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policies/Security/vendor_risk_management_guidance.md

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Vendor & Third-Party Risk Management Guidance

Document owner: [Owner/Role]
Approved by: [Steering Committee / CISO]
Effective date: [YYYY-MM-DD]
Review cadence: [Annually]


1. Purpose & Scope

Implementation guidance for the Vendor & Third-Party Risk Management Policy. Applies to Procurement, Vendor Owners, and Security reviewing onboarding requests.


2. Tiering — Quick Decision Tree

  1. Does the vendor touch TLP:RED or TLP:AMBER+STRICT data, or sit on the kill-chain (per Authentication Policy §2.1)? → Critical.
  2. Does it touch TLP:AMBER data or run a significant business function? → High.
  3. Does it touch only TLP:GREEN data or have limited, non-privileged system access? → Medium.
  4. No system access, TLP:CLEAR only? → Low.

3. Due Diligence — Practical Checklist

  • Request SOC 2 Type II (or ISO 27001 cert) — check the report period, not just that one exists; a report older than 12 months is effectively expired.
  • For Critical vendors without a SOC 2 (common with smaller/newer vendors): require a completed security questionnaire (CAIQ or equivalent) plus a call with their security lead.
  • Cyber insurance: confirm coverage amount is proportionate to potential exposure, not just that a certificate exists.

4. Concentration Risk — Worked Example

Vendor Function Alternative Exists? Exit Plan Status
Cloud IdP Authentication for all staff No (single IdP by design) Required: documented break-glass + 90-day migration runbook — see Authentication Policy §2.11
Payroll processor Payroll Yes (2 alternatives evaluated) Lower priority — market has substitutes
Single MSP running all endpoint management Device security No Required: document in-house fallback capability or dual-MSP readiness

5. Offboarding Checklist

Access revoked within 24h of termination.
API keys/service accounts rotated or deleted.
Data return or destruction certificate received and filed.
Federated trust (SSO app registration, SAML/OIDC config) removed from IdP.
Vendor Owner confirms no shared inbox/shared credential remains active.


6. References