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This is an interesting dilemma, and a question I hear regularly.  It goes like this:

“We have a lot a vendors that don’t want to fill questionnaires out at all.  What do vendors think of SecurityStudio?”

My answer to this is always the same…

3 or 4 years ago, when vendor risk management programs were largely nonexistent, vendors would push back on security questionnaires.  They would dodge, avoid, argue irrelevance, hide, ignore, answer cryptically, lie (in some cases, yes they do), get answers wrong, etc.  Basically everyone was trying to avoid having to fill out any information about security programs.

Now that we’re a few years down the road, vendors are used to this, especially in any regulated industry or anyone that works with healthcare orgs, finance, etc.  We’re a vendor, and we expect our customers to ask us about our security. 

So at this point, if I have a vendor that doesn’t want to give up information about their security, that’s a GIANT red flag for me. 

There are only a few reasons for not being forthcoming to a customer or prospect:

  • What the vendor does is highly sensitive, and they have to protect that information from everyone, including customers.
  • The vendor is a big enough company that they don’t need to respond to prospective customers.
  • A security program isn’t in place or the vendor doesn’t know how to answer the questions.

Each scenario is bad for me as a risk manager:

  • Even if you say you’re highly secure, it’s my responsibility to make sure.  So in scenario one, they would still have to have something they can provide me as evidence they know what they’re doing.  From my side, I can’t just take their word for it.  So give me something.
  • Although they’re a huge company (i.e. AWS, Microsoft, Google) they still pose a risk to us.
  • If they avoid/resist, give excuses, or want to argue about why they don’t need to provide us any information, I assume they don’t have a security program.

When deciding if you should “fire” a vendor, there are many things to consider:

  • Someone in your organization likely wants to do business with this vendor.
  • It could be a significant deal for your organization.  That adds pressure to push them through.
  • How significant is the risk and what could happen to you if they get breached?

There are many more factors obviously, but the point is that it is usually extremely hard to fire a vendor that the business wants to work with.  If you have the authority to pull that trigger, then I would advise using it sparingly.  We enlist the business to help us get the assessment results back if needed, and we prefer to push them into remediation rather than firing them.  SecurityStudio makes remediation really easy, so we prefer to just build remediation plans they can work on.  That way everyone is winning!

I would only fire a vendor if all these questions get answered “yes”:

  • They simply won’t give us information.
  • They argue and avoid enough that they give me the sense that they don’t have a security program.
  • The business has alternative vendors that they can use, and they are ok with the firing.

Short of that, we opt for remediation, or if the vendor won’t cooperate at all, then we opt to have the business waiver the vendor.  That way as a risk manager I can show that I did my due diligence but that the business decided to pursue the relationship anyway.  This is more than just CYA, it’s an important part of the partnership between security and the business.  We don’t want to shut them down, we just want to manage our risk.  They have the right to accept the risk of a vendor that won’t cooperate.  (document, document, document)

The feedback we get regarding vendor willingness to use SecurityStudio has been really good.  Yes, we have definitely seen the same types of patterns (avoidance, arguing, ignoring) but that’s what SecurityStudio is built to overcome.  Automated reminders, questions written in common language, an appealing interface, etc. all contribute to a positive experience for vendors too.  So yes, they have to do something, but the feedback we’re getting is that vendors like the way SecurityStudio works for them. Make it easier for yourself and company, and schedule your demo for SecurityStudio today!

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Within a busy organization, vendor risk management (VRM) can feel like an ideal concept, but can also seem far out of reach.  Armed with a vendor risk management checklist and VRM software, like SecurityStudio, and establishing a vendor risk management program is well within grasp and can take less time, energy, and resources than expected.  The first step to creating a VRM program is to develop a plan.

1. Develop a Plan

The first step in creating a VRM program is to create a plan.  Simple enough, especially with a VRM software program like SecurityStudio.  The great thing about using a program like SecurityStudio is that the vendor risk management workflow is already built in along with most communication.  Everything is centrally located in the program, and vendors move from one phase to the next with everything in plain view.  Most quality VRM programs include a classification phase, and then vendors are typically assessed followed by a treatment plan.  Then there’s steps to repeat the process.  With a plan like this the risk manager (administrator) will need to surround themselves with a quality team to execute the plan.

2. Assemble your Team

As with any vendor risk management program, the risk manager will want a group of professionals to help with inventorying vendors and classifying them.  Talking to your team members and making sure that everyone is onboard will help with participation, and most importantly that they are given context as to how important information security and this particular vendor risk management checklist are to the organization. Team members can lose focus as to how important their role is partly due to the tedious nature of tracking down information.  Putting a date on task also helps with motivating people with completing them.

