third party risk management policies and procedures pdf

1083 0 obj <>stream UMGC X-1.18 Information Security Risk Management Third parties, fourth parties, and Nth parties are required under HIPAA to employ the same safeguards as the primary organization when dealing with protected health information. Data: Data is element(s) of information in the form of facts, such as numbers, words, names, or descriptions of things from which "understandable information" can be derived. How mature is your third-party risk management program? <> By adhering to a battle-tested framework, you can ensure that your vendor risk management is comprehensive. The Health Insurance Portability and Accountability Act of 1996 (HIPAA) was established to ensure that sensitive protected health information (PHI) would not be disclosed without the patients consent. A fourth party may be subcontracted by a third party. 2 0 obj endobj Contractor: A person or a company that undertakes a contract to provide materials or labor to perform a service. Outsource monitoring and assessment of prospective vendors against ABAC, ESG, SLA requirements and more. The Information Security Team will review the security assessment and determine whether the Third-Party Provider complies with the University security requirements. You can unsubscribe at any time.

East, The European Banking Authority (EBA) Guidelines on Outsourcing Arrangements outlines specific provisions for the European banking sector's governance of outsourcing arrangements and related supervisory processes. !ujbe18GvCi%vljrf/gW Oq6U7Z n4|aA|CdJLzN IM%>%@ay_ "+w>t)-rTLLPU&nkoeL"S X"U60=JgxRs=ksC dnQhc(g+` S ;MC;|3K4$02Rn0=-gHze`1vzh,lWV< `'H8=#cB8th"Koqd>2)1; cv.YV9#"-aJz ,zhoi [l?JJVf$@8O|2y-aTE@9#DIk=pvR2.H{mj*T'G>GQ_x. No classes or services at this location Prevalent Achieves Record-Breaking First Half of 2022 with Over 50% Growth, Prevalent Unveils New Request for Proposal (RFP) Solution, New Study Reveals Organizations Not Equipped to Handle Third-Party Security Incidents, Prevalent is Recognized as a 2022 Gartner Peer Insights Customers Choice for IT VRM.

Help Center Building a clear set of policies can help propel your organizations third-party risk management practices and ensure that risk is considered throughout the due diligence process and vendor lifecycle. 4 0 obj RFP Toolkit for Third-Party Risk Management Solutions: Free Customizable Template and Scoring Sheet! Information: Any communication or representation of knowledge such as facts, data, or opinions in any medium or form, including textual, numerical, graphic, cartographic, narrative, or audiovisual. Join us at an upcoming conference or industry event. % Get a free risk report for your company or one of your vendors. By using our website you agree to our use of cookies. Still concerned about being comprehensive enough in your third-party risk management policies? <> This Policy applies to all University operations involving University Information or its Information Technology Resources. hb```,|ea8(( Zon{y&,28]:SKsnn[=((!bsGCG#"f6c7`U]M56a;` a`*@ 9 0 obj 4 0 obj Just because an organization was low-risk at the time of onboarding does not mean they will remain so.

