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11th December 2024.
That’s the grace period the Monetary Authority of Singapore (MAS) has allowed before its new Notices on Outsourcing (658 and 1121) takes effect. Announced on 11th December 2023, the 12-month grace period also repeals the Outsourcing guidelines outlined in Notices 634 and 1108.
This means even if your organization was compliant with Notices 634 and 1108 last updated in 2018, you still have work to do. You’re probably here because you know that. So without much ado, in this article, I’ll:
Highlight who the latest MAS Outsourcing guidelines apply to
Discuss the key areas in the new MAS Outsourcing guidelines
Show you how to automate parts of the process of becoming (and staying) compliant with MAS’ updated regulations.
Who the Latest MAS Outsourcing Guidelines Apply to
According to the regulator’s official statements, Notices 658 and 1121 spells out compliance requirements for banks and merchant banks outsourcing relevant services to third-parties, respectively.
As illustrated below:
Both outsourcing guideline Notices are issued pursuant to section 47A(2), (4), (6), (7) and (12), as applied by section 55ZJ(1), of the Singaporean Banking Act 1970 (the “Act”) and applies to all banks and merchant banks.
The stated information confirms who the new MAS Outsourcing guidelines apply to: Banks and merchant banks. However, the responsibility of becoming compliant rests on the senior management, CISOs, and executives at such financial institutions (FIs).
You’ll see that as we proceed.
But before we proceed:
Key Areas in the New MAS Outsourcing Guidelines
Although there are dozens of requirements, key areas FIs must adhere to, to become compliant with the new MAS Outsourcing guidelines are:
Having a register of all outsourced service providers
Third-party risk governance and management oversight
Ongoing evaluation of 3rd (and 4th) party vendors
Continuous independent audits of third-parties
Register of All Outsourced Relevant Services
Under this requirement, MAS mandates all banks and merchant banks to have and keep a register that comprehensively records all:
More importantly, the regulator requires all FIs to update the register promptly and submit the same to the Authority semi-annually and at any time it is requested.
You can have and keep an updated register of outsourced relevant services like the one required by MAS through the good ol’ spreadsheet. But this will take a lot of manual data entry and maintenance efforts. A more optimal way is to leverage Cyber Sierra’s third-party risk management suite:
With our platform, an updated inventory of all third-party vendors and service providers are kept automatically. As shown above, you also get a database for your security team to quickly search and track how critical vendors perform relative to outlined MAS cybersecurity guidelines.
In the new Outsourcing guidelines, MAS requires the implementation of an appropriate third-party risk management governance framework. They also require FIs to have an executive team to provide oversight of the same.
Two critical must-dos are:
To comply with these requirements, you can create a custom third-party risk management governance framework. A better option that helps in streamlining the compliance process is to adopt and customize globally-accepted governance frameworks like SOC and NIST.
Cyber Sierra helps with that:
Our platform is pre-built with customizable versions of the SOC and NIST governance frameworks used to assess 3rd parties worldwide. You also get a single pane to invite all stakeholders needed to collaborate, customize, and oversee any of the governance frameworks your team implements.
Ongoing evaluation of 3rd (and 4th) party vendors
In the updated Outsourcing guidelines, MAS requires FIs to properly evaluate third-parties before and after engaging them. The financial regulator also requires due diligence extended to the subcontractors (fourth-parties) a 3rd party service provider is working with.
This due diligence checks should be ongoing:
To become compliant with the ongoing evaluation of third-and fourth-parties, MAS expects third-parties working with FIs to provide evidence of meeting designated security assessment requirements.
Specifically, the expect that:
You can automate processes involved in collecting such evidence documents with Cyber Sierra. For instance, you can request and have third-parties upload required security assessment evidence from one pane.
Our platform also auto-verifies each uploaded evidence:
The ability to automate crucial third-party risk management processes like this is why financial institutions trust Cyber Sierra. Take one global bank based in Singapore:
Continuous Independent Audits of Third-Parties
The compliance requirements here is straightforward:
Working with independent auditors has many benefits. One is giving external, more experienced eyes a chance to assess 3rd parties that pose risks and can stop your company from becoming compliant. But because MAS requires that this is done on an ongoing basis, there’s a need to streamline the process for everyone.
For instance, you can give auditors a central place where they can search, easily review, and identify third-parties with unsatisfactory security measures in place.
Again, you can do this with Cyber Sierra:
Take the MAS Outsourcing Notices Seriously
Singapore’s threat landscape is always evolving.
To stay one step ahead, Notice 658 and Notice 1121 sets out updated measures necessary for protecting financial institutions from threat actors increasingly trying to strike through outsourced services. By taking the new MAS Outsourcing guidelines seriously and complying with them, you bolster your organization’s cyber resilience.
Another reason to take this seriously is the allowed grace period. MAS expects all financial institutions to become compliant with all new requirements before 11th December 2024. Depending on when you read this, that’s just a few months away.
To facilitate the process for your team, consider streamlining and automating the crucial parts of becoming (and staying) compliant. Of course, this is where a platform like Cyber Sierra comes in:
Third Party Risk Management
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Pramodh Rai
Meet Pramodh Rai, a technology aficionado and Cyber Sierra's co-founder, whose zest for innovation is fuelled by a cupboard stacked with zero-sugar Redbull. With a nimble footwork through the tech tulips across Asia Pacific, he's donned hats at Hmlet (the proptech kind) and Funding Societies | Modalku, building high-performing teams and technologies. A Barclays prodigy with dual degrees from Nanyang Technological University, Pramodh is a treasure trove of wisdom, dad jokes, and everything product/tech. He's the Sherpa in sneakers you need.
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In today’s rapidly changing business environment, success is often a matter of who you know – or in many cases, who you work with. Third-party relationships can be a boon, opening doors and enabling innovation. However, they can also be a complex web, a vast network that can introduce a host of risks, especially cybersecurity risks.
Understanding the gravity of these risks is crucial.The vulnerability of third-party connections presents a formidable challenge for organizations navigating the cybersecurity landscape.This underscores the critical importance of implementing a proactive and strategic Third-Party Risk Management (TPRM).
This TPRM blogpost will help demystify TPRM, explain why it’s important, and provide best practices to fortify your organization against these risks.
What is TPRM?
Third-party risk management (TPRM) is a proactive and strategic approach to identifying and mitigating the varied risks associated with an enterprise’s use of third parties (also known as vendors, suppliers, partners, contractors, or service providers) for its business requirements
TPRM helps organizations understand the third parties they work with, how they are used, and what safeguards the third parties have in place. The scope and requirements of TPRM vary from one organization to another based on industry, regulations, and other factors, but many best practices are universal. TPRM can be thought of as a broader discipline that includes vendor risk management (VRM), supplier risk management, and supply chain risk management. By implementing a robust TPRM program, organizations can reduce the likelihood of disruptions to their operations and protect their reputation, data, and assets.
Importance of TPRM in 2024
In 2024, Third-Party Risk Management (TPRM) continues to be critical for organizations across various industries due to the evolving threat landscape, increasing reliance on third-party vendors, and rising regulatory scrutiny. According to Deloitte, last year 62% of global leaders identified cyber information and security risk to be the top third-party risk. At the same time, almost half (42%) of them believe that their third parties play a more important role than ever in driving revenue compared to three years ago. This highlights the significant challenges and responsibilities faced by third-party risk management and security teams in identifying, managing, and mitigating the varied risks associated with integrating them into their IT environment.
Increased regulatory scrutiny:
The increasing focus on data protection and privacy regulations like GDPR, MAS TRM, and CCPA has led to a greater scrutiny of third-party outsourcing. Regulators worldover, like those in the EU and the US, are demanding tighter governance and accountability, particularly in AI and cloud services. Rules like DORA, NYDFS, and NIS2 mandate mapping third-party assets, evaluating criticality, and adopting proactive risk management strategies, including third-party risk assessments. This shift requires organizations to ensure TPRM practices align with evolving regulations.
Evolving threat landscape:
With businesses increasingly leveraging cloud services, the potential attack surface has grown. TPRM is crucial in identifying and mitigating these emerging risks by implementing and monitoring effective cybersecurity measures. However, enterprises must consider the shared responsibility model of cloud infrastructure systems like AWS, which shifts certain responsibilities to SaaS providers. This shift complicates data security and can lead to vulnerabilities, as seen in the 2015 Uber breach. Companies must implement best practices and maintain strong oversight of their cloud services and third-party relationships.
Examples of Third-Party Risks
Organizations face various third-party security risks, some of which are mentioned below:
Cybersecurity Risk: The association with third parties can result in many kinds of cyber threats, including data breaches or even data loss. Routine evaluation of vendors and tracking of their activities is one of the measures aimed at minimizing this risk.
Operational Risk: Third-party initiatives and disruptions can prevent business operations from going normal. To eliminate this, companies usually implement SLAs (service level agreements) with vendors and prepare backup plans for the sustenance of business continuity.
Compliance Risk: Third-party activities can increase an organization’s risk of noncompliance with established standards or contractual agreements. This area is particularly sensitive for companies that operate in industries with a high degree of regulation, such as banking, telecom, government, and the health sector.
Reputational Risk: Any organization working with third parties faces potential reputational risks from adverse incidents. Such incidents involve security failures, data breaches, or unethical behavior. They can damage customer trust loss, brand reputation, and overall business quality.
Financial Risk: Inadequate management of third-party relationships can also cause financial difficulties for companies. A third party with inadequate security measures may attract fines and legal fees, further damaging the company’s financial stability.
Strategic Risk: Furthermore, third-party risks can be detrimental to an organization’s strategic objectives. If not addressed adequately, they can impede business success.
These risks often converge – for example, a breach can lead to loss of customer data, posing simultaneous risks to operations, brand reputation, finances, and compliance
Third-Party Risk Management Lifecycle
1. Recognition and Categorization of Third-Party Risk
Effective third-party risk management starts with understanding and categorizing the risks posed by different third-party relationships. This involves creating a complete inventory of all vendors, suppliers, contractors, partners, and other third-party entities that an organization engages with. Here are several factors to consider when categorizing these relationships:
Determine access level: Providers with high levels of access to sensitive data or systems are the ones considered to be at high risk.
Relationship type: Providers that take a rather meaningful part in the enterprise are thought of as higher-risk ones.
Industry or sector: Particular industries or sectors could be more prone to risks, such as fraud or data breaches.
Regulatory compliance: Ensure clarity and alignment with regulatory expectations by categorizing third-party risks according to specific compliance mandates and industry regulations.