3. Determine a Timeline

Putting a timeline on tasks for both the team members and vendors helps with moving the process along.  If there’s not a timeline, then it’s easy for the vendor risk management program to be put to the side.  Software programs, such as SecurityStudio, have built-in timelines, but the due dates and timelines can be customized if needed. 

4. Inventory of Vendors

Taking inventory of the organization’s vendors is a key step in becoming defensible.  Whether the organization is using a software program or a spreadsheet, there needs to be a list of vendors that can pose a possible risk in order to be defensible.  This would seem like common sense, but in a lot of situations where organizations don’t utilize a vendor risk management software program, there are incomplete, inaccurate, or outdated spreadsheets floating around in employees’ inboxes.  This alone could make a case for software program like SecurityStudio, where all vendors are located in one centralized location. 

5. Designating a Relationship Owner

The security analyst, risk manager, administrator of the program, or whoever is assigned these responsibilities (usually the same person) is not necessarily the right person who would have access to contact information or would have direct vendor information to accurately answer classification questions.  Generally, the person who works directly with the vendor will be able to answer the questions most accurately.  Of course, this can vary between organizations.

6. Categorizing/Classifying Vendors

Classifying and Categorizing vendors is arguably the most important stage of any VRM program.  VRM programs will measure the risk of each vendor, and with software programs like SecurityStudio, this is done efficiently and objectively.  The decisions made at this stage will set the tone and precedence for all future stages.  In short, if you’re going to get one stage right, this is the one.  An assessment is sent based on this classification.

7. Assess your Vendors

After the classification stage, an assessment is sent based on the results.  This is especially true for vendor software programs like SecurityStudio.  Assessments vary in length and scope based on classification, but it’s best practice to have binary answers to assessment questions of either true, false, or N/A.  If a vendor does have a conditional answer they will be able to explain the answer in another stage (usually during remediation).  Having binary answers to assessments will create a stronger, more objective, assessment. 

8. Establish your Threshold

As vendors start completing assessments, it becomes time to establish best practices if the organization hasn’t already done so.  For whatever method your organization chooses to assess vendors, there should be a minimum threshold as to how much risk the organization wants to take on.  In SecurityStudio, where the scoring is based on a scale similar to a credit score, the program has a recommended threshold, but organizations are able to set their own threshold based on objective results.  Whichever method is chosen, it’s best practice to apply the same standards for all vendors or vendors within a set industry. 

9. Choosing a Treatment Plan

Once the assessment results come back, then it’s up to the organization to determine what to do with the results.  At times it’s a matter of just approving the results, but if the results are not as favorable as expected, then an organization should have a plan in place.  This is another sample of a situation where best practices should be established. If a vendor is far too risky to work with, or if the organization wants to give the vendor a chance to improve their results, there should be clear plan.  In programs, such as SecurityStudio, it’s relatively easy to look back on assessment results, and then choose a plan based on them. 

10. Objectively Repeat the Process

Vendor risk management is a never-ending process, and the VRM program needs to be repeatable in order to be effective at all.  Business relationships change and morph over time, so it would only make sense that the VRM program should adjust to these changes.  Not only would business relationships change over time, but VRM practices will update with time.  Updating the VRM program as new threats present themselves is just as important.  With programs like SecurityStudio, the changes in security practices and updates will be automatic and seamless.

This is what happened in the infamous case of Target Data Breach in 2013 and the vendor risk management checklist is something that might have prevented it.

If you want an easy-to-use automated workflow that evaluates all third-party vendors and brings your weakest links to the surface, schedule a demo with us today!

free information security risk assessment tool

Part of any vendor risk management program involves putting together a list of vendors.  Sometimes this information can be scattered across an organization, and it takes some real wrangling to collect it all.  This is why software programs like SecurityStudio are convenient- because they help create a centralized list of vendors that are easy to update as necessary.  Here are key places to look for your full list of vendors:

1. Accounts Payable Specialist

The Accounts Payable Specialist is the first place that most people look for vendors.  This is probably the most practical place to look, primarily because most companies have to stay on top of their bills.  The Accounts Payable Specialist will have all the company invoices, and in most instances have the most comprehensive list of vendors. 

2. Internal Bookkeeping Software

Sometimes if the company is small enough, all the company debits and credits are collected in a software program and updated by either an accountant or someone who assumes this role.  Usually, this type of program is managed by an Accounts Payable Specialist, but this isn’t always the case in all circumstances.

3. Department Heads

Occasionally, not all vendors will provide an invoice.  What about that free software that employees install on their computers?  This is still considered a vendor and poses a risk.  The department head would know the day to day tasks of their employees and would have a better idea as to what’s installed on their computers and other contact with vendors.