Contracts between businesses and suppliers must have provisions for fourth parties. Standardization is particularly important when creating your organization's vendor risk assessment questionnaire. More Contact Options, Mailing Address Learn more about our customers across all industries. hO&\->v(N For example, if your company deals with protected health information (PHI), it is important to use your third-party risk management policies to spell out exactly how and when that information is shared with other organizations. Many organizations overlook the importance of having a clear, standardized, and actionable set of cybersecurity policies and procedures. Building a clear set of policies can help propel your organizations third-party risk management practices and ensure that risk is considered throughout the due diligence process and vendor lifecycle. Vendors: Conduct and share self-assessments! See how Prevalent stacks up against the competition. Conduct due diligence for ABAC, ESG, SLA performance, and more. The Third-Party Vendor Security Management program, governed by the Information Security Team is an initiative to reduce the risk to University Data and computing resources from Third-Party Providers. Learn more about how we use cookies by reading ourPrivacy Policy. << /Length 5 0 R /Filter /FlateDecode >> endobj Your policies should clearly define what information is shared with third parties, when it is shared, and what the protocols are for ensuring the information is protected. <> Information Governance, Security, and Technology Policies, UMGC X-1.18 Information Security Risk Management, UMGC 366.10 Contract Review and Maintenance Procedures, UMGC 370.10 Procurement Policies and Procedures. She holds certifications in vBSIMM, CTPRP, ITIL and CPM. The North American Electric Reliability Corporation (NERC) critical infrastructure protection (CIP) standard establishes new cybersecurity requirements for electric power and utility companies to ensure, preserve, and prolong the reliability of the bulk electric system (BES). Any Employee, Contractor, or other Third-Party Provider performing duties on behalf of the University who violates this Policy may be denied access to Information Resources and may be subject to disciplinary action, up to and including termination of employment or contract or pursuit of legal action. If an exception is requested a compensating control or safeguard should be documented and approved. Using these pre-built frameworks can provide excellent guidance regarding the types of controls that should be included in your third-party risk management policies. The term includes computers, mobile devices, software, firmware, services (including support services), and UMGC's network via a physical or wireless connection, regardless of the ownership of the computer or device connected to the network. The Office of the Comptroller of the Currency (OCC) is the group within the Department of the Treasury that charters, regulates, and supervises all national banks and federal savings associations, as well as federal branches and agencies of foreign banks. 8 0 obj Here are some requirements to consider when drafting your policies: The California Consumer Privacy Act (CCPA) regulates business collection and sale of consumer data to protect California residents sensitive personal information and provide consumers with control over how that information is used. All Rights Reserved. This policy is effective as of the date set forth above. View job opportunities and see if Prevalent is right for you. Assess adherence to GDPR, CCPA, NYDFS, and more. The Federal Financial Institutions Examination Council (FFIEC) is an interagency body empowered to establish guidelines and uniform principles and standards for the federal examination of financial institutions. Outsource your vendor risk lifecycle management to our experts. The National Institute of Standards and Technology (NIST) is a federal agency within the United States Department of Commerce. The International Organization for Standardization and the International Electrotechnical Commission (IEC) assemble experts to share knowledge and develop international standards to solve global challenges. FCA FG 16/5 is designed to help financial firms effectively oversee all aspects of the lifecycle of outsourcing arrangements. Regardless of where you are today, Prevalent can help you build a third-party risk management program with unmatched visibility, efficiency, and scale. 0 <> endobj endobj The General Data Protection Regulation (GDPR) is a privacy law that governs the use, movement, and protection of data collected on European Union (EU) citizens. endobj The Stop Hacks and Improve Electronic Data Security (SHIELD) Act is a data protection law that applies to organizations that collect personal information from residents of New York State. Here are some controls we would recommend to build into your comprehensive vendor risk management policies. Before you begin writing your third-party risk management policies, take the time to review your own internal compliance requirements. <>>> G'd7R8jqk0QgY} 3n3&{`4OU3rjYPntK@%iWjj>\ujI_0I)DCL%mCF^C{duo7t. Stay ahead of data, privacy and operational risks from IT solutions and services.

endobj The Third-Party Provider must complete a security questionnaire, known as the Higher Education Community Vendor Assessment Toolkit (HECVAT) and/or provide a copy of their most recent independent security audit or certification reports (i.e., SOC 2, ISO 2700x certification). Without a standardized vendor evaluation process, you cant compare different vendors based on the level of risk they pose to your organization. The platform makes it easy to onboard vendors; assess them against standardized and custom questionnaires; correlate assessments with external threat data; reveal, prioritize and report on the risk; and facilitate the remediation process. Assess, monitor, analyze, and remediate vendor information security, operational, and data privacy risks. Get free breach, reputation, business, and financial monitoring for 20 vendors. UMGC X-1.02 Data Classification When planning out your third-party risk management program you can borrow from widely accepted third-party risk management frameworks such as NIST 800-161 or Shared Assessments TPRM Framework. Minimize the impact of supply chain disruptions and ensure regulatory compliance. 855-655-8682 Design, implement, and optimize your third-party risk management program. Security reviews for third-party providers will cover a single use case and are required upon a new solution acquisition, changes in scope or use cases for current solutions, changes in system design or controls, business transfer, merger, or acquisition, and upon the renewal of current solutions. Offload your assessment, monitoring, and due diligence activities to our experts with these affordable packages. If third-party associates are permitted to subcontract, the SLA should require that the fourth party follow the same cybersecurity guidelines as the parent business. It is designed to improve cybersecurity protections and data breach notification procedures. Third-Party Providers that will store, process or transmit Data must: Sign a Data Processing Agreement (DPA) if applicable. 6 0 obj Discover and assess third parties in 30 days or less. When designing your policies and procedures, make sure to consider broad compliance requirements that may impact business operations. For example, GDPR places strict limitations on how the data of European nationals is stored, protected, and transferred. Fortunately, you dont need to come up with all the controls yourself. Onboarding is an essential, early step in the vendor risk management lifecycle.