Financial stability: The providers with financial instability are likely to raise the risk levels of organizations.
Categorizing third-party relationships based on these factors can help organizations prioritize their risk management efforts and allocate resources more effectively to mitigate potential risks. It also provides a framework for ongoing monitoring and assessment of these relationships.
2. Risk assessment and Due Diligence
In the second stage of the TPRM lifecycle, organizations conduct a comprehensive risk assessment and due diligence to ensure the reliability and compliance of their third-party relationships with their security requirements.
Risk assessment involves:
Identifying the third-party risk associated with each outsourced relationship
Measuring the probability and potential impact of these risks, which may involve financial stability, operational resilience, regulatory compliance, and safe use of data.
Due diligence involves:
Assessing the provided information by the third parties for reliability and capabilities of the provider, which may include reviewing the financial data and documents, among others.
Creating policies and procedures for when outside parties are involved, such as making sure external agents are obligated to follow the security standards and provisions of the company, including data encryption and access controls.
This step of the TPRM lifecycle should be aimed at ensuring that the organization fully understands the risks that the third-party relationships will bring and acts in response to them, mitigating each to a possible minimum. It also serves as a reference for the constant monitoring and testing of the ties to guarantee that the actions are compliant and secure.
3. Risk Mitigation
After the assessment of risks and fulfillment of due diligence, the next step in the TPRM lifecycle is risk mitigation and management. This means that policies, controls, and processes must be developed to mitigate existing risks in the first stages of third-party risk management and expose the organization to lesser third-party risks.
Risk mitigation and control strategies may include:
Contractual clauses: Incorporating specific clauses that are meant to outline the duties of each party in the third-party agreement, the privacy, data security, compliance, and indemnification clauses.
Continuous monitoring: Developing the process of long-term surveillance of third-party actions to ascertain that they comply with the security requirements and conduct regular audits, activities, and periodic reports.
Data protection: Implementing enforcement measures, which include access restrictions, data encryption, and regular backups.
Incident response: Ensuring a quick response strategy focused on security incidents including protocols for alerts, incident management, and post-incident assessments.
4. Contracting Management
In the modern business landscape, organizations frequently look to external vendors for a whole host of services – financial services, marketing, and technology, for example. While these relationships can drive substantial benefits, they’re not without risk – risk that must be managed effectively. This is where contractual and relationship management practices come into play.
Establish SLAs: Service level agreements (SLAs) are contracts that set performance benchmarks and service level standards between an organization and a third-party provider. Critical services must have SLAs that include benchmarks for response times, availability, and the timeframe for resolving problems. These metrics should be frequently reviewed and adjusted as required to ensure they meet current business needs and goals.
Manage relationships: It is essential to have a dedicated relationship management team or point of contact to manage third-party partnerships effectively. This team or individual should be responsible for monitoring the third-party provider’s performance, addressing any issues or concerns, and ensuring that the organization’s expectations are being met. Establishing regular channels of communication, status updates, and conducting periodic evaluations are also critical.
Ensure compliance: Third-party providers must comply with all contractual obligations. This requires ongoing monitoring of the provider’s performance and ensuring that all service-level agreements and other contractual requirements are being met. Additionally, regular audits and assessments should be conducted to ensure compliance with relevant laws, regulations, industry standards, and best practices.
Perform regular review: Contracts with third-party providers should be reviewed and updated regularly to ensure they remain relevant and effective. This includes updating SLAs and other performance metrics to account for changes in business requirements or advancements in technology. Moreover, contracts should be reviewed to ensure they comply with all relevant rules and regulations.
5. Incident response and remediation
In the TPRM life cycle, incident response and remediation features are prominent since they are the safety nets for handling unknown cybersecurity risks. Although organizations use several preventive actions, security incidents can still turn up unexpectedly. Rapid acts of decisiveness are very important since they help mitigate the damage and avoid similar problems in the future.
Here are the key steps in handling security incidents:
Establishing incident response plans: All the parties involved should be well familiar with the roles analysis and the existing incident response plan. The plan should be detailed, identifying and addressing each task from start to finish, and should also cover communications with the key stakeholders and analysis of the incident aftermath.
Addressing third-party involvement: If it is a third-party provider that has been involved, steps should be retained to notify the provider and ascertain their part in the incident. This involves investigating the provider’s security policies and determining if they follow the compliance of any legal requirements and industry standards.
Implementing corrective actions: Once the situation is contained the organizations leverage corrective action to prevent similar incidents from happening again in the future. A new security framework may include: enhancing security measures, updating policies and procedures, and providing additional training and guidance to authorities.
Conducting post-event evaluations: It is essential to conduct a holistic review of the outcomes after the incident to identify areas of improvement. In this evaluation, the focus is on reviewing and improving the security measures, enhancing controls, and reinforcing employee education procedures.
Essentially the relationship between incident response and remediation is an integral part of the TPRM cycle as they function as reactive as well as proactive measures to avoid unexpected risks and secure the data and assets. The establishment of proper and effective incident response protocols can help to ensure the management of risks efficiently and maintain the company’s reputation as well as business continuity.
6. Ensuring Compliance
Compliance is an essential part of the Third-Party Risk Management (TPRM) lifecycle. Compliance efforts ensure that all aspects of the TPRM program align with industry standards and provide a framework for continuous monitoring and improvement, helping organizations adapt to changing regulatory landscapes and emerging threats. This stage includes:
Monitoring and validating third-party compliance with contractual obligations, regulatory requirements, and industry standards.
Conducting regular audits and assessments to identify any compliance gaps or areas for improvement.
Implementing corrective actions or strategies to address compliance issues and improve overall compliance posture.
Providing ongoing training and support to third parties on compliance-related matters.
Reviewing and updating compliance policies and procedures in response to changes in regulations or industry standards.
Ensuring that all aspects of the TPRM program, including risk assessments, due diligence, and relationship management, adhere to compliance guidelines.
7. Monitoring of Third-party relationships
While third-party partnerships offer significant benefits, they also come with inherent risks that need to be managed effectively. This is where sound third-party relationship management practices come into play. This includes:
Establishing clear service level agreements (SLAs) to set performance expectations between an organization and its third-party provider. This includes defining response times, availability, and problem resolution timeframes.
Assigning a dedicated relationship management team or point of contact is essential for the effective management of third-party partnerships. They are responsible for monitoring the provider’s performance, addressing concerns, and ensuring that expectations are met.
Conducting regular audits and evaluations of contracts to ensure ongoing compliance with relevant laws and regulations, as well as alignment with organizational goals and standards.
Best Practices of Third-Party Risk Management
Segmentation
Divide third-party relationships into separate groups based on their risk levels, significance, data access, and regulation status.
Prioritize dealing with risks based on the profile of each group so as to use resources wisely.
Conduct ongoing and monitoring of high-risk groups while periodically reviewing low-risk ones.
Continuous Monitoring
Maintain an updated inventory of all third-party relationships, including vendors, suppliers, and contractors.
Establish a process for continuous monitoring of third-party relationships to ensure they meet security standards.
Regularly perform security assessments, audits, and compliance checks to identify and address emerging risks promptly.
Establish Clear Policies and Procedures:
Develop and enforce clear policies and procedures for managing third-party risks.
Identify the roles and responsibilities of the individuals who are part of maintaining the vendor relationships.
Review and refresh permissions when business needs and risks change.
Collaborate with Internal and External Auditors:
Collaborate with the internal and external auditors to build a strong third-party risk management program.
Get help and support from auditors and compliance experts to meet the industry standards and regulatory rules.
Form cross-functional teams of critical stakeholders and auditors from multiple departments to resolve issues and enhance third-party risk management processes.
Leverage automation for TPRM:
Utilize automation tools to streamline the collection, analysis, and reporting of TPRM data, enabling real-time insights into vendor risk profiles, compliance status, and performance metrics.
Implement customizable dashboards and automated reporting functionalities to visualize key risk indicators, trends, and compliance gaps, facilitating informed decision-making and strategic planning.
Challenges in Third Party Risk Management (TPRM)
Risk mapping: Organizations face difficulties in developing an overview of their vendor networks. This can result in a lack of visibility into risks and an increase in overall risks.
Dealing with risks: The risk landscape is constantly changing, requiring organizations to be adaptable and proactive in recognizing and handling emerging risks within their third-party partnerships. However many organizations struggle to keep pace with these changes, leaving them susceptible to threats.
Lack of preparedness for incidents: Despite having risk management strategies in place security incidents involving third parties can still occur. To minimize the impact, companies need incident response plans. Nevertheless, many organizations are not adequately prepared to respond effectively to incidents and lack readiness.
Implementation of ongoing monitoring: Most assessment methods used in TPRM offer a view of a vendor’s risk at a specific moment. This can be limiting. But there are some TPRM platforms, such as Cyber Sierra that allow for near real-time monitoring of the vendors’ security controls
Development of vendor risk management policy: Crafting a Vendor Risk Management (VRM) policy is essential for TPRM. This involves outlining compliance standards responsibilities in the event of a breach, acceptable vendor controls, response protocols, and oversight mechanisms.
Compliance: Ensuring compliance with regulations and industry frameworks is crucial for managing third-party risks. However, staying abreast of the evolving environment can pose challenges. It can get challenging for companies to guarantee that their third-party partnerships adhere to all the relevant regulations.
Integration: TPRM should be an integral part of an organization’s overall risk management strategy. However, companies often struggle to integrate TPRM into their existing business processes, leading to disjointed risk management efforts and potential gaps in risk coverage.
Leverage an Automated Third-party Risk Management program
In general, TPRM is one of the necessary components of a comprehensive risk management program. It helps organizations protect themselves, their customers, and their assets while meeting regulatory compliance, reducing cost, and improving efficiency. Through responsible policies and timely monitoring, organizations can reduce the impact of third-party risks. The right tools enable preparation and forge deals that stimulate growth and success. That said, while you can mitigate third-party risks, it is impossible to eliminate them completely.
This is where Cybersierra comes in. Our TPRM solution simplifies complex third-party relationships and strengthens an organization’s security posture. It provides a comprehensive view of the third-party ecosystem, identifies and prioritizes risks, and deploys targeted risk mitigation strategies. What’s more, it gives you a dashboard view of your vendor’s security posture at any time, instead of the static, one-time snapshot from traditional security questionnaires.
Schedule a demo now to see how Cybersierra can streamline your TPRM processes. Our platform effectively mitigates third-party risks so you can focus on driving business growth through strategic partnerships.
