CISOs Guide 3P Security Management 220527 202621
CISOs Guide 3P Security Management 220527 202621
to Third-Party
Security Management
2
Because you share data with third parties, you must stay informed about their security as much
as your own. Managing the security of your third parties is even more important because of the
following reasons:
1. Increase in cloud apps. According to a McAfee report, the average organization increased its
usage of cloud services by 15% from last year. Moreover, the amount of sensitive data shared on
THE
the cloud increases 53% year over year. It’s expected that within a decade, 90% of IT dollars will
Situation
be spent outside of the IT organization.
2. Remote working. Many companies that have shifted to working from home face increased
cybersecurity challenges, including technology and human risks. The same can be said for their
Your organization’s attack surface is
third parties.
growing continuously. As you outsource
large portions of your IT systems to third
3. Third-party data breaches. According to a Ponemon report, 59% of organizations experienced
parties, you are effectively adding their
a data breach caused by their third parties. The consequences of such breaches can be
attack surface to your own. Moreover, you
disastrous and can include lost consumer confidence and loyalty, as well as costly penalties that
probably have people in your organization
could even lead to bankruptcy.
connecting with outside providers all the
time, so often it’s not even clear what is
4. New regulations. Data privacy regulations such as GDPR, CCPA and the NY SHIELD Act require
included in your attack surface.
companies to ensure that customer data remains private and secure. A breach through a third
party could result in significant financial penalties for the organization to which it is connected.
For all of these reasons, having a comprehensive third-party security process is crucial.
3
The Problems with
Questionnaires
THE
Problems Questionnaires lack context. Often security questionnaires can contain hundreds of
questions, and many are not relevant to every single third party. For example, a vendor that
develops software should complete a different questionnaire than a third party which offers
Most organizations use two tools to cloud-based infrastructure.
assess their third parties’ security: Security
questionnaires and security ratings Questionnaire processes cannot scale. It’s time-consuming to manually send relevant
services (SRSes). However, each method questionnaires to each third party. Following up with third parties to make sure they
can be problematic on its own. complete the questionnaire in a timely fashion and manually reviewing them can demand
many resources. Such a lengthy process hampers business enablement and the ability to
quickly onboard third parties.
Questionnaires are only good for a limited time. Answers to questionnaires may only be
valid for the moment that they are completed. Because new technologies are introduced
all the time, a third party may be fully secure one month and breached the next.
4
The Problem with SRSes
SRSes provide a limited view of cyber posture. While they can do a good job of assessing the
exterior attack surface of third parties, SRSes cannot make sure that a third party complies with
internal security policies and practices. Essentially, using an SRS is looking at the tip of the iceberg:
An organization cannot see the entire picture of cyber posture with just an exterior scan.
THE
Your third parties want nothing more than to close the deal. A security check takes time and effort,
and often requires third parties to remediate cyber gaps, which they may not have the resources to
do. For these reasons, many third parties view security assessments as business blockers and can
come up with excuses to avoid them. Some of those excuses, which stem from specific problems
in the third-party security process, might even be like the ones on the next page.
5
Questionnaire Excuses
Irrelevant questions:
“The questionnaire was too long.”
Unclear questions:
“The questionnaire has nothing to do with my business.”
Communication gap:
“The questionnaire never got to the right person.”
THE
Problems
SRS Excuses
Unclear report:
“I don’t know what you’re seeing.”
False positives:
“I disagree. This is not my asset.”
No remediation plan:
“You found an issue. What do we do?”
6
Context: It’s important for organizations to identify the risk-relevant characteristics of each of their
third-party relationships. The business owner should provide context about what data the third party
will be processing and how critical it is to the business, how the data flows and what it’s being used
for, who will have access, and whether the third party is doing business with subcontractors like
cloud service providers.
THE
Visibility: To effectively assess the security of their third parties, organizations should ideally
Solutions combine an external cyber posture scan with questionnaires so that they can verify internal security
policies. For example, if a company claims that it is PCI compliant but does not have encryption on
communication in transit, that indicates a problem. In addition, third parties should be monitored
Automation is key for a comprehensive continuously, with specific policies that include steps to be taken if a cyber issue is discovered.
third-party security program. It provides
the ability to rapidly scale while
considering the following: Engagement: To enable business, it’s important to partner with your third parties to make the
security process as smooth as possible. Questionnaires should be tailored according to context, so
that there is no need to respond to irrelevant questions. Findings and clear, actionable remediation
plans should be provided to third parties, along with visibility about how cyber gaps were pinpointed.
Organizations should set realistic deadlines and provide an intuitive method for communication. In
short, the organization and third party should establish a collaborative business relationship.
7
1. Identify stakeholders. It’s important to understand who are your internal partners. They might
include the business owner, legal and procurement teams and security subject matter expert.
2. Define tiers for the provider portfolio. Have a comprehensive master list of all of your third
parties and then tier it based on the inherent risk of each relationship. Inherent risk refers to risk
Building based on criticality, meaning how long your organization can manage without that provider;
combined with data risk, meaning how essential and/or sensitive is the data your organization
Your
shares with that provider.
Program 3. Define the standard of care for each tier. Once you have identified the tiers of your third
parties, you must establish a security policy for each tier. The policy should include how
each level should be assessed, how often it should be reassessed, thresholds for continuous
Organizations that need to create monitoring, an alert management process and your expectations regarding how a vendor
or wish to upgrade their third-party should respond.
security program can get started by
doing the following:
4. Focus on providers that don’t adhere. Finally, it’s important to establish a process for how to
handle cyber issues that arise with third parties. Does your organization remediate, implement
internal controls or terminate the business relationship? These are some of the issues that must
be addressed.
8
Adding
Intelligence Scanning a third
party’s attack
surface
Detection of
fourth parties
Business
intelligence
feeds
9
As organizations continue to depend on third parties, the need for effective third-party security
processes is growing. With these steps, organizations can be assured that their security process is
scalable, efficient and comprehensive.
Panorays can help you create and improve your third-party security process. Using Panorays, you can:
About the
Authors Dov Goldman
Director of Risk & Compliance, Panorays
Goldman has years of experience in the third-party risk and compliance field, as
well as a long history as a serial entrepreneur, software and network engineer.
He focuses on the evolving best practices and industry standards in third-party
management and regulatory compliance. Previously, Goldman was VP of innovation
at Opus, director of product marketing at Navigant, and founder and CEO of Cognet
Corp and Dynalog Technologies. He has spoken at industry events around the
world and has been quoted in numerous industry press articles, as well as The Wall
Street Journal, about information security and privacy.
11
Take a look at these resources for helpful
Get Educated! third-party security tips and insights:
The Impact of EBA 3 Key Tips for 4 Ways to See if The 4 Most Important 5 Ways to Prevent
Guidelines on Third-Party Making Your Security You Are at Risk of a Features to Look for in Third-Party Data
Risk Management Questionnaires More Vendor Breach a Third-Party Security Breaches
Effective Risk Platform
12
How Panorays Can Help
Panorays quickly and easily automates third-party security risk evaluation and
management — handling the whole process from inherent to residual risk,
remediation and ongoing monitoring.