Brenda Ferraro brings several years of first-hand experience addressing the third-party risks associated with corporate vendors, services and data handling companies. stream <> 10 0 obj If a corporation was unaware that a fourth party was involved and was the source of a data leak, it would be found liable and subject to fines by regulators. For a more comprehensive list, check out our Vendor Risk Management Checklist post. Get a free TPRM maturity assessment, a comprehensive risk monitoring report, or business & financial monitoring for 20 vendors. Ou1/aQ|.FM(&Fa-;|?T0T2 b(ELN4`tT>3\eVC6rg%!6}$}ap} ^]:Vu]M#za *rA%v7RT (RX-{e fytYQ^v4J baIc\5-pn`>-n7(]jcK8cn5"Fw>^:}BG{s3LQw: Third-party risk management policies should clearly stipulate how and when business units are required to administer questionnaires, as well as define acceptable levels of residual risk. Assess, monitor, analyze, and track supplier contracts, plus financial, reputational, ESG, performance, and compliance risks. Make sure that your organization is operating from a standard set of documentation when dealing with third-party relationships. Well work with you to find a mix of managed services, network membership, and/or TPRM platform access that works best for your organization. Organizations familiar with System and Organization Control (SOC) 2 audits will recognize that these trust services criteria are used to report on the effectiveness of their internal controls and safeguards over infrastructure, software, people, procedures, and data. Youll gain a fast time to value, be equipped to make intelligence-driven decisions, and measurably reduce vendor-related risk all with fewer headaches for you and your team. In addition, you can utilize other frameworks such as NIST CSF v1.1 and ISO 27036 to help you design your vendor risk assessment questionnaires. Get customized recommendations for evolving your TPRM program. endstream <>

It has never been more important to have a clearly defined vendor onboarding process with standardized risk assessment questionnaires and metrics. % Read the latest news about Prevalent and our solutions. Adelphi, MD 20783. Gain insights into vendor cyber, business, and financial risks. 3501 University Blvd. <> We recommend reviewing Shared Assessments and NIST 800-161 to help plan out what your program needs to look like and the types of controls that are worth including. The standard applies to all entities that store, process or transmit cardholder data. The Financial Conduct Authority (FCA) regulates financial firms providing services to consumers and maintains the integrity of the financial markets in the United Kingdom. The ISO 27001, 27002, 27018, 27036-2, and 27701 standards set requirements for establishing, implementing, maintaining and continually improving an information security management system. Information Technology Resource(s): Any equipment or interconnected system or subsystem of equipment that is used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information by UMGC directly or by a third party under a contract with UMGC which requires the use of such equipment. OCC Bulletins highlight the need for an effective risk management process throughout the lifecycle of third-party relationship. In many cases, criminal groups may try to penetrate the fourth party and work their way up the system laterally until they find the PII they are looking for. Make sure to also pay attention to requirements that affect individual business units.