FAQs
Who falls under the category of a third party?
A third party or vendor can be broadly defined as an external entity with which an organization has entered into a contract or agreement to provide a good, product, or service. This can include suppliers, contractors, service providers, partners, or any other entity outside the organization’s immediate scope that contributes to or impacts its operations.
Why is third-party risk management important?
The importance of third-party risk management (TPRM) lies in safeguarding organizations from cybersecurity threats, supply chain disruptions, and potential data breaches that could lead to reputational damage. It’s not just a matter of best practice; it’s increasingly becoming a regulatory requirement.
Why is continuous monitoring of third-party relationships crucial?
Continuous monitoring of third-party relationships is critical because it allows organizations to identify and address emerging risks in near real-time. It provides ongoing insights into a vendor’s security posture and compliance, ensuring that the organization remains vigilant and proactive in managing potential risks associated with its third-party ecosystem.
Third Party Risk Management
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Srividhya Karthik
Srividhya Karthik is a seasoned content marketer and the Head of Marketing at Cyber Sierra. With a firm belief in the power of storytelling, she brings years of experience to create engaging narratives that captivate audiences. She also brings valuable insights from her work in the field of cybersecurity and compliance, possessing a deep understanding of the challenges and pain points faced by customers in these domains.
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In today’s business landscape, operating without a third-party vendor can be challenging. Therefore, organizations often seek the strategic advantage of third-party vendors. But unfortunately, outsourcing third parties comes with inherent risks that must be actively managed.
Compliance leaders frequently note that organizations often face unforeseen risks following the initial onboarding and due diligence processes. This underscores the inherent complexity of third-party connections and highlights the critical need for comprehensive Third-party Risk Management (TPRM) strategies. While it is not possible to eliminate all third-party risks, establishing a comprehensive third-party risk management framework will help mitigate potential risks associated with each vendor.
“To build pervasive security across that third-party ecosystem, you not only need to know who those third parties are and what they’re doing for you,” said Edna Conway, chief security officer, global value chain at Cisco, “you had best understand the leadership and the operational processes utilized in your own enterprise that manage the commercial relationship with those third parties.” –
It is, therefore, imperative to understand your third-party risks. So, in this blog post, we will detail how to create a suitable third-party risk management framework for your organization and their associated benefits. Let’s get started right away!
What is a TPRM Framework?
A third-party risk management framework evaluates and mitigates potential security risks associated with outsourcing to third-party vendors, partners, suppliers, or service providers. The framework provides a road map for organizations to build customizable risk management programs per their industry best practices.
A TPRM aims to comprehensively evaluate the risk landscape to minimize the likelihood of data breaches and vulnerabilities, and enhance the overall cyber resilience against threats from third-party vendor associations. The evaluation could range from access to your intellectual property to operational, legal, financial, and compliance risks.
There are two main categories under the TPRM framework— 1) Tailored specifically for TPRM or Supply Chain Risk Management program (SCRM) like Shared Risk Assessment TPRM framework and NIST – 800-161. 2) Supplementary information security programs that enhance the TPRM program or assist in vendor risk management questionnaires, such as NIST CSF v1.1. ISO 27001, and ISO 27036. These standards outline building an effective infosec program by effectively managing controls associated with third-party risks.
Why do you need a TPRM Framework?
While most organizations focus on securing endpoints such as servers, routers, and firewalls mostly, it is worth noting that they are not the only threat actors. There could be potential risks from unfamiliar sources such as the networks of trusted third parties too. These connections can become the vulnerabilities that hackers use to infiltrate your defenses! Hence it is important to come up with a holistic third-party risk management framework.
By employing a TPRM framework, companies can increase their understanding of risks and gain insight into the risk profiles of their suppliers and service providers. This way, the business can make conscious decisions on whether it should partner with a given entity or terminate its relationship to safeguard its operations.
Recent research reveals that a startling 62% of data breaches originate from vulnerabilities in third-party vendor relationships. This indicates just how vital having a TPRM framework is for protecting sensitive organizational information. A properly instituted TPRM program enables organizations to consistently uncover and address potential risks, as well as provide a structured approach for developing and deploying effective risk mitigation tactics.
Regulatory bodies demand rigorous third-party risk management. Start with a thorough due diligence, meet contractual obligations, implement internal security controls, and ensure ongoing compliance with security standards throughout the vendor management lifecycle.
A comprehensive TPRM framework is an essential catalyst for meeting these requirements by providing guidelines to comply with the prescribed security standards and regulatory obligations.
Failure to mitigate third-party risks can result in legal repercussions, reputational and financial losses, and more importantly, erosion of customer trust. A TPRM framework acts as a credibility amplifier that protects your business from vendor risks, safeguards your resources and assets, and maintains your trust and reputation in your marketplace.
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Different Components in the TPRM Framework
There is no one-size-fits-all TPRM program; you can customize your TPRM framework based on your business needs.This can be accomplished by either utilizing a TPRM automation software or developing a fully integrated risk management solution. Any effective TPRM approach should incorporate these six essential elements:
Due diligence
Third-party due diligence is a critical step in risk management, allowing companies to evaluate vendors before engaging in a business relationship. This involves conducting background checks and mitigating risks associated with conflict of interest, legal, cyber security, or compliance issues, ensuring these external partners are legitimate, reliable, and won’t harm the company’s reputation or finances.
Risk identification
The next step in choosing a TPRM framework is recognizing and assessing potential risks related to third-party vendors. Here, you evaluate the nature of the risks, such as operational, compliance, or data privacy risks, the scope of the risk, and the involved parties.
Risk assessment
Following risk identification, this phase involves determining the impact of the likelihood of identified risks. By analyzing the severity and probability of various risks, organizations can prioritize them and allocate resources accordingly to manage and mitigate the highest priority risks.
Risk monitoring
Risk monitoring is a sustained practice utilizing specialized tools and procedures to track, assess, and analyze risk factors continuously. This ongoing process enables organizations to stay abreast of changes in the risk landscape, swiftly identify emerging risks, and proactively address potential vulnerabilities in their third-party relationships.
Risk mitigation
This phase centers on mitigating identified risks to an acceptable level. Strategies may involve implementing internal controls, establishing well-defined contractual agreements, conducting routine audits, formulating contingency plans, and fostering transparent communication with third parties. The objective is to minimize the impact of risks, ensuring the ongoing integrity and security of the organization’s operations within the context of the third-party relationship.
Continuous assessment
Continuous vendor monitoring and risk assessments help you align with the industry best practices. It is essential to establish procedures for security incidents related to third-party vendors. This includes reporting, investigating, and remediating any possible security incidents.
How to Choose a Third-Party Risk Management Framework
When choosing a third-party risk management framework for your company, it’s important to carefully assess your company’s specific needs and risk exposure profile. This includes regulatory requirements, tolerance limits on risk, compliance requirements, vendor dependence, and many organizational considerations. Some key matters to consider are outlined below:
Regulatory Compliance & Risk Appetite:
Consider the prevailing regulations in addition to your organization’s risk tolerance
Ensure the framework aligns with regulatory requirements as well as reflects your risk appetite.
Dependence on Third Parties
Determine to what extent your organization depends on third parties Examine growing threats related to outsourcing and usage of technologies such as cloud services.
Core Business Functions Performed by Vendors
Understand that tasks previously handled by internal employees are now carried out by third parties.
Be aware of how the disruptions or failures caused by vendors can affect you. Increased reliance on vendors can amplify risks
Characteristics of TPRM Frameworks to consider:
Vendor risk assessment program: Ensure that it provides a structured approach within which vendors’ risks can be assessed using custom features based upon the nature of the relationships and the significance of services rendered.
Third-party vulnerability detection: Look for mechanisms that identify vulnerabilities, including cybersecurity gaps, and have features that enable vulnerability scanning, penetration testing, and continuous monitoring of third-party environments.
Compliance gap detection: Assess whether the framework enables continuous compliance monitoring with relevant regulations and industry-specific requirements. Look for functionalities that identify compliance gaps and deviations from established standards.
Risk assessment questionnaire: Evaluate if the framework offers automation capabilities for administering security questionnaires and collecting information from third-party vendors. Look for functionalities that streamline the assessment process, automate responses, and provide detailed risk analyses.
Remediation program: Check if the framework supports developing and implementing remediation plans to address identified risks and vulnerabilities. Check for availability of features that facilitate stakeholder collaboration, tracking of remediation progress, and help prioritize corrective actions based on risk severity.
Reporting: Ensure the framework includes reporting capabilities to communicate TPRM activities to stakeholders. Look for customizable reporting templates, dashboards, and metrics that provide insights into risk exposure and mitigation efforts.
Some cyber frameworks that align well with TPRM requirements and security controls include NIST CSF, ISO 27001, ISO 27002, ISO 27019, ISO 27036, and NIST RMF 800-37. These frameworks provide structured approaches to addressing cybersecurity risks and can be tailored to support your organization’s third-party risk management initiatives. By taking into account these elements and establishing a robust TPRM framework, organizations can adeptly handle third-party risks while optimizing the value gained from these partnerships.
How to Create a TPRM Framework
A strong third-party risk management framework helps avoid potential hazards and ensures vendor complexities do not derail a business. It safeguards assets, ensures regulatory compliance, and protects the company’s reputation. Here is an easy process for creating a third-party risk management framework:
1. Engage your stakeholders
The first step towards developing the TPRM framework is putting together a cross-functional team. It’s important to involve representatives from departments like risk management, operations, procurement, finance, IT, cybersecurity, legal, and compliance. This achieves alignment and allows each group to contribute their perspective and expertise in managing vendor risks effectively.
2. Group your third-parties
List down all your third-party service providers. Categorize them based on—the nature of the service or product offered, types of data accessed, the extent of data access and its necessity, and any fourth-party providers availed by the vendor.
Evaluate how important each third-party relationship is for the accomplishment of your organization’s goals. Also, consider geographic location of vendors for regulatory differences or geopolitical instability.
3. Define scope and risk tolerance
After thoroughly categorizing the vendors, define the scope of the TPRM framework by identifying the type of third parties involved and the risk factors to be considered. In addition, determine the organization’s acceptable level of risks.
Determine the organization’s risk appetite and tolerance levels, including cybersecurity, compliance, and operational disruptions. Account for industry-specific regulations and standards when defining the scope of the TPRM framework.
You can implement a risk matrix to categorize all the identified risks based on their criticality. This allows identifying risk thresholds.
