Post on 25-Feb-2016
description
Top 10 Tips for Effectively Assessing Third-Party Vendors
Tom Garrubba, CISA, CRISC, CIPP/ITSenior Privacy Manager, Information Governance & Privacy - Legal | CVS Caremark Office 412.967.8196 | Cell 724.689.6386 620 Epsilon Drive, Pittsburgh PA 15238 thomas.garrubba@cvscaremark.com
3
Top 10 Tips1. One size doesn’t fit all … and it isn’t free!
The Role Players• Regulators & Standard Setters• Customers• The Corporation and the Business Units• The Vendor • Subcontractors/down stream vendors
Who does the real work?• Employees, 3rd party, mix, other …
Program Initiation and Alignment • Formula for Implementation• Centralized• Decentralized• Who pays for it
4
Top 10 Tips
1. One size doesn’t fit all … and it isn’t free2. Determine what data is in-scope for assessment
5
Top 10 Tips2. Determine what data is in-scope for assessment
Who?• Regulators (FTC, Federal Reserve, HHS, FDIC, etc.)• Industry (PCI)• Customers• Own criteria
What Information?• Customer Information• Employee information
Why?• You are compelled to perform due diligence by law, regulation, standard• Your customers demand it as you are putting their info at risk by giving it to another company.
6
Top 10 Tips
1. One size doesn’t fit all … and it isn’t free2. Determine what data is in-scope for assessment3. Accurately & thoroughly describe how the data will flow
7
Top 10 Tips3. Accurately & thoroughly describe how the data flows
Precisely and completely, describe: • Services the vendor will provide; • Customer, employee, & company data and information the vendor will
collect and/or have access to• What the vendor will do with this data and information. • Where this data and information will be processed & stored• How the data will get to the vendor• Any subcontractors to be used
8
Top 10 Tips
1. One size doesn’t fit all … and it isn’t free2. Determine what data is in-scope for assessment3. Accurately & thoroughly describe how the data will flow4. Triage risk – High, Medium, & Low
9
Top 10 Tips4. Triage Risk - High, Medium, & Low
Why?• Focus limited resources• Reduce vendor’s efforts
How?• Short questionnaire – 10 + questions
Who?• Business owner & vendor
Other Benefits• Shape/reduce longer assessment
10
Top 10 Tips
1. One size doesn’t fit all … and it isn’t free2. Determine what data is in-scope for assessment3. Accurately & thoroughly describe how the data will flow4. Triage risk – High, Medium, & Low5. Start with an assessment & data collection instrument
11
Top 10 Tips5. Start with an assessment and data collection instrument
Assessment - A due diligence activity to gain a level of comfort with the overall security, privacy, data protection posture of the vendor
Send a questionnaire to them and have it returned for analysis• Use an existing questionnaire such as the Shared Assessments SIG
“Standard Information Gathering”; Industry standard questionnaire developed by members of the Shared Assessments (www.sharedassessments.org) program• Covers all domains of ISO 27002 as well as HIPAA-HITRUST, PCS-
DSS, CoBIT, NIST, GLBA, Privacy & Cloud, and BYOD • Develop & send your own questionnaire
Have qualified people assess their responses• CISA, CRISC, CISSP, CIPP/US/G/C/IT/IT, …
12
Top 10 Tips5. Start with an assessment and data collection instrument
VAP Phase 1: Pre-Assessment • Obtain all information regarding the scope of work• Find out the data that will be CSTUPID’ed
• Collect• Store• Transmit• Use• Process• Interface• Destroy
• Converse with the assigned BU and/or the vendor contacts to fully understand what, where, and how’s
• If applicable, determine if the assessment will be handled by an internal or external assessor
• Send the vendor the questionnaire to be completed
13
Top 10 Tips5. Start with an assessment and data collection instrument
• Update BU and Vendor Management
• Track CI’s• File BU/Vendor Docs• Remediate CI’s
• Risk Scoring• Re-evaluate Data Type• Reevaluate Location
• Perform Kickoff• Obtain BU and
Vendor Docs• Acquire SIG
Responses• Perform AUP• Document CI’s
• Define Scope• Define Data in use
(CSTUPID)• Distribute questionnaire
Phase 1:Pre-
AssessmentPhase 2:
Assessment
Phase 3: Post-
Assessment
Phase 4: Re-Assessment
14
Top 10 Tips
1. One size doesn’t fit all … and it isn’t free2. Determine what data is in-scope for assessment3. Accurately & thoroughly describe how the data will flow4. Triage risk – High, Medium, & Low?5. Start with an assessment & data collection instrument6. Trust but Verify - Collect evidence
15
Top 10 Tips6. Trust but Verify – Collect evidence!VAP Phase 2: Assessment• Have a meeting with the BU and vendor to discuss contacts, deliverables,
and timelines• Request/Review pertinent documentation from:
• The BU - Contracts, SOW’s, NDA’s, BAA’s• The Vendor - SSAE-16 Type II documents; ISO 27001/2 cert, CMM
level, NAID, …• Review the returned questionnaire responses• Note “contingent items” (non-compliant items, findings, etc.)• Update BU and Vendor Management• Track Contingent Items• Compose the assessment report• File BU/Vendor Documents• Track through remediation all contingent items
16
Top 10 Tips
1. One size doesn’t fit all … and it isn’t free2. Determine what data is in-scope for assessment3. Accurately & thoroughly describe how the data will flow4. Triage risk – High, Medium, & Low?5. Start with an assessment & data collection instrument6. Trust but Verify - Collect evidence7. Accept or remediate non-compliant findings
17