In many cases, only one department, such as marketing, may work with European data. Non-disclosure agreements, third-party risk questionnaires, and service level agreements (SLAs) should be as uniform as possible throughout the procurement lifecycle. BY IV]StV---|Ntzfa"ho-:CR,///tU3 I-V#F\r!Umm;SLCZII-V%^gqimF#nV!Rcci-V_|!UiiA-Vx!fKOOwqqAXO?#;C_vv6?QY-V nKvANn*w={cc#:CRxN;{GyX^nQ(N~kCgHj}vdk3$Uy }1sLT`ckc|c$UzV~[c$U/-ZT#99_fnGWX1X,7sQC_7$OssQUI~WwwwtU,88I}?tUL1;Q/{chLOOJSBCCoNq26mwq^_V1ei'TSSU`$OYYo|}L;gNTd2-['rD'ISQQHv$IMM/iITUU3_uS':IR7>|):IR &nz~$Iel6[^^#G=e2U7F;>_usqqk.X`z t2w{IX,eiZtyh4q@ The GDPR covers any organization that collects, stores, processes, or transfers personal data on individuals in Europe, regardless of the organizations location. The FFIEC IT Exam Handbook is one of a series of booklets on specific topics of interest to field examiners that prescribe uniform principles and standards for financial institutions. Capitalized terms shall have the meaning ascribed to them herein, and shall have the same meaning when used in the singular or plural form or any appropriate tense. 7 0 obj Unify vendor and supplier risk management and compliance throughout the 3rd-party lifecycle. Availability: The principle of ensuring timely and reliable access to and use of Information based upon the concept of Least Privilege. Permit inclusion of UMGC standard security clauses and language in all relevant contracts, which addresses compliance with UMGC security policies, right to audit, right to access, right to monitor and compliance with applicable regulations where feasible. The purpose of this policy is to ensure that all vendors have appropriate controls to minimize risks that could adversely impact Confidentiality, Availability, and/or Integrity of the service or product. %PDF-1.5 % endobj <>/Metadata 219 0 R/ViewerPreferences 220 0 R>> ? Third-party risk can come in a variety of forms. It is critical that you assess the types and quantities of data gathered across the organization to determine compliance needs rather than making assumptions based on your industry.

Larger businesses with hundreds of third-party contractors are most likely to fall into this category. Prior to joining Prevalent, Brenda led organizations through control standardization, incident response, process improvements, data-based reporting, and governance at companies including Aetna, Coventry, Arrowhead Healthcare Centers, PayPal/eBay, Charles Schwab, and Edwards Air Force Base. Failure to do so could result in non-compliance with critical regulatory requirements as well as reputational damage should a third party experience a data breach. UMGC X-1.04 Information Security tO Rx&y_>Hy^ !Miu)HS$ 8"#T`,2_K]"$'mO~$vt+bo3Aq \"&^`2*'Vg*1)D< Fbtp)OMRO*{ YT=f"$F13B$ 3B Third-party risk management policies are even more critical. 3 0 obj You can then pick specific controls for your questionnaires from standard information security frameworks.

xOU6CB@op("5hm^-5`NMkqEjZ Zlj"**"f8SNo2>{|}}#-vA77G=ZRRT}Eze CH*tU)66 2BBBEVe`tb~~~.`iTl|Nwu%"RPPP~~>:@RHF1 I.(hfeddJ!xbN;{h4$kjj@Y<==n^+** In many cases, you may want to require that third-party organizations dealing with sensitive data comply with independent information security requirements such as SOC2 or HIPAA. Conducting a vendor risk assessment prior to onboarding a new supplier or giving a third-party access Sign up for our blog digest, and get early access to educational webinars and research reports. The regulation is designed to protect the confidentiality, integrity and availability of customer information and related IT systems. Based on the security review performed, the UMGC Information Security Team will determine if a comprehensive security assessment will be required prior to entering into any agreement with the vendor. In many cases, we find U.S.-based organizations often rely on NIST, while companies in Europe, Asia, and Africa often choose ISO. This Policy applies to all University Employees as well as adjunct faculty, Third-Party Providers to include contractors, consultants, temporary employees, and other third parties performing duties on behalf of the University. Many information security requirements place strict limits on the type of data that can be shared with third parties. Confidentiality: The principle of preserving authorized restrictions on Information access and disclosure, including means for protecting personal privacy and proprietary information. Vendors should also be continuously monitored for cybersecurity risk, operational risk, and compliance risk throughout the business relationship. Automate third-party risk survey collection and analysis. endobj Any Employee, Contractor, or Third-Party Provider performing duties on behalf of the University with knowledge of an alleged violation of this Policy shall notify the VP of Information Security as soon as practicable. Automate the vendor contract lifecycle from onboarding to offboarding. The 2022 Third-Party Risk Management Study, 2021 Gartner Magic Quadrant for IT Vendor Risk Management Tools, Navigating the Vendor Risk Lifecycle: Keys to Success at Every Stage, The NIST Third-Party Compliance Checklist. Copyright 2022 University of Maryland Campus. Designing a set of third-party risk management policies can seem daunting. Quickly scale your TPRM program by accessing libraries of comprehensive vendor intelligence profiles supported by real-time risk monitoring. Streamline assessment and reporting across 25+ regulations and best-practice frameworks. All University departments engaging third-party IT products or services are required to undergo a security risk review of the requested product or service. endobj xMo@Dzf?K=D9PH@B>c9j(jEGjegE2'U /EXn~2DX&ra0 Periodic review of a Third-Party Provider security posture and continued compliance will be conducted as needed, based upon changes in system use, design or controls, contract renewal or business transfer, merger, or acquisition. Ensure that you consult stakeholders across multiple departments throughout the process to make sure that your policies are implementable and applicable to different parts of the organization. %PDF-1.7 Whether you employ an IT expert or use business services, this is reality. In her role with Prevalent, Brenda works with corporations to build single-solution ecosystems that remove the complexities of Third-Party Risk Management by way of a common, simple and affordable platform, framework and governance methodology. You may have to consider hundreds of vendor relationships across dozens of departments including operations, technology, and accounting. Exceptions to this policy should be submitted to the VP of Information Security for review and approval. stream UMGC is a proud member of the University System of Maryland.