4. Establish a TPRM process
Start by drafting vendor onboarding guidelines and pre-screening processing to categorize the vendors per their risk profile. Establish third-party risk assessment questionnaires to gather information on vendors’ internal controls, security practices, compliance, and industry-specific standards and best practices.
These questionnaires should cover areas like data encryption, access controls, regulatory compliance, and financial health, aligning with your organizational needs. Standardized or customized questionnaires can be used depending on our preferences and prevailing practices in our industry.
5. Risk identification and mitigation
Implementing a strong TPRM framework requires identifying and assessing risks systematically. This involves categorizing risks based on their potential impact and likelihood, and then conducting assessments to prioritize mitigation efforts.
Next, effective mitigation strategies, such as implementing security controls or enhancing contractual provisions, are defined. By following these steps, organizations can proactively manage third-party risks and safeguard their operations.
6. Due diligence
Before entering into third-party relationships, you must carry out a robust due diligence to thoroughly assess potential partners’ suitability and reliability. This involves monitoring and evaluating vendor performance, verifying their compliance with the required regulations, and adherence to contractual obligations. By staying vigilant and proactive in vendor management, organizations can develop fruitful partnerships and effectively mitigate risks over time.
7. Incident response plans
Develop corrective action or incident response plans to address security and data breaches, or other incidents involving third-party vendors. Also, establish business continuity and contingency plans to mitigate the impact on organizational operations, in the event of such disruptions or failures in third-party relationships.
8. Compliance
Ensure compliance with the applicable laws and regulations, industry benchmarks, and contractual obligations governing your third-party relationships. Establish open channels of communication with stakeholders, such as executive management, board members, and regulators on TPRM activities, results and risk status.
9. Continuous improvement
Ongoing monitoring and evaluation mechanisms must be implemented for the TPRM framework. This helps in identifying lessons learned from past experiences and highlights emerging risks or changes in the business environment to enhance policies, procedures, and risk assessment methodologies.
10. Training
Develop training modules and awareness sessions to educate employees about their roles and responsibilities in managing third-party risks. Doing this fosters a security-first culture and promotes risk awareness and accountability throughout the organization.
Best practices to maintain third-party risk management framework
A TPRM framework requires continuous monitoring and adoption to changing business conditions. Essential practices to ensure effective risk management in vendor relationships includes:
Develop standards and frameworks for third-party monitoring
Establish standardized operating procedures to be used throughout the organization.
Utilize established risk management frameworks such as NIST and ISO to complement the assessment process and ensure comprehensive coverage of third-party risks.
Risk cataloging and assessment
Catalog cybersecurity risks posed by third-party vendors and assess them based on potential impact and likelihood.
Adjust risk profiles per the changes in vendor operations, the scope of services provided, or any relevant regulations.
Segment vendors based on identified risks and prioritize mitigation efforts according to your organization’s risk appetite.
Conduct due diligence
Conduct annual audits to review the effectiveness of your risk management efforts
Compare performance against pre-defined risk tolerance thresholds.
Identify key security controls and monitor its adherence by the vendors.
Continuous improvement
Implement mechanisms to monitor third-party relationships, including performance, compliance, and risk indicators.
Develop incident response plans to ensure effective responses to security breaches or other incidents involving third-party vendors.
Provide training programs to educate employees and stakeholders on TPRM best practices and emerging risks.
Utilize automation tools for improvement
Leverage technology to automate evaluations and oversights, where possible.
Ensure continuous monitoring and improvement of third-party management processes.
Establish clear success criteria aligned to the level of risk tolerance.
Act on lessons and observations from incidents, audit findings, or best practices in the industry to strengthen due diligence processes.
How does Cyber Sierra help you manage third-party risk?
As emphasized, conducting thorough checks on third-party partners is crucial for businesses. It goes beyond merely ticking a checkbox; it’s an ongoing effort filled with inherent risks.
Developing a robust Third-Party Risk Management (TPRM) program may seem daunting without a dedicated solution. Fortunately, your team can streamline critical processes of your vendor risk management program with Cyber Sierra.
Our unified cybersecurity platform empowers your team to assess, onboard, and manage your vendors’ security and compliance posture in near real-time, enabling you to mitigate vendor risks much faster. Ultimately, Cyber Sierra serves as a proactive partner, integrating governance, risk management, and cybersecurity adherence into a complete cybersecurity solution. Schedule a demo today!
FAQs
How can a TPRM framework benefit your organization?
A TPRM framework provides several benefits, including enhanced risk awareness, better decision-making regarding vendor partnerships, improved regulatory compliance, and protection of organizational assets and reputation. By systematically managing third-party risks, organizations can minimize the likelihood of vulnerabilities, data breaches, financial losses, and disruptions to operations, thereby safeguarding their overall resilience and competitiveness in the market.
How often should you conduct third-party risk assessment?
It is recommended to assess new third parties during onboarding, before audits, upon contract renewals, during incidents, during termination of partnerships, and also periodically whenever there are changes in the control environments.
Is there software for conducting third-party risk assessments?
Yes. There are specialized third-party risk management software and tools to perform risk assessment. These tools enable you to conduct assessments following a questionnaire, automate tasks, manage data, and offer insights into risks, streamlining the entire third-party risk management process.
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Srividhya Karthik
Srividhya Karthik is a seasoned content marketer and the Head of Marketing at Cyber Sierra. With a firm belief in the power of storytelling, she brings years of experience to create engaging narratives that captivate audiences. She also brings valuable insights from her work in the field of cybersecurity and compliance, possessing a deep understanding of the challenges and pain points faced by customers in these domains.
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‘A lot more is now required.’
That’s how I’ll summarize the huge lift in requirements in version two of the Cybersecurity Code of Practice (CCoP 2.0) Regulations. Per KPMG’s assessments, to become compliant, clauses companies must now adhere to jumped 116%, from 102 to a whopping 220:
This increase leaves you, a CISO or company executive charged with leading your team’s compliance efforts, with much more to do. It’s also crucial to note that, after CCoP 2.0 went into effect in July 2022, Singapore’s CyberSecurity Act (CSA) allowed a grace period of just twelve (12) months. The implication of this is that you need some urgency to avoid the hammer.
The first are the organizations in sectors explicitly spelled out by the CSA. Per their official statement, Critical Information Infrastructure (CII) of companies in designated sectors responsible for essential services in Singapore must comply.
They include:
Government
Energy
Healthcare
Banking and Finance
Transport (Land, Maritime, and Aviation)
Media
Infocomm, and
Security and Energy Services
Your company may not be in these sectors.
Regardless, if your organization works with businesses in those sectors, you also need to comply. This is because of the second way the CSA states who CCoP 2.0 is applicable to:
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Key CCoP 2.0 Requirements for CII
As earlier mentioned, across its eleven (11) requirement sections, there are about 220 auditable security clauses in CCoP 2.0.
As shown below:
Protection, Governance, Detection, Operational Technology (OT) Security, Response & Recovery, Cyber Resilience, and Cybersecurity Training & Awareness. These seven requirements all have over half a dozen security clauses. At face value, it may seem like the key requirements for complying with CCoP 2.0 CII revolve around these.
While they do to some extent, the bulk of what’s needed in the clauses under these requirements comes down to creating policy documents. Companies can work with compliance consultants to get these done. Where you want to channel your efforts is on ensuring that your CII systems are actually secured from cyber threats.
Achieving that goes beyond creating policy documents. You need a way to automate processes for governing, detecting, and training employees on ways to remediate cyber threats and vulnerabilities.
And that’s where Cyber Sierra helps.
Our platform enables you to coordinate your entire team and manage multiple compliance audits from one place. For instance, Speedoc, a Singaporean-based tech company, relies on Cyber Sierra for this:
How to Automate CCoP 2.0 Compliance Audit
The CSA applied five design principles in drafting CCoP 2.0. These principles are important because they provide the guardrails to successfully prepare for CCoP 2.0 compliance audit.
They are illustrated here:
Cumulatively, these principles give organizations the flexibility to focus on CCoP 2.0 requirements they deem necessary. With that in mind, the steps below summarizes how Cyber Sierra automates vital requirements involved in crushing a CCoP compliance audit.
Governance
This requirement essentially mandates having qualified employees assigned to the right roles and working collaboratively to:
Provide cybersecurity leadership and oversight
Handle cybersecurity change management
Create policies, standards, and guidelines
Perform periodic internal compliance audits
Select necessary cloud security requirements
Implement vendor risk management framework.
Cyber Sierra makes doing all these easier. With our platform, you can add all employees on your Governance team, assign responsibilities, and work collaboratively from one place:
Protection
Protection is the CCoP 2.0 requirement with the most number of security clauses. Clauses under this requirement primarily force organizations to protect their CII from unauthorized access.
Twelve crucial clauses covered includes:
Privilege access management
Access control
Patch management
System hardening
Database security
Penetration testing
Network segmentation
Windows domain controller
Cryptography key management
Network segmentation
Application security, and
Vulnerability management.
To meet CCoP 2.0’s Protection requirements, having a solid process for detecting threats is an important step. This is because in Clause 5.14.2, the Code states:
To achieve this, you need to automate detecting where threats and vulnerabilities are coming and get insights for remediating them.
And that’s the next vital requirement.
Detection
This requirement can be summarized to one thing: Your organization should have technology for enacting cybersecurity controls that helps your security team streamline processes involved in:
Cyber threat intelligence
Continuous controls’ monitoring
Cybersecurity log management, and
Threat hunting.
Cyber Sierra’s Risk Dashboard automates all that:
As shown, this feature enables your team to filter and scan Critical Information Infrastructure assets continuously. Besides detecting and identifying cyber threats and vulnerabilities that could affect your CII from this, you also get a dashboard with real-time reports needed for compliance audits. On the same dashboard, your team can manage and get factual insights for resolving vulnerabilities.
Cybersecurity Training & Awareness
Clauses under this requirement can be split into two parts:
Cybersecurity awareness programme, and
Cybersecurity training and skills.
Both may sound like the same thing, but they are not. One is about keeping employees aware of existing and emerging cybersecurity attack types. The other is concerned with equipping them with the skills needed to counter threats and effect cybersecurity responsibilities.
To comply with both, in 9.1.3, the CCoP 2.0 mandates that:
Cyber Sierra helps you automate this. Our Employee Awareness suite gives you a single pane to:
Launch and manage employee awareness and training programs
Monitor and nudge employees to complete programs, so everyone is always ready for CCoP 2.0 compliance audits:
Staying Compliant with CCoP 2.0 Regulations
Achieving CCoP 2.0 compliance is flexible.
