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Building trust with vendor management
If you’re working towards a stronger security posture to become an organization that’s worthy of customer trust, your vendors are going to play an increasingly important role.
In this article, we’ll give you an overview of vendor management and walk through what a robust vendor management process looks like.
What is vendor management in the context of security and compliance?
The term “vendor management” can be used in a variety of contexts. In the context of security and compliance, vendor management is all about managing and minimizing the risks that your vendors can pose to your business and your data.
Just about any vendor you onboard could pose some security risk. This can include:
- Software tools that integrate with your network
- Contractors you hire and grant access to your system or your facility
- Even vendors that you are specifically hiring for the purpose of security like a third-party access management system, security auditor, and so on.
Why vendor management is important
Vendor management is an important and ongoing part of strengthening your security posture. Nearly any vendor can unintentionally (or intentionally) open a pathway to your confidential data. Most of the time, this happens from simple oversight or neglect. A vendor might not be updating their software appropriately, or maybe they aren’t vetting their employees who are given access to your facility. You can’t always count on them to know when there’s a vulnerability and to address it appropriately, so vendor management allows you to stay on top of these risks.
The role of vendor management in establishing trust with prospects and customers
Establishing trust with your prospects and customers starts with making a genuine effort to keep their private data safe. Vendor management is a large part of this. You want to be able to be transparent and explain to potential customers exactly how you’re keeping their data safe, and part of that “how” needs to involve minimizing risks from vendors.
Consumers are becoming increasingly aware of third-party vendor risks because those risks have been responsible for several high-profile data breaches. For example, in 2021, hackers breached a consulting firm that was used by Major League Baseball and gained access to the private data of MLB benefits members. Situations like this make it critical for you to be able to address consumers’ concerns with a strong, strategic vendor management policy.
Vendor management best practices
How do you create a vendor management strategy that keeps your organization secure? It will look different depending on your operations and security needs, but there are several vendor management best practices that can help you establish your strategy.
Assess individual vendors in detail
The ultimate rule in vendor security is to never make assumptions. Before entrusting a vendor, you need to thoroughly evaluate their trustworthiness and security posture. Assess them individually to determine:
- What potential risks this vendor could bring to your business
- How the vendor is proactively trying to prevent security risks that impact your business
- The vendor’s history and reputation from a security standpoint
- The vendor’s own vendor management process and how they curtail risks that could come from the vendors they use
Include security expectations in vendor contracts
When you sign on with a new vendor, make sure to leave nothing implied or unspoken when it comes to security. Include specific verbiage in your vendor contracts that details the vendor’s responsibility for taking reasonable action to prevent security breaches that could impact your business. You may also include specific recourse or penalties if the vendor falls below your security standards.
Include software vendors in your continuous monitoring process
Continuous monitoring for vulnerabilities is an important part of robust information security. In your continuous monitoring practice, be sure that you’re monitoring not only your own system but any third-party tools that integrate with your system. These can introduce gateways into your system, and you have no knowledge of when and how they are updating their code, so it’s important to keep an eye on them on an ongoing basis.
The vendor management process
So what should your vendor management process look like? Here are the key components of a strong vendor management process.
1. Establish your vendor selection process
Before you can start finding the best vendors for your organization, you need to invest time in planning a strategic vendor selection process. Which colleagues in your organization are responsible for selecting vendors? What questions need to be asked of vendors? What standards do vendors need to meet? What security policies do vendors need to have in place? Define a list of criteria for each vendor. This should serve as the bare minimum list of requirements for every vendor; you can always expand on this list for specific circumstances.
2. Set up a way to manage vendor data
Thorough vendor management needs to include a way to easily organize and track all information related to your vendors. Set up a type of vendor management database or system where you can easily maintain all this data. That includes vendor contracts, vendor assessment results, contact information for vendors, files on vulnerabilities you have detected and addressed with the vendor in the past, and so on.
3. Evaluate and select vendors
Once you have all the systems in place to evaluate and track your vendors, it’s time to get started on your vendor selection. Use the process and the metrics you defined in step 1 to assess which potential vendors do and do not meet your standards.
4. Finalizing vendor contracts
Once you have selected your vendors, it’s time to develop the contracts for them. Remember, these contracts should be specific about the responsibility the vendor has to prevent security breaches. You can have a template with clauses you included in each vendor contract, but be sure to include additional details and clauses based on the vendor and the role it will play in your security.
5. Create a vendor review process
Finally, you need a system in place to ensure that vendors are meeting their obligations, security-wise. Establish a process for routinely reviewing your vendors to look for potential security risks and identify if a vendor is falling below your contracted standards. This can include a vendor auditing committee and a schedule of when to audit each vendor’s performance.
Streamline vendor management with Vanta
As the leading trust management platform, Vanta helps teams proactively manage third-party risk by automating vendor discovery, risk assessment, and remediation. This way, teams can spend less time on vendor reviews and more time on strengthening their overall security posture.