Schedule a personalized solution demonstration to see if Prevalent is a fit for you. UMGC 370.10 Procurement Policies and Procedures. QX=C BY(7}b/1i>uZ2fh3$,df=H?H There are several advantages to adopting third-party risk control strategies and procedures, regardless of how daunting it can be. Identify, analyze, and remediate risk throughout the vendor lifecycle. Hear how customers benefit from Prevalent solutions. Meet our team of industry veterans and our visionary board. Outsource business and financial risk monitoring of your vendors and suppliers. If the subcontracted provider does not adhere to the same information security practices as the primary contractor, then malicious actors may be able to gain access to your organization's data. The Cloud Security Alliance (CSA) Consensus Assessments Initiative Questionnaire (CAIQ) was developed as an industry standard for documenting security controls, and it can be used to aid in security evaluations of IaaS, PaaS, SaaS and other cloud service providers. The New York State Department of Financial Services (DFS) instituted 23 NY CRR 500 to establish new cybersecurity requirements for financial services companies. The Third-Party Risk Management Compliance Handbook reveals TPRM requirements in key regulations and industry frameworks, so you can achieve compliance while mitigating vendor risk. Access on-demand webinars, white papers, RFP templates, and more. Information Security collaborates with the Office of Legal Affairs, the Office of Procurement & Business Affairs, the University Data Protection Officer (DPO), and University Departments to protect Information Technology Resources and digital intellectual property at the University. Before providing a third party with sensitive information, it is critical to conduct extensive third-party due diligence. Several NIST special publications, including NIST 800-53, NIST 800-161, and the NIST Cybersecurity Framework (CSF) have specific controls that require organizations to establish and implement the processes to identify, assess and manage supply chain risk. H20i.T8 ex Rb 1068 0 obj <>/Filter/FlateDecode/ID[<236AA5A5CA9CDE4B8F27B9E71869D7A3><4038222C738C75498F07029D50DF908E>]/Index[1052 32]/Info 1051 0 R/Length 80/Prev 115061/Root 1053 0 R/Size 1084/Type/XRef/W[1 2 1]>>stream endstream endobj 1053 0 obj <. 1 0 obj endstream endobj startxref Hwzj56nNT{2yt:LRo-2s={6G>2NDV`0zg#555T&-- \'O[r3g?S{ntse`4zQ/+t6_}yTWW6\DFFr@7k+kwN}fY\k+eL&t=FVXXXTj.Y"117>K.k+OO. If the Third-Party Provider is non-compliant, compensating controls will need to be implemented and reassessed. Gain a 360-degree view of third-party risk with our self-service SaaS platform for unified assessment and monitoring. The Prevalent Third-Party Risk Management Platform unifies vendor management, risk assessment, and threat monitoring to deliver a 360-degree view of risk.

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