As the guiding principles used in creating its draft revealed, organizations are free to choose and only comply with CII requirements that are applicable to them. But once those initial requirements have been chosen and their corresponding security controls defined, staying compliant can’t be treated flexibly.
The CSA mandates organizations to implement a continuous cycle of security assessments to enable swift responses to cybersecurity incidents. This was hammered in clause 13.21 of their official documentation of responses to feedback on CCoP 2.0 compliance:
In other words, you should monitor the cybersecurity controls defined in your CCoP 2.0 compliance continuously to stay compliant. Cyber Sierra’s Governance suite enables that.
Organizations leverage it to:
Monitor CCoP 2.0 compliance control breaks continuously
Get practical remediation insights
Assign and remediate risks with teammates collaboratively.
Here’s a peek:
Automate Becoming and Staying CCoP 2.0-Compliant.
Cyber Sierra automates crucial steps involved in becoming (and staying) CCoP 2.0-compliant
Governance & Compliance
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Pramodh Rai
Meet Pramodh Rai, a technology aficionado and Cyber Sierra's co-founder, whose zest for innovation is fuelled by a cupboard stacked with zero-sugar Redbull. With a nimble footwork through the tech tulips across Asia Pacific, he's donned hats at Hmlet (the proptech kind) and Funding Societies | Modalku, building high-performing teams and technologies. A Barclays prodigy with dual degrees from Nanyang Technological University, Pramodh is a treasure trove of wisdom, dad jokes, and everything product/tech. He's the Sherpa in sneakers you need.
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Where there’s sugar, expect unwanted ants.
That has proven true in Singapore. As the country grows into a world-renowned tech hub, it has become a sweet spot for innovative startups and enterprises. So has it for unwanted bad actors.
So much that, in 2022 alone, Singaporean financial institutions (FIs) spent a whopping US$5.7 billion fighting cybercrime and meeting regulations. In one massive phishing attack, for instance, Singapore’s OCBC Bank and its customers lost over US$10.8 million.
With no end to such cyberattacks in sight, more stringent cybersecurity compliance measures were needed. The Monetary Authority of Singapore (MAS) rightly stepped up to update its Technology Risk Management (TRM) Guidelines.
Updating the MAS TRM Guidelines was Necessary
The updated MAS TRM Guidelines adds another item to the already loaded to-dos of CISOs of banks and financial institutions (FIs). But given that cybercrime is getting worse, becoming (and staying) compliant is necessary to help your team achieve cyber resilience.
In other words, threat actors are now more sophisticated. The dire situation means MAS TRM Guidelines helps banks, FIs, and all enterprises working with them to:
Understand their company’s exposure to technology risks.
Ensure IT and cyber resilience by erecting robust risk management frameworks across their company’s operations.
The first and second sections provide an overview of the MAS TRM Guidelines. After that, each section from 3–15 has subsections outlining best practices organizations should follow to become and stay compliant. But as illustrated below, after reviewing all these sections and subsections, we grouped them into three critical areas:
Risk governance and oversight
Third-party risk management (TPRM)
Data and operational security management.
Risk Governance and Oversight
Sections under this area of the MAS TRM Guidelines outline the personnel and frameworks needed to ensure that a technology risk management strategy is established and implemented. The emphasis is first on having a more extensive list of roles appointed into your organization’s board of directors and senior management.
The regulatory body notes:
The importance of these roles can’t be overstretched.
Their combined expertise is needed to oversee the creation and implementation of technology risk management and IT project management frameworks, respectively. Once these personnels have been appointed, it’s best to have them working collaboratively.
That’s where an interoperable cybersecurity platform like Cyber Sierra comes in. Our platform gives you a central place to work collaboratively and implement the needed security frameworks:
As shown, you can add appointed executives for more streamlined collaboration based on their roles. This automatically gives them role-based access controls for overseeing:
The implementation of technology risk management strategy
The erection of a third-party risk management framework
The continuous assessment, management, and remediation of threats and risk necessary to remain compliant.
One benefit of having them collaborate from a streamlined platform like Cyber Sierra is that besides the ease of assigning policies and security controls to them, they’ll work together from a single pane.
More on that as we proceed.
Third-Party Risk Management (TPRM)
Sections 6–10 of the MAS TRM Guidelines, if you look closely, have a lot to do with 3rd party vendor risks. This is probably why the most recent update focuses mainly on third-party risk management. According to the regulatory body, this renewed focus is because:
By this recommendation, assessing risks from 3rd-parties should be prioritized. To do this effectively, it’s best to start by categorizing vendors based on their access to your organization’s sensitive data.
As illustrated below:
Once you’ve categorized vendors, the next step is to create, customize, and send security assessment questionnaires based on that categorization. Cyber Sierra automates this process.
Our platform has globally-recognized vendor risk assessment templates, such as NIST and ISO. Your team can customize them to suit regional requirements for compliance programs like MAS TRM. You can also add and use your own risk assessment templates:
The steps are streamlined into:
Choosing an appropriate assessment template
Customizing it by selecting and editing questions needed to assess a particular third-party vendor
Assigning reviewer(s) with different role-based access control in a few clicks, and
Providing details of the third-party vendor such as where they are located or the assessee type they are:
Through these steps, especially the 4th step, our platform enforces the categorization of 3rd-party vendors, right from sending out security assessment questionnaires. And by automating the entire process from one place, your organization can assess third-party risks and monitor their security postures in real-time.
The last five sections of MAS TRM Guidelines deal with how organizations manage and secure data in their daily operations. Due to the dynamism involved in managing sensitive data, achieving compliance to requirements outlined in these sections calls for continuous monitoring of cybersecurity controls.
That is, your security team should:
Continuously monitor and analyze cyber events
Promptly detect and respond to cyber incidents.
The regulatory body recommends that:
Here’s why this recommendation is vital.
It allows enterprises to identify any changes in a provider’s risk profile over time rather than just at preset intervals, shifting from periodic risk assessments to continuous intelligence.
For instance, your organization outsources technology services to cloud providers like AWS, Azure, Google Cloud, and others. Based on the MAS TRM’s official statement, your security team should automatically, through continuous monitoring, test controls and configurations in those environments. This removes the need for manual checks and provides assurance on cloud-based controls.
Cyber Sierra automates this process:
As shown, in one dashboard, your team can:
Continuously monitor and detect MAS TRM control breaks and their corresponding vulnerabilities.
View details of vulnerabilities related to a control break
Get actionable tips for remediating threats, and
Assign remediation to qualified teammates.
Automate MAS TRM Compliance
Begin the MAS TRM compliance journey in a few clicks. Automate the entire process in one place.
The Consequence of MAS TRM Noncompliance
Brand reputation damage and, of course, fines.
Those are the major consequences of violating MAS TRM Guidelines. Specific to fines, this report noted that the penalty per breach of a TRM requirement can exceed S$1 million. But it doesn’t end there. Multiple breaches of the MAS TRM requirements can result in a multi-million dollar fine for an organization.
This was demonstrated by MAS’s 2023 report of penalized financial institutions. DBS Bank was among those penalized. They were fined a whopping S$2.6 million for violations and noncompliance failures committed between July 2015 and February 2020.
Their case revealed that your organization can still be penalized several years after for noncompliance failures committed today. This necessitates the need to prioritize becoming (and staying) compliant to MAS TRM Guidelines today.
Ease through Singapore’s MAS TRM Guidelines
MAS TRM Guidelines has 15 sections.
Under each section, there are dozens of subsections of requirements organizations must adhere to become compliant. Along with these, their corresponding security controls that must be implemented. To ease the process, it is better to leverage a platform that automates most processes involved:
Our platform has the MAS TRM program built-in.
This means, in a few clicks, you can invite your team and work collaboratively to become (and stay) MAS TRM-compliant, while automating various tasks involved from one place.
Our platform has the MAS TRM program built-in.
This means, in a few clicks, you can invite your team and work collaboratively to become (and stay) MAS TRM-compliant, while automating various tasks involved from one place.
Automate MAS TRM Compliance
Begin the MAS TRM compliance journey in a few clicks. Automate the entire process in one place.
Third Party Risk Management
CISOs
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Pramodh Rai
Meet Pramodh Rai, a technology aficionado and Cyber Sierra's co-founder, whose zest for innovation is fuelled by a cupboard stacked with zero-sugar Redbull. With a nimble footwork through the tech tulips across Asia Pacific, he's donned hats at Hmlet (the proptech kind) and Funding Societies | Modalku, building high-performing teams and technologies. A Barclays prodigy with dual degrees from Nanyang Technological University, Pramodh is a treasure trove of wisdom, dad jokes, and everything product/tech. He's the Sherpa in sneakers you need.
Across these core areas, lots of activities go into implementing an effective cybersecurity CCM program. This piece will discuss examples in these areas. You’ll also see how enterprise security teams simplify implementation processes with a cybersecurity CCM tool.
Before we get to those…
Why Is Cybersecurity Continuous Monitoring Important?
Two main reasons:
You get real-time visibility into your company’s internal controls and cybersecurity infrastructure for taking timely security actions.
Beyond its importance, if implemented properly, the benefits of CCM are enormous. Chief Information Security Officers (CISOs) and enterprise tech execs leverage it to unlock benefits such as:
If you’re just getting started, knowing this is crucial before trying to replicate examples. To help you, we created this cybersecurity CCM checklist relied on by enterprise CISOs and tech execs.
Grab a free copy below. It’d help your security team implement CCM properly, as you aim to replicate the examples that follow:
The Enterprise Cybersecurity CCM Checklist
Enterprise security execs use this checklist to effectively implement cybersecurity continuous monitoring (CCM).
Enterprise Examples of Continuous Control Monitoring
The highlight above brings us to the first example (and prominent use case) of continuous control monitoring in cybersecurity:
1. Compliance Automation
There are numerous privacy laws and regulatory frameworks enterprise orgs must be compliant with today. From global programs such as SOC 2, GDPR, ISO 27001, to local ones like CCPA in California or Singapore’s Cyber Essentials Mark, the list goes on.
Here’s the most challenging part.
Each of these frameworks, whether global or local, has dozens of mandatory security controls. Ensuring each control is working as required by policy, as Gartner notes, is the only way a company remains compliant. And to achieve this, automating the entire compliance processes across all programs is necessary.
That’s a perfect example (and use case) of continuous, automated monitoring of compliance controls. With a pure-play cybersecurity CCM platform, enterprise security teams are able to manage multiple security controls and compliance audits smoothly.