Learn more about how Vanta can help you streamline vendor risk management. Request a demo today.
Determine whether the GDPR applies to you and if so, if you are a processor or controller (or both)
Do you sell goods or service in the EU or UK?
Do you sell goods or services to EU businesses, consumers, or both?
Do you have employees in the EU or UK?
Do persons from the EU or UK visit your website?
Do you monitor the behavior of persons within the EU?
Create a Data Map by taking the following actions
Identify and document every system (i.e. database, application, or vendor) which stores or processes EU or UK based personally identifiable information (PII)
Document the retention periods for PII in each system
Determine whether you collect, store, or process “special categories” of data
Determine whether your Data Map meets the requirements for Records of Processing Activities (Art. 30)
Determine whether your Data Map includes the following information about processing activities carried out by vendors on your behalf
Determine your grounds for processing data
For each category of data and system/application have you determined the lawful basis for processing based on one of the following conditions?
Take inventory of current customer and vendor contracts to confirm new GDPR-required flow-down provisions are included
Review all customer contracts to determine that they have appropriate contract language (i.e. Data Protection Addendums with Standard Contractual Clauses)
Review all in-scope vendor contracts to determine that they have appropriate contract language (i.e. Data Protection Addendums with Standard Contractual Clauses)
Have you performed a risk assessment on vendors who are processing your PII?
Determine if you need to do a Data Protection Impact Assessment
Is your data processing taking into account the nature, scope, context, and purposes of the processing, likely to result in a high risk to the rights and freedoms of natural persons?
Review product and service design (including your website or app) to ensure privacy notice links, marketing consents, and other requirements are integrated
Does the notice to the data subject include the following items?
Does the notice also include the following items?
Do you have a mechanism for persons to change or withdraw consent?
Update internal privacy policies to comply with notification obligations
Update internal privacy notices for EU employees
Determine if you need to appoint a Data Protection Officer, and appoint one if needed
Have you determined whether or not you must designate a Data Protection Officer (DPO) based on one of the following conditions (Art. 37)?
If you export data from the EU, consider if you need a compliance mechanism to cover the data transfer, such as model clauses
If you transfer, store, or process data outside the EU or UK, have you identified your legal basis for the data transfer (note: most likely covered by the Standard Contractual Clauses)
Have you performed and documented a Transfer Impact Assessment (TIA)?
Confirm you are complying with other data subject rights (i.e. aside from notification)
Do you have a defined process for timely response to Data Subject Access Requests (DSAR) (i.e. requests for information, modification or deletion of PII)?
Are you able to provide the subject information in a concise, transparent, intelligible and easily accessible form, using clear and plain language?
Do you have a process for correcting or deleting data when requested?
Do you have an internal policy regarding a Compelled Disclosure from Law Enforcement?
Determine if you need to appoint an EU-based representative, and appoint one if needed
Have you appointed an EU Representative or determined that an EU Representative is not needed based on one of the following conditions?
If operating in more than one EU state, identify a lead Data Protection Authority (DPA)
Do you operate in more than one EU state?
If so, have you designated the Supervisory Authority of the main establishment to act as your Lead Supervisory Authority?
Implement Employee Trainings to Demonstrate Compliance with GDPR Principles and Data Subject Rights
Have you provided appropriate Security Awareness and Privacy training to your staff?
Update internal procedures and policies to ensure you can comply with data breach response requirements
Have you created and implemented an Incident Response Plan which included procedures for reporting a breach to EU and UK Data Subjects as well as appropriate Data Authorities?
Do breach reporting policies comply with all prescribed timelines and include all recipients i.e. authorities, controllers, and data subjects?
Implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk
Have you implemented encryption of PII at rest and in transit?
Have you implemented pseudonymization?
Have you implemented appropriate physical security controls?
Have you implemented information security policies and procedures?
Can you access EU or UK PII data in the clear?
Do your technical and organizational measure ensure that, by default, only personal data which are necessary for each specific purpose of the processing are processed?