4. Tax Forms

Maintaining a current list of vendors is imperative to any vendor risk management program, but keeping a historical list of vendors is ideal.  Even though the company may not have business transactions with a previous vendor, there’s a good chance that information is kept on file with the vendor and still poses a risk.  Chances are good that this information will be stored on tax forms, so this is an ideal place to look for historical vendor information.

5. Bank Statements

Bank statements are a snapshot of invoices paid and is an excellent source to look up vendors.  The information may not be complete, but it’s still a way to locate vendors that may be flying under the radar. 

6. Credit Card Statements

While not all vendors are going to be included on a credit card statement or even be paid via credit card, it’s still a good place to look for one of those one-off vendors that aren’t necessarily used very often, but still poses a risk. 

If you want an easy-to-use automated workflow that evaluates all third-party vendors and brings your weakest links to the surface, schedule a demo with us today!

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Got a vendor risk management strategy defined? Need help? You’re not alone.

Introduction

People are not inherently good at defining strategies. This is a problem. The problem is worse when considering information security strategy, and more worse when considering vendor (and third-party) security risk management strategy. These assertions come from observations made over more than 25 years, working with a wide variety of organizations.

If you engage in vendor risk management activities, you should have a strategy defined. If you don’t have a strategy, then you’re going to be less effective in achieving anything meaningful to the organization.

This article is dedicated to helping you define an effective vendor security risk management strategy. An effective strategy will help you achieve your organization’s goals with measurable results.

Rule of Thumb: The larger the effort, the more important the strategy. In terms of vendor risk management:

  • More vendors = more important.
  • More people involved in vendor management = more important.

Now, let’s define a basic strategy together.

Start with why.

Strategies start with why. If yours doesn’t, it’s probably not a good strategy.

Another word for why is purpose. I prefer why because it seems that people can relate to it better. I think this is because they can keep asking themselves why for every piece, part, and process in whatever it is we’re trying accomplish.

Simple question. Why are you doing, or thinking about doing, vendor security risk management? If you don’t know the answer to this, then you have no “why”.  If you struggle with your “why”, look at some of these common ones, and consider them when developing yours:

  • We want to manage vendor security risk well.
  • We have to do it because our regulator told us we had to.
  • We want to be defensible, meaning to be able to defend ourselves in court when/if a vendor-related breach occurs.
  • Everybody else is doing it, so we should do it too.
  • We suffered from a vendor-related security breach in the past, and we don’t want it to happen again.

I’ll tell you our why, where I work. We believe that managing risk is core to the definition of information security. We can’t manage information security without managing risk. Vendors pose a risk to the security of our information, so managing risk must include vendors; therefore, vendor security risk management is core to our security program.

There it is; we do vendor security risk management because we believe that it is core to our security program.

You can have more than one why, and I actually encourage it. The more you have, the more focus it can bring. Now, document your why. Document it so you don’t forget it, so you can share it with others, and so you can make sure other parts of your strategy align with it.

Set goals.

Our goals are set by what we define as success.

Goals must be…

  • Measurable.
  • Associated with some function of time (timeline, timeframe, deadline, etc.).
  • Aligned with our why.

Think of the ways you can set measurable goals on a timeline that enables your why to be adequately supported. Your why may be different than ours, but I’ll use us as an example again. We’ll use SecurityStudio in our example. Not only do we sell SecurityStudio , but we certainly use it too!

Our Why:

We believe that vendor security risk management is core to our security program

Goals:

To support our vendor security risk management efforts, we have defined the following goals:

  • 100% of all vendors will be inventoried in a central repository by 3/1/2019.
  • 100% of all vendors will be classified according to inherent risk (sometimes called “impact”) by 6/1/2019.
  • All high and medium impact vendors will be assessed for residual risk by 1/1/2020.
  • Every vendor will be re-classified on an annual basis by the 1st of each year.
  • All high impact vendors will have a S2SCORE of 660 or higher by 6/1/2020, any exceptions must be formally approved by the business unit Vice President.
  • All medium impact vendors will have a S2SCORE of 660 or higher by 6/1/2020, any exceptions must be formally approved by the business unit Vice President.
  • At no time will a vendor S2SCORE of 600 or less be accepted by the organization.

Define how.

Now this is where the rubber meets the road. A strategy is worthless if it can’t be enacted or executed against. How will we accomplish our goals? In order to achieve the goals that we’ve set, we’re probably going to need something, or maybe a lot of somethings.