Cyber threats could be external, from hackers looking for misconfiguration to exploit in your IT systems. It could also be internal, from your employees leaving vulnerabilities through which cyber thieves can exploit and steal critical data.
As a result, there’s a need to have a comprehensive overview of your IT, network, and cloud assets. Specifically, you want to continuously find and fix misconfigurations or user behaviors that could lead to data breaches. Doing both simultaneously is how your security team can better secure company and users’ information. This is another example (and critical use case) of a cybersecurity CCM platform.
Vendors will go the extra mile, checking off all security requirements to win a company’s business. But don’t trust them to consistently secure company data once they become part of your company’s 3rd party ecosystem.
This makes ongoing vendor assessments a vital example (and use case) of cybersecurity continuous control monitoring. Using a CCM platform with vendor risk management capabilities, enterprises monitor vendors’ security posture in real-time.
Automating Cybersecurity Continuous Monitoring Activities In One Platform
Done separately, each example of using cybersecurity continuous control monitoring comes with loads of activities. But with an interoperable cybersecurity CCM platform, activities related to monitoring of controls can be automated from one place. This saves your security team more time to focus on more strategic endeavors of securing the company.
Say you wanted to instill automation in your enterprise compliance management and continuously monitor controls. With Cyber Sierra, you get access to all the popular compliance programs, along with each one’s mandatory policies (1) and security controls (2):
It doesn’t end there.
Our platform even automates the process of continuously monitoring security controls of all implemented compliance programs. This enables your compliance team to get notified whenever there are control breaks.
Here’s a peek:
As shown, activities this streamlines in one view include:
Monitoring control breaks of all compliance programs
Viewing details of each control break
Getting tips for remediating each control break, or
Assigning remediation members of your security team.
CCM activities related to cyber threats’ remediation and vendor risk management also need to be automated. And with Cyber Sierra, your security team can monitor a range of controls from the same place.
Take cyber threats’ remediation.
Our platform lets you integrate and connect all IT, network, and cloud assets used across your organization. Once integrated, it continuously monitor and pulls data into a Risk Register, where misconfigurations and user behaviors that could cause breaches are flagged in real-time:
Our platform lets you integrate and connect all IT, network, and cloud assets used across your organization. Once integrated, it continuously monitor and pulls data into a Risk Register, where misconfigurations and user behaviors that could cause breaches are flagged in real-time:
In this view, our Risk Register detected a vulnerable control break (3) by a user (2) of the GSuite cloud asset (1) automatically.
Last but not least are continuous control monitoring activities for third-party risk management. Identifying and mitigating vendor risks can be a handful, as your team must analyze, assess, and monitor 3rd parties’ security postures in real-time. This is why we built Cyber Sierra to enable enterprise security teams to do it all in one place.
Our platform’s TPRM capability automatically and continuously assesses evidence of security controls uploaded by vendors. It is also intelligent enough to flag vendors whose evidence fail verification:
Automate Continuous Monitoring Activities
The activities involved in cybersecurity continuous control monitoring can be daunting, especially if tackled manually or from different tools. But by automating them from a single platform, enterprises can constantly monitor and get full visibility needed for the proper implementation of security controls.
That’s a reason executives at enterprise tech companies rely on a pure-play cybersecurity CCM platform like Cyber Sierra. One example is Aditya Anand, the CTO of Hybr1d. Their security team monitors and gets full visibility of security controls with our platform.
Hybr1d demonstrates that the many activities of cybersecurity CCM can be automated with an interoperable platform like Cyber Sierra.
Your team can achieve the same:
Automate Cybersecurity Continuous Control Monitoring Activities
Ready to see how Cyber Sierra continuously monitors and automates compliance automation, cyber threats’ remediation, and vendor risk management activities?
Continuous Control Monitoring
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Pramodh Rai
Meet Pramodh Rai, a technology aficionado and Cyber Sierra's co-founder, whose zest for innovation is fuelled by a cupboard stacked with zero-sugar Redbull. With a nimble footwork through the tech tulips across Asia Pacific, he's donned hats at Hmlet (the proptech kind) and Funding Societies | Modalku, building high-performing teams and technologies. A Barclays prodigy with dual degrees from Nanyang Technological University, Pramodh is a treasure trove of wisdom, dad jokes, and everything product/tech. He's the Sherpa in sneakers you need.
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The frequency at which cybercriminals are launching new —and more sophisticated— attacks will only increase. To buttress, imagine it takes you 5–7 mins to skim this article. In that short time, hackers would’ve targeted the cybersecurity infrastructures of over 33 enterprises.
And that’s by 2021 estimates:
As the predictions reveal, by 2031, enterprise organizations would be cyberattacked every two seconds. Given this alarming frequency, how can enterprise security teams identify, investigate, and counter-attacks at the pace of cyber thieves?
I wrote this article to help proactive CISOs and Enterprise Security Leaders like you heed this crucial advice. We’d evaluate cybersecurity control types and go through how your security team can implement the right ones with Cyber Sierra.
But first:
What are Cybersecurity Controls?
Cybersecurity controls are measures used by security teams to detect, prevent, and remediate cyber threats. Creating, implementing, and enforcing them ensures the cybersecurity CIA triad —confidentiality, integrity, and availability)— of your company’s IT assets:
As illustrated, without the proper controls, achieving the cybersecurity CIA triad is difficult, if not impossible. The rise of cybersecurity continuous control monitoring (CCM) is as a result of this. Today, enterprises mustn’t just strive to have the right cybersecurity controls, but you must monitor them continuously to always ensure proper implementation.
So for the rest of this article, we’d:
Evaluate types of cybersecurity controls
Go through how to implement and monitor them.
Before that:
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Types of Cybersecurity Controls for Enterprises
All cybersecurity controls revolve around four essentials: People, technology, processes, and strategy. This means you must:
Have the right people on your security team
Empower them with the right technology
Institute the right security processes, and
Have a strategy that tracks the right security metrics.
Across the four essentials outlined above, all control types can be categorized under the core pillars of cybersecurity:
Governance and compliance
Cyber threat remediation
Vendor risk management
Governance and compliance controls
Continuously meeting all industry and government regulations is now a prerequisite for gaining customers’ and investors’ trust. To this end, having the required governance and compliance controls does two crucial things for your enterprise organization:
They help you achieve compliance for highly-sought standards like SOC 2, ISO 27001, GDPR, PCI DSS, and others.
They also help your company continuously improve those controls to remain compliant as new changes emerge.
But the challenge: How do you know the specific controls required for each compliance standard your company must attain?
Each compliance program has dozens of policies, requiring multiple dozens of security controls to be in place. SOC 2, for instance, has 23 mandatory policies and over 96 cybersecurity controls. Creating, tracking, and implementing each can be a stretch, especially when you add those from other programs like ISO 27001, GDPR, and so on.
But with Cyber Sierra, your security team gets a centralized view of all compliance program policies and their corresponding controls:
From the view shown above, you can evaluate:
All the mandatory policies for all the compliance programs your company must become compliant with, and
Each control required under every policy.
Your security team can also implement these controls on the same pane with Cyber Sierra. This is why executives at enterprise companies trust the capabilities of our platform.
One of the ways cybercriminals exploit companies is through loopholes and vulnerabilities in their network and IT assets. To stay one step ahead, enterprise security teams must:
Continuously scan their network and cloud assets for threats.
Implement controls for detecting and remediating them.
With Cyber Sierra, your team can accomplish both.
Our platform lets you integrate and connect all your network, Kubernetes, and cloud assets for continuous scanning. Through our Risk Register, you also get cybersecurity controls from vulnerabilities related to all scanned assets automatically implemented. This means your team can focus on identifying and remediating control breaks:
As shown, Cyber Sierra’s Risk Register automatically detected a vulnerable control break (3) by a user (2) of the GSuite cloud asset (1).
Vendor Risk Management Controls
Third-party vendors, while crucial to all enterprises’ operations, introduce lots of cybersecurity risks. According to Joseph Kelly, EY’s Third Party Risk Leader, enterprise security teams have no option than to find a way to deal with the risks they introduce:
To answer the question Joseph raised…
Have vendor risk management controls for identifying, managing, and mitigating vendor risks. Specifically, you must analyze, assess, and monitor 3rd parties’ security postures in real-time. Your team can achieve this with a platform that automatically assesses evidence of security controls defined by your company. Such a platform should also be intelligent enough to flag vendors who fail verification for immediate remediation.
How to Ease Cybersecurity Controls’ Implementation
Using a centralized platform eases the implementation of all cybersecurity controls. The reason is that cybersecurity controls aren’t mutually exclusive. For instance, those required by compliance programs affect cyber threats’ remediation from cloud assets and third-party risk management.
Research by EY confirmed this.
Their study found that companies using a centralized platform performed vendor risk control assessments much faster:
Done with an automated, centralized platform like Cyber Sierra, enterprise companies can even do more. For instance, a global bank leveraging our platform was able to streamline their entire workflow.
Other cybersecurity controls are better implemented with a centralized, automated platform. Take the ongoing implementation of governance and compliance program controls. With a platform like Cyber Sierra, enterprise security teams get two benefits.
First, all controls of compliance programs you need to become compliant with are auto-consolidated into a single dashboard:
As shown, from this pane, you can:
See what programs a control is attached to
View and update evidence of having that control
Assign control implementation to team members
Add new compliance program controls as they emerge.
Second, after initial implementation, our platform automatically monitors and flags all control breaks for immediate remediation.
Here’s a peek:
From here you can easily:
Monitor control breaks across all compliance programs
View details of each control break
Get action tips for remediating each control break, or
Assign their remediation to anyone on your security team.
Implement Cybersecurity Controls with Ease
A point worth re-stressing is that cybersecurity controls aren’t mutually exclusive. The controls you need for becoming and staying compliant to governance and compliance programs relate to your internal risk management controls. To this end, it makes sense to constantly implement and monitor all controls from a single platform.
Aditya Anand shared how the security team at Hybr1d achieves both with Cyber Sierra’s intelligent, interoperable cybersecurity platform.
Hybr1d shows that to easily implement and monitor cybersecurity controls, enterprise companies should consider using an automated, interoperable platform like Cyber Sierra.
And you can start with a free demo:
Implement & Monitor All Cybersecurity Controls with Ease
Get a 100% free demo to see how Cyber Sierra eases the entire process of implementing and monitoring cybersecurity controls.