Develop a roadmap for successful implementation of an ISMS and ISO 27001 certification
Implement Plan, Do, Check, Act (PDCA) process to recognize challenges and identify gaps for remediation
Consider ISO 27001 certification costs relative to org size and number of employees
Clearly define scope of work to plan certification time to completion
Select an ISO 27001 auditor
Set the scope of your organization’s ISMS
Decide which business areas are covered by the ISMS and which are out of scope
Consider additional security controls for business processes that are required to pass ISMS-protected information across the trust boundary
Inform stakeholders regarding scope of the ISMS
Establish an ISMS governing body
Build a governance team with management oversight
Incorporate key members of top management, e.g. senior leadership and executive management with responsibility for strategy and resource allocation
Conduct an inventory of information assets
Consider all assets where information is stored, processed, and accessible
- Record information assets: data and people
- Record physical assets: laptops, servers, and physical building locations
- Record intangible assets: intellectual property, brand, and reputation
Assign to each asset a classification and owner responsible for ensuring the asset is appropriately inventoried, classified, protected, and handled
Execute a risk assessment
Establish and document a risk-management framework to ensure consistency
Identify scenarios in which information, systems, or services could be compromised
Determine likelihood or frequency with which these scenarios could occur
Evaluate potential impact of each scenario on confidentiality, integrity, or availability of information, systems, and services
Rank risk scenarios based on overall risk to the organization’s objectives
Develop a risk register
Record and manage your organization’s risks
Summarize each identified risk
Indicate the impact and likelihood of each risk
Document a risk treatment plan
Design a response for each risk (Risk Treatment)
Assign an accountable owner to each identified risk
Assign risk mitigation activity owners
Establish target dates for completion of risk treatment activities
Complete the Statement of Applicability worksheet
Review 114 controls of Annex A of ISO 27001 standard
Select controls to address identified risks
Complete the Statement of Applicability listing all Annex A controls, justifying inclusion or exclusion of each control in the ISMS implementation
Continuously assess and manage risk
Build a framework for establishing, implementing, maintaining, and continually improving the ISMS
Include information or references to supporting documentation regarding:
- Information Security Objectives
- Leadership and Commitment
- Roles, Responsibilities, and Authorities
- Approach to Assessing and Treating Risk
- Control of Documented Information
- Internal Audit
- Management Review
- Corrective Action and Continual Improvement
- Policy Violations
Assemble required documents and records
Review ISO 27001 Required Documents and Records list
Customize policy templates with organization-specific policies, process, and language
Establish employee training and awareness programs
Conduct regular trainings to ensure awareness of new policies and procedures
Define expectations for personnel regarding their role in ISMS maintenance
Train personnel on common threats facing your organization and how to respond
Establish disciplinary or sanctions policies or processes for personnel found out of compliance with information security requirements
Perform an internal audit
Allocate internal resources with necessary competencies who are independent of ISMS development and maintenance, or engage an independent third party
Verify conformance with requirements from Annex A deemed applicable in your ISMS's Statement of Applicability
Share internal audit results, including nonconformities, with the ISMS governing body and senior management
Address identified issues before proceeding with the external audit
Undergo external audit of ISMS to obtain ISO 27001 certification
Engage an independent ISO 27001 auditor
Conduct Stage 1 Audit consisting of an extensive documentation review; obtain feedback regarding readiness to move to Stage 2 Audit
Conduct Stage 2 Audit consisting of tests performed on the ISMS to ensure proper design, implementation, and ongoing functionality; evaluate fairness, suitability, and effective implementation and operation of controls
Address any nonconformities
Ensure that all requirements of the ISO 27001 standard are being addressed
Ensure org is following processes that it has specified and documented
Ensure org is upholding contractual requirements with third parties
Address specific nonconformities identified by the ISO 27001 auditor
Receive auditor’s formal validation following resolution of nonconformities
Conduct regular management reviews
Plan reviews at least once per year; consider a quarterly review cycle
Ensure the ISMS and its objectives continue to remain appropriate and effective
Ensure that senior management remains informed
Ensure adjustments to address risks or deficiencies can be promptly implemented
Calendar ISO 27001 audit schedule and surveillance audit schedules
Perform a full ISO 27001 audit once every three years
Prepare to perform surveillance audits in the second and third years of the Certification Cycle
Consider streamlining ISO 27001 certification with automation
Transform manual data collection and observation processes into automated and continuous system monitoring
Identify and close any gaps in ISMS implementation in a timely manner
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Determine which annual audits and assessments are required for your company
Perform a readiness assessment and evaluate your security against HIPAA requirements
Review the U.S. Dept of Health and Human Services Office for Civil Rights Audit Protocol
Conduct required HIPAA compliance audits and assessments
Perform and document ongoing technical and non-technical evaluations, internally or in partnership with a third-party security and compliance team like Vanta
Document your plans and put them into action
Document every step of building, implementing, and assessing your compliance program
Vanta’s automated compliance reporting can streamline planning and documentation
Appoint a security and compliance point person in your company
Designate an employee as your HIPAA Compliance Officer
Schedule annual HIPAA training for all employees
Distribute HIPAA policies and procedures and ensure staff read and attest to their review
Document employee trainings and other compliance activities
Thoroughly document employee training processes, activities, and attestations
Establish and communicate clear breach report processes
to all employees
Ensure that staff understand what constitutes a HIPAA breach, and how to report a breach
Implement systems to track security incidents, and to document and report all breaches
Institute an annual review process
Annually assess compliance activities against theHIPAA Rules and updates to HIPAA
Continuously assess and manage risk
Build a year-round risk management program and integrate continuous monitoring
Understand the ins and outs of HIPAA compliance— and the costs of noncompliance
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