risk Management with UpGuardPrevent third-party breaches,discover potential vendor risks,and track regulatory compliance all from a single award-winning solution.Were here to help,shoot us an email at Looking for a better,smarter way to protect your data and prevent breache

85、s?UpGuard offers a full suite of products for security,risk and vendor management +1 888- Castro Street,Suite 120-387,Mountain View CA 94041 United States 2023 UpGuard,Inc.All rights reserved.UpGuard and the UpGuard logo are registered trademarks of UpGuard,Inc.All other products or services mentioned herein are trademarks of their respective companies.Information subject to change without notice.

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