Continuous Control Monitoring
CISOs
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Pramodh Rai
Meet Pramodh Rai, a technology aficionado and Cyber Sierra's co-founder, whose zest for innovation is fuelled by a cupboard stacked with zero-sugar Redbull. With a nimble footwork through the tech tulips across Asia Pacific, he's donned hats at Hmlet (the proptech kind) and Funding Societies | Modalku, building high-performing teams and technologies. A Barclays prodigy with dual degrees from Nanyang Technological University, Pramodh is a treasure trove of wisdom, dad jokes, and everything product/tech. He's the Sherpa in sneakers you need.
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Work-related stress has long been the bane of enterprise security execs, mainly chief information security officers (CISOs). For instance, in Nominet’s 2020 research, 90% of CISOs said work-related stress affected their wellbeing and personal lives.
Years after, the situation isn’t getting better.
Threat actors are becoming more advanced by the day. As a result, securing a company’s IT assets, employees, IP, and so on, will only get harder. This has led to higher stress levels, as this recent study found:
Realistically, you can’t wave a magic wand and remove all work-related stress. It is built into the fabric of leading an enterprise security team. However, you can drastically reduce it by simplifying the cybersecurity continuous control monitoring (CCM) process steps.
That’s what we’re delving into today. But first, let’s establish…
What Enterprise Continuous Control Monitoring Process Is
A cybersecurity continuous control monitoring (CCM) process is a collective of the action steps taken to stay one level above cybercriminals. The whole idea is to achieve the golden rule: Prevention is better than cure.
Enterprise security execs use this checklist to implement cybersecurity continuous monitoring (CCM).
Continuous Security Monitoring Process Steps
Four steps enable the cybersecurity CCM process:
1. Consolidate and Integrate Data from Tools
The first step towards achieving CCM is to integrate data from all tools prone to misconfigurations and vulnerabilities into a single platform. This includes critical cloud assets and business tools used across your organization:
Integrating and connecting apps will enable your team to maintain an undated cloud asset inventory. Done with an intelligent, interoperable cybersecurity platform like Cyber Sierra, you get:
Granular data segmentation of integrated assets.
Continuous monitoring of misconfigurations.
More on Cyber Sierra as we proceed.
2. Establish Governance of Security Controls
All risk management compliance programs have security controls that must be in place for an organization to attain and remain compliant. This is true for SOC2, ISO27001, GDPR, and others.
So establishing governance enables your team to know what security controls to prioritize and continuously monitor across programs.
And doing this is easy with Cyber Sierra:
As shown, our intelligent cybersecurity platform automatically aggregates security controls from all implemented compliance programs into one view. From this holistic view, you can:
See programs a security control is attached to.
View evidences of having that control in place.
Assign critical controls to key members of your security team.
Easily create and add new controls to your cybersecurity governance.
3. Automate Vendor Risks’ Assessments
Third-party vendors can introduce risks that undermine your cybersecurity continuous control monitoring efforts. To buttress, research by Verizon revealed that:
Worse, it can take up to 277 days for organizations to detect risks from 3rd-parties, according to IBM. One way to mitigate this as part of the cybersecurity continuous control monitoring process is to automate vendor risks’ assessments.
Cyber Sierra enables your team to do this. For instance, our platform auto-assess evidence of security controls uploaded by 3rd-parties. It also consolidates everything into a single view, where your team can track evidence that failed verifications.
Here’s a sneak peek:
4. Streamline Security Awareness Training
Employees across an entire organization form an important, if not the most important, component of all cybersecurity processes. And continuous control monitoring is no exception.
Ongoing security awareness training is therefore essential for educating employees on the steps outlined above. It is also crucial for equipping them on implementing the ever-changing CCM process.
Cyber Sierra streamlines this in a way that makes sense for enterprise security execs. On the same platform, you can:
Launch new regular cybersecurity training
Monitor ongoing training to ensure employees complete them and stay informed on their responsibilities in achieving continuous control monitoring:
All through the four cybersecurity continuous control monitoring process steps, I showed how our platform helps. Consolidating multiple security tools on a single platform like Cyber Sierra reduces stress for CISOs and enterprise security execs.
Being a pure-play cybersecurity CCM platform, Cyber Sierra has built-in, enterprise-grade capabilities. For instance, the holistic ‘Controls Dashboard’ enable your enterprise security team to continuously monitor controls in near real-time by:
Integrated cloud asset categories or asset types
Custom or standard compliance programs implemented:
As shown, consolidating all security controls into this dashboard enables near real-time risk monitoring. You can also track controls assigned to teammates from the same pane, making it way easier to fix control breaks.
2. Seamless Risk Remediation
An effective cybersecurity continuous control monitoring process should detect threats, control breaks, and promptly remediate them. Achieving this is seamless with Cyber Sierra.
From all controls in your security governance, our platform automatically detects and pulls control breaks into a separate view:
From this view, you can easily assign control breaks for prompt remediation and tracking. Another way Cyber Sierra enables seamless risk management and remediation is through its Risk Register.
Enterprise security teams use it to continuously:
Detect IT assets with misconfigurations and vulnerabilities.
Examine all security controls linked to such assets.
Check the control breaks and assign remediation:
Enterprise tech executives trust Cyber Sierra for simplifying their cybersecurity processes due to the advantages mentioned above. One, out of many examples, is Aditya Anand, the CTO of Hybr1d.
To recap, our recommended cybersecurity CCM process steps are:
Consolidate and integrate data from tools.
Establish governance of security controls.
Automate vendor risks’ assessments, and
Streamline security awareness training.
Typically, each of these steps required a different software product. But most tools often don’t work well together, making the process more complex and stressful for enterprise security leaders.
To solve this, our platform consolidates the core capabilities required into an intelligent, interoperable cybersecurity platform. This way, you can simplify the entire cybersecurity continuous control monitoring process steps from one place:
Simplify the Cybersecurity CCM Process
Access the core tools for simplifying the continuous control monitoring process in one enterprise cybersecurity platform.
Continuous Control Monitoring
CISOs
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Cybersecurity Enthusiasts
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Pramodh Rai
Meet Pramodh Rai, a technology aficionado and Cyber Sierra's co-founder, whose zest for innovation is fuelled by a cupboard stacked with zero-sugar Redbull. With a nimble footwork through the tech tulips across Asia Pacific, he's donned hats at Hmlet (the proptech kind) and Funding Societies | Modalku, building high-performing teams and technologies. A Barclays prodigy with dual degrees from Nanyang Technological University, Pramodh is a treasure trove of wisdom, dad jokes, and everything product/tech. He's the Sherpa in sneakers you need.
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I talk to a lot of CISOs.
Most decry not having enough budget to hire talent and buy every tool needed to implement their desired third-party risk management (TPRM) framework. But even among those who don’t have such challenges, our chats often reveal a common, underlying question:
What metrics do I need to prove my TPRM program is successful? This question is valid to both sides of the spectrum. Because to secure more budget or get approval for next year’s budget, you must establish metrics demonstrating the success of your TPRM program.
In other words, metrics are useful for more than just getting a TPRM program budget approved. They are also crucial for making decisions relative to securing your company from vendor risks.
But the question remains: How do you choose them?
Criteria for Choosing Vendor Risk Management Metrics
There’s no one-size-fits-all criteria.
However, I like Josh Angert’s recommendation for Chief Information Security Officers (CISOs). He hammered on the need to always start with the end in mind when establishing TPRM program metrics.
Based on Josh’s insight, the metrics you choose should cut across key performance indicators (KPIs) and key risk indicators (KRIs). KPIs keep your security team focused on aligning your organization’s TPRM program with business objectives. KRIs, on the other hand, track the prompt identification and mitigation of vendor risks.
So to choose vendor risk management metrics:
Define business objectives relevant to your TPRM program.
Outline mission-critical vendor risks that must be mitigated.
Select enterprise metrics that encompass all of the above:
The rest of this guide explores metrics I see enterprise CISOs using to ascertain the success of their TPRM programs. As we proceed, you’ll also see how our interoperable cybersecurity and compliance automation platform, Cyber Sierra, helps you achieve them.
Before we dive in:
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Enterprise Third-Party Risk Management Program Metrics
By knowing what to measure (i.e., the TPRM metrics below), your security team can know what to improve and succeed.
1. Number of Identified Vendor Risks
This metric measures how many 3rd party risks your security team identifies over time. The objective of this metric, relevant to most enterprise TPRM programs, is to identify as many risks as possible.
As organizations add new vendors, they need to identify all risks and security threats brought into their ecosystems. So the more risks identified over time, the more your security team can demonstrate its understanding of 3rd party risks.
2. Number of Reduced Risks
Identifying an appreciable number of risks over time is good. But demonstrating that they are reducing relative to when your program went into effect is more important.
Say your organization hasn’t added new vendors in the last three months. This metric tracks changes in third-party risks within that period. Less risk means your security team is effective.
3. Cost of Managing Third-Party Risks
Security teams should track this in twofold:
Articulate all direct and indirect costs associated with managing vendor risks before implementing your TPRM program.
Show how these costs have reduced over time relative to the negative business impact mitigated.
Reporting this metric is critical because it’s a great way for board members to see your TPRM program as a value, and not a cost center.
4. Time to Detect Vendor Risks
As the name suggests, this metric helps you track how long it takes your team to detect vendor risks on average. A shorter risk detection time shows that your security team is efficient.
Board members would want to see risks being detected as soon as possible. This is why third-party security managers track and report on how their team has reduced their average risk detection time.
5. Time to Mitigate Risks
How long does your team take to mitigate vendor risks?
This metric measures the answer to that question. Once your team detects risks, they must immediately mitigate them. The faster they do this, the more financial and reputational damage your vendor risk management program will save your company.
The enterprise security managers I talk to use this metric to visualize how they are mitigating risks within a timeframe. By tracking it, you can set objectives for improving your time to mitigate risks over time.
6. Time to Complete Risk Assessments
Vendors are business entities contracted to help achieve your company’s mission or business goals. Putting them through rigorous third-party risk assessment is critical for mitigating risks.
However, it is also important to track how long it takes to completely assess vendors. Security managers should strive to reduce the time it takes to assess vendors for two reasons:
Demonstrate to management how efficiently they are risk-assessing and onboarding 3rd parties into their ecosystem.
You can achieve these with software that streamlines the process of initiating and completing vendor risk assessments in three steps:
As shown above, this streamlined 3-step workflow is built into Cyber Sierra’s TPRM module. So instead of looping between spreadsheets or exchanging endless email threads, enterprise security teams can profile, assess, and manage vendor risks in one place.