Top 10 Tips7. Accept or remediate non-compliant items VAP Phase 3: Assessment• Contingent Items (aka: issues, findings, observations, etc.)• You can accept the risk associated with a particular item or…• You can require remediation of the item – • Require remediation by the vendor or business unit
• Risk-rate and prioritize as such• Actively monitor until they are closed• Escalate to appropriate levels of management if timelines are not met• Adjust the timelines if the vendor cannot reasonably meet the target dates
• Contingent Items – 3 Types of CI’s• Contractual
• Contracts, SOW’s, NDA’s, BAA’s; DPSR’s, DSA’s; Med-D Waivers; IRB Waivers• These are usually incomplete or out of date
• HR-Related• Drug testing; Background checks; Credit checks
• Technical/Operations• Typical IT/operations-related issues/findings/observations
18
Top 10 Tips1. One size doesn’t fit all … and it isn’t free2. Determine what data is in-scope for assessment3. Accurately & thoroughly describe how the data will flow4. Triage risk – High, Medium, & Low?5. Start with an assessment & data collection instrument6. Trust but Verify - Collect evidence7. Accept or remediate non-compliant findings8. Identify & assess critical, downstream vendors/subcontractors
19
Top 10 Tips8. Identify and assess critical, downstream vendors, and subcontractorsDown Stream Vendors/Subcontractors • If you have a contract with them…
• See if you’ve already assessed them; if not…then assess them!• Request the same documentation as if they were a primary vendor
• If you don’t have a contract with them…• Work with the primary vendor to obtain documentation• Have the primary vendor set up a call to see what the DSV/subcon is willing
to provide• Use the same assessor if possible (they know the scope of work)!
20
Top 10 Tips1. One size doesn’t fit all … and it isn’t free2. Determine what data is in-scope for assessment3. Accurately & thoroughly describe how the data will flow4. Triage risk – High, Medium, & Low?5. Start with an assessment & data collection instrument6. Trust but Verify - Collect evidence7. Accept or remediate non-compliant findings8. Identify & assess critical, downstream vendors/subcontractors9. Determine if/when an on-site review is necessary
21
Top 10 Tips9. Identify and assess critical, downstream vendors, and subcontractors
Have the Primary vendor identify its vendors that: • Will process, have access to or potential access to, transport, store, …
protected data• Are in another country
Determine how the vendor assesses, contracts with, and monitors these vendors • You might have to do some work here – Conference call interview, other
Q & A’s, …
Determine if your staff or External Assessors will be needed!
22
Top 10 Tips1. One size doesn’t fit all … and it isn’t free2. Determine what data is in-scope for assessment3. Accurately & thoroughly describe how the data will flow4. Triage risk – High, Medium, & Low?5. Start with an assessment & data collection instrument6. Trust but Verify - Collect evidence7. Accept or remediate non-compliant findings8. Identify & assess critical, downstream vendors/subcontractors9. Determine if/when an on-site review is indicated10. Determine when a reassessment should be performed
23
Top 10 Tips10. Determine when a reassessment should be performed
VAP Phase 4: Re-assessment • Start planning by determining “what criteria”?• Based on type of data (PCI, PHI, etc.)? Suggestions include:
• PCI = Annual• PHI = Annual• PII = Annual (?)• Company confidential (i.e., strategic) = ???
• Based on the geographic location?• Onshore• Offshore• Offshore but with safe harbor agreements
• Based via scoring system?• Risk Rating (“Scholastic Score”)• SIG • Other GRC tool• In house tool
• Combination of the above?
25
Top 10 Tips1. One size doesn’t fit all … and it isn’t free2. Determine what data is in-scope for assessment3. Accurately & thoroughly describe how the data will flow4. Triage risk – High, Medium, & Low?5. Start with an assessment & data collection instrument6. Trust but Verify - Collect evidence7. Accept or remediate non-compliant findings8. Identify & assess critical, downstream vendors/subcontractors9. Determine if/when an on-site review is indicated10. Determine when a reassessment should be performed and … 11. Retain all assessment data, decisions, & records
26
Top 10 Tips11. Retain all assessment data, decisions and records
Why? • You are going to need them later!
• Regulatory, internal or other audit• Something goes wrong (e.g., negative assessment)• Reassessment
How? • GRC system, SharePoint, or some other centralized system.
Back It Up (Murphy’s Law!)
28
Top 10 TipsBONUS #1: Manage Your External Assessors
They are an extension of your VAP team and should be treated as such• Discuss their progress at least weekly• Ensure they pull you in when the assessment begins to “look bad” - no surprises!• Participate in closing meetings for key/offshore vendors
Make sure vendors will accept their NDA’s• Be prepared for the legal departments to red-line the document!• Be prepared to adjust start/end dates
29
Top 10 TipsBONUS #2: Use Operational Metrics VRB status monitoring• Assessments assigned to assessors• Internal/external assessments open• Pre-assessment review
Stage gates monitoring• Assessor kickoff• How long it takes to get the questionnaire back• How long it takes to resolve AUP items (questions, documentation)• Assessments in management review• Contingencies due in the past 30/60/90/>120 Days