CC9.2
Points of Focus
Establishes Requirements for Vendor and Business Partner Engagements
The entity establishes specific requirements for vendor and business partner engagements that include- (1) scope of services and product specifications, (2) roles and responsibilities, (3) compliance requirements, and (4) service levels.
Identifies Vulnerabilities
The entity evaluates vulnerabilities arising from vendor and business partner relationships, including third-party access to the entity's IT systems and connections with third-party networks.
Assesses Vendor and Business Partner Risks
The entity inventories, tiers, and assesses, on a periodic basis, threats arising from relationships with vendors and business partners (and those entities' vendors and business partners) and the vulnerability of the entity's objectives to those threats. Examples of threats arising from relationships with vendors and business partners include those arising from their (1) financial failure, (2) security vulnerabilities, (3) operational disruption, and (4) failure to meet business or regulatory requirements.
Assigns Responsibility and Accountability for Managing Vendors and Business Partners
The entity assigns responsibility and accountability for the management of risks and changes to services associated with vendors and business partners.
Establishes Communication Protocols for Vendors and Business Partners
The entity establishes communication and resolution protocols for service or product issues related to vendors and business partners.
Establishes Exception Handling Procedures From Vendors and Business Partners
The entity establishes exception handling procedures for service or product issues related to vendors and business partners.
Assesses Vendor and Business Partner Performance
The entity assesses the performance of vendors and business partners as frequently as warranted, based on the risk associated with the vendor or business partner.
Implements Procedures for Addressing Issues Identified During Vendor and Business Partner Assessments
The entity implements procedures for addressing issues identified with vendor and business partner relationships.
Implements Procedures for Terminating Vendor and Business Partner Relationships
The entity implements procedures for terminating vendor and business partner relationships based on predefined considerations. Those procedures may include safe return of data and its removal from the vendor or business partner system.
Obtains Confidentiality Commitments From Vendors and Business Partners
(For Trust Service Criteria of CONFIDENTIALITY) The entity obtains confidentiality commitments that are consistent with the entity's confidentiality commitments and requirements from vendors and business partners who have access to confidential information.
Assesses Compliance With Confidentiality Commitments of Vendors and Business Partners
(For Trust Service Criteria of CONFIDENTIALITY) On a periodic and as-needed basis, the entity assesses compliance by vendors and business partners with the entity's confidentiality commitments and requirements.
Obtains Privacy Commitments From Vendors and Business Partners
(For Trust Service Criteria of PRIVACY) The entity obtains privacy commitments, consistent with the entity's privacy commitments and requirements, from vendors and business partners who have access to personal information.
Assesses Compliance With Privacy Commitments of Vendors and Business Partners
(For Trust Service Criteria of PRIVACY) On a periodic and as-needed basis, the entity assesses compliance by vendors and business partners with the entity's privacy commitments and requirements and takes corrective action as necessary.
Evidence Requests
| Area of Focus | Artifact | Description |
|---|---|---|
| Risk Management | Supply Chain Risk Management (SCRM) Plan | Documented evidence of a Supply Chain Risk Management (SCRM) Plan. This is program-level documentation in the form of a playbook, concept of operations or a similar format provides guidance on organizational practices that support existing policies and standards. |
| Risk Management | Supply Chain Risk Assessment (SCRA) | Documented evidence of supply chain-specific risk assessment that evaluates risks that are specific to its supply chain. |
| Third-Party Management | Third-Party Service Reviews | Documented evidence of a formal, annual stakeholder review of third-party services for each Third-Party Service Provider (TSP). |
| Third-Party Management | Third-Party Terms & Conditions | Documented evidence of terms and conditions for external systems. |
| Third-Party Management | Third-Party Contracts | Documented evidence of third-party contractual obligations for cybersecurity & data privacy protections. |
| Third-Party Management | Third-Party Criticality Assessment | Documented evidence of third-party criticality assessment that evaluates the critical nature of each third-party the organization works with. |
Policies
- Vendor Information Security Policy - Establishes requirements for managing third-party and vendor risks
Example Organization Controls
- CC9.2.1 - Documented policies and procedures are in place to guide personnel in performing vendor risk assessments and ongoing monitoring.
- CC9.2.2 - A risk assessment is performed on an annual basis that considers risks associated with vendors and business partners. Identified risks are rated using a risk evaluation process and are formally documented with mitigation strategies.
Example Control Objectives
- Vendor risk management - Vendor and third-party risks are assessed and managed through formal risk assessment processes.
Example Evidence
- Critical Vendor SOC 2 Reports - Current System and Organization Controls 2 (SOC 2) Type II reports for critical vendors (GCP, AWS)
- Vendor Inventory - Current listing of vendors with risk classification and review status