Achieve Your TPRM Program Metrics
Profile, streamline vendor risk assessments, and manage third-party vendor risks in one place.
Achieving Vendor Risk Management KPIs & KRIs
Tracking the metrics above is good.
But without context, metrics on a dashboard won’t show how effective your TPRM program is. Worse, they are not so helpful if you can’t tie them to noticeable business objective indicators.
Josh Angert shared why indicators —key performance indicators (KPIs) and key risk indicators (KRIs) —are more important:
Let me rephrase that.
Choosing TPRM metrics is vital. It guides your security team. Management, on the other hand, concerns itself with indicators —KPIs and KRIs— tied to business objectives they can track and use to make decisions. Below are three you should prioritize.
1. Resource Efficiency
Imagine using the perfect blend of ingredients to bake a batch of cookies without wasting anything. Resource efficiency is similar to that. It means using just the right amount of time, tools, people, and budget to implement an effective TPRM program.
Resource efficiency indicates to management that your security team is doing a great job while saving time and money. According to Bryan Littlefair, the CEO of Cambridge Cyber Advisers, to improve this KPI, start by having a mature vendor risk management strategy.
Say your company must address an average of 300 vendor risks per month. Throughput gives management an overview of how quickly your security team is able to do that over a given time period.
This important KPI helps you identify and minimize bottlenecks in your vendor risk management processes, enabling your team to do more in less time. This is essential for achieving selected TPRM program metrics.
3. Process Efficiency
Think of process efficiency like striking the right balance between operational effectiveness and risk mitigation.
It helps management track the speed at which your security team assesses, manages, and mitigates third-party risks. While the first two required having the right strategy, this one is about streamlining core elements of third-party risk management.
And this is where Cyber Sierra comes in.
For instance, you can assess, onboard, and manage third-party vendors much faster with our platform. And for prompt risk mitigation, our software auto-verifies all evidence of security controls uploaded by vendors in response to assessment questionnaires.
Unverified evidence indicates a lack of necessary security measures that could lead to data breaches. With Cyber Sierra, your team can follow up with vendors to resolve this on the same pane:
Achieve Key TPRM Program Metrics
As I’ve stressed, knowing what metrics to choose is how you demonstrate that your TPRM program is successful. But as you choose them, it is equally, if not more important to align efforts towards achieving visible KPIs and KRIs.
Your team can do this by streamlining critical processes of your vendor risk management program with Cyber Sierra. For instance, you get the NIST and ISO TPRM assessment frameworks built into our interoperable cybersecurity platform.
With these critical assessment frameworks in one place, your team can assess, onboard, manage, and mitigate vendor risks much faster:
Achieve Your TPRM Program Metrics
Profile, streamline vendor risk assessments, and manage third-party vendor risks in one place.
Third Party Risk Management
CISOs
CTOs
Cybersecurity Enthusiasts
Enterprise Leaders
Startup Founders
Pramodh Rai
Meet Pramodh Rai, a technology aficionado and Cyber Sierra's co-founder, whose zest for innovation is fuelled by a cupboard stacked with zero-sugar Redbull. With a nimble footwork through the tech tulips across Asia Pacific, he's donned hats at Hmlet (the proptech kind) and Funding Societies | Modalku, building high-performing teams and technologies. A Barclays prodigy with dual degrees from Nanyang Technological University, Pramodh is a treasure trove of wisdom, dad jokes, and everything product/tech. He's the Sherpa in sneakers you need.
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What do Toyota, Okta, and Keybank have in common?
On the surface, not much, given they operate in different sectors —car manufacturing, B2B software, and banking, respectively. But review recent cyberattacks that made the news, and you’ll see the commonality: They all suffered major data breaches in 2022 through third-party vendors. Given these are global enterprises, one would argue they had some kind of Third-Party Risk Management (TPRM) framework in place.
It begs the question:
Why do companies suffer data breaches through third-parties, despite having some way to manage risks?
If you’re a CISO or an enterprise security exec pondering over that question, here’s the likely answer. First, choosing the right TPRM framework is crucial, but it’s not enough. This is because no matter how good one may be, it is only useful if effectively implemented.
And that brings us to the rest of this article.
We’d explore the top enterprise TPRM frameworks you can choose from. More importantly, you’ll see how our interoperable cybersecurity platform, Cyber Sierra, effectively streamlines their implementation.
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In other words, TPRM frameworks developed by NIST and ISO come recommended. But there are variations of these, so choosing which ones to implement should be based on your company’s specific needs.
To help you do that, below are the various frameworks designed by both institutions and their relevance to enterprise TPRM.
However, given the large number of 3rd parties enterprise organizations now work with, private sector organizations can also adopt NIST 800-161. This framework breaks down the supply chain or vendor risk management process into four phases:
Frame,
Access,
Respond, and
Monitor:
Across these phases, there are 19 data security control themes, ranging from employee training to systems and service acquisition.
Generally, the NIST 800-37 RMF outlines steps companies can take to protect their data and systems. This includes assessing the security of systems, analyzing threats, and implementing data security controls. For vendor risk management purposes, section 2.8 of the framework specifically fits the bill. It is invaluable as it helps security teams consider relevant risk mitigation tactics for onboarding new third-parties.
Base your third-party risk assessment questionnaires on security controls in the NIST CSF framework, and your team can accurately assess potential vendors’ cyber threat profiles. This is especially useful for enterprise organizations with strict privacy or regulatory compliance concerns.
4. ISO 27001, 27002, and 27018
The International Organization for Standardization (ISO)developed the ISO 27001, 27002, and 27018 standards. Although known more for implementing governance, risk, and compliance (GRC) programs, these standards can also be used in creating frameworks for evaluating third-party risks.
Specifically, each of these standards have sections guiding security teams to ensure their vendor risk assessments are thorough. This is in addition to each standard helping your team manage a broader information security program across your organization.
5. ISO 27036
Unlike other ISO standards focused more on companies’ overall GRC programs, ISO 27036 series helps organizations manage risks arising from the acquisition of goods and services from suppliers.
ISO 27036 has provisions for addressing physical risks arising from working with professionals such as cleaners, security guards, delivery services, etc. It also has more standard processes for working with cloud service providers, data domiciles, and others.
Elements of an Effective Vendor Risk Management Framework
Notice something in the frameworks above?
Each addresses an element of the TPRM implementation process. For instance, NIST 800-37 enforces risk mitigation tactics for onboarding vendors while the ISO 27001 standard helps security teams design comprehensive risk assessment questionnaires.
This means two things:
First, for effective vendor risk management, companies may need to combine elements from various TPRM frameworks. The elements (or components) to keep in mind are illustrated below:
Secondly, because trying to cut off sections of various frameworks to achieve all necessary elements is too much manual work, there’s a need to streamline the process with a TPRM tool.
This is where Cyber Sierra comes in:
As shown above, our interoperable cybersecurity platform integrates NIST and ISO TPRM frameworks into easy-to-use templates for streamlined implementation.
How to Streamline Third-Party Risk Management Framework Implementation
Effective implementation of an enterprise TPRM framework must have all elements illustrated above. Specifically, it must include components for ongoing risk assessment, due diligence, contractual agreements, incidence response, and continuous monitoring.
Here’s how Cyber Sierra automates the critical ones.
Risk Assessment
This element of a TPRM framework focuses on assessing risks associated with potential third-party vendors. It involves using security questionnaires to evaluate vendors’ security practices, reputation, financial stability, and others.
But there’s a caveat.
Assessee tier (basic or advanced) and possible threats to deal with often depends on a vendor type and their geographic location. To this end, Cyber Sierra enforces security teams to choose a vendor type, geographic location, and if an advanced assessment is needed when initiating each third-party risk assessment flow:
Due Diligence
A study by the Ponemon Institute revealed why due diligence is a core component of an effective-implemented TPRM framework.
They found that:
In other words, don’t expect 3rd parties to be honest about responses to risk assessments on their threat profiles. Instead, use a TPRM platform like Cyber Sierra to auto-verify and automate due diligence on evidence uploaded for each security assessment question:
Contractual Agreements
This component of implementing a TPRM framework requires working with trained legal and compliance professionals. Such expertise is needed for designing custom contractual agreements that effectively outline each 3rd party’s security obligations, requirements, and expectations relative to risk management.
Incidence Response
How will your security team respond to cyber risks and security threats that emerge from vendors in your supply chain network?
This element of an implemented TPRM framework addresses that crucial question. It involves establishing proactive measures for remediating data threats and cyber risks arising from 3rd party vendors in your entire supply chain network.
But to respond to incidents, your security teams must first identify them before they lead to a data breach. This requires proper implementation of the fifth element of a TPRM framework.
Continuous Monitoring
This element of a TPRM framework entails:
Monitoring third-party security controls based on implemented risk management, governance, and compliance policies.
Verifying third-parties’ uploaded evidence of meeting their obligation of having required risk management controls.
Identifying and flagging vendors in your supply chain network without that fail to meet data security requirements.
You can enforce this by asking vendors managed with the Cyber Sierra platform to click on “Get Verified,” say, monthly:
On your team’s dashboard view, our platform automatically verifies vendors’ uploaded evidence of having mandated security controls.
It also flags evidence that fails verification and your team can work with vendors to resolve them on the same pane:
Implement TPRM Frameworks In One Place
As demonstrated in the steps above, you can implement critical elements of an enterprise vendor risk management program with Cyber Sierra. More importantly, our platform lets you choose between the NIST or ISO TPRM frameworks:
This means whichever recommended framework makes more sense for assessing and managing third-party vendor risks in your supply chain, you can do it with our platform without jumping loops.
You can even use both for specific vendors.
Choose (and Implement) Recommended Enterprise TPRM Framework In One Place
Book a free demo to see how Cyber Sierra easily streamlines TPRM Programs for enterprise organizations.
Third Party Risk Management
CISOs
CTOs
Cybersecurity Enthusiasts
Enterprise Leaders
Startup Founders
Pramodh Rai
Meet Pramodh Rai, a technology aficionado and Cyber Sierra's co-founder, whose zest for innovation is fuelled by a cupboard stacked with zero-sugar Redbull. With a nimble footwork through the tech tulips across Asia Pacific, he's donned hats at Hmlet (the proptech kind) and Funding Societies | Modalku, building high-performing teams and technologies. A Barclays prodigy with dual degrees from Nanyang Technological University, Pramodh is a treasure trove of wisdom, dad jokes, and everything product/tech. He's the Sherpa in sneakers you need.