Obviously, one of things that we leverage is SecurityStudio. If you don’t use SecurityStudio, you can either choose to use it, or you’ll need to find something else. If you’re unsure of SecurityStudio and/or how to implement it, schedule a demo with us today. Whatever you use, it must allow you to accomplish all of your goals. SecurityStudio is one thing, but you’re going to need more. You’ll also need (at a minimum):

  • A policy. See our previous article about developing and using a vendor security risk management policy (/blog/vendor-risk-management-policy/). There’s even a free policy template there.
  • Personnel (or time). Somebody will need to do the work. SecurityStudio takes all of the dirty-work out of way, but there still needs to be some involvement. We have a vendor risk management ROI calculator if you’re interested in how much time and money is saved when you use SecurityStudio versus manual processes.
  • Training. The people who will be involved with vendor risk management are going to require some training. SecurityStudio is simple to use, but it’s still good to do some brief training anyway.
  • Procedures. Step-by-step guidance will ensure that the same thing is done every time. This gives us the ability to tweak things and make things more efficient.
  • Budget. Everything costs money nowadays, hard and soft dollars.

That does it for the how. Now combine the high-level how information into your strategy, and give everything a sanity check. Does everything fit, or do you need to adjust? I’ve gone through this same exercise with large companies, and it’s not uncommon to revisit all, or part of the strategy many times before you nail it.

Good luck! If you need help, contact us!

free information security risk assessment tool

 It’s easy for an organization to get caught up in establishing policies, workflows, and procedures for vendor risk management. Without context as to why these policies are important and stressing this to your team, many will lose sight of the primary goal of vendor risk management – to put the organization in a defensible position.  An organization owes it to their customers.  The goal of vendor risk management is to position the organization in a defensible position by taking inventory of all vendors, measuring how much of a risk each vendor poses, assessing each vendor objectively, and then systematically repeating this process.  That’s a hefty goal, so let’s break it down.  

Inventory – Taking inventory of all vendors

The first step to mitigating risk is to take inventory of all vendors.  This list includes everything from the organization’s HVAC technician, cleaning service, insurance broker, and even the free online software provider.  These are all considered vendors, and while not all of them have the same access to sensitive information, many vendors will have some access to the organization’s information either physically or otherwise.  The goal of taking inventory of your vendors is to make sure that all the vendors within an organization is accounted for.  Quite simply, you don’t know, what you don’t know.

Classify – Measuring how much of a risk each vendor poses

Not all vendors will have access to the same amount of information, but it’s important to sort your vendors into buckets.  Using the same classification method puts all your vendors into perspective, and puts the organization in a defensible position.  The HVAC technician won’t necessarily have the same impact as an insurance broker that has access to sensitive information.  However, both vendors pose a risk – SecurityStudio has three impact levels – high, medium, and low.  By classifying vendors objectively, the right course of action can be taken to assess them appropriately. 

Assess – Assess each vendor so that the appropriate action can be taken

The goal of the assessment process is to make sure that the right questions are being asked, and that the same questions are being asked of all vendors within the same bucket.  This again will put the organization in a more defensible position. The goal of the assessment process is to be as objective as possible and to complete due diligence.  It’s important to ask these questions now, so that in the case of an adverse event, the organization is still defensible.  Tools, like SecurityStudio, makes it easy.  SecurityStudio offers a comprehensive list of questions, and the program tags who answers the questions and timestamps when the questions are answered.  The ultimate goal of the assessment is to have an objective overview of the vendor’s security posture so that the organization is able to make an informed decision to either go into business or continue doing business with the vendor.  Once the results of the assessment are given, then it’s a matter of replicating the process on a regular timely basis, or as the business relationship changes. 

Now that the goal is broken down, it puts things in perspective.  Yes, organizations are pressured to develop a vendor risk management program by regulatory laws, but it’s more than that.  It’s just the right thing to do.  Organizations owe it to customers to make sure that the information they provide is secure by mitigating risk the best they can and putting themselves in a defensible position.  This is the primary goal of vendor risk management.

To put your goals to action and get an easy-to-use automated workflow that evaluates all third-party vendors and brings your weakest links to the surface, schedule a demo with us today!

Vendor Risk Management Goals
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For most organizations, measuring vendor risk management is extremely difficult, if not, impossible.  That’s because they’re either doing nothing to manage vendor security risk or they are using a method that isn’t conducive to measurement.

Here are a few helpful statistics to measure in any VRM program:

  • Overall risk exposure
  • Trending of overall risk
  • Riskiest vendors both from an operational risk standpoint as well as impact
  • Individual vendor trending
  • Number of total vendors
  • Number of high risk vendors
  • Specific areas that are a significant risk across multiple vendors

Your VRM program should be reportable.  Most C-suites or boards would like an update at some frequency on both the overall security program but also the VRM program.  Having these types of statistics easily reportable is a huge plus to the information security program in general.

Use statistics like these to keep leadership informed of the current state of the program as well as to justify the need to continue managing 3rd party risk.

SecurityStudio leverages S2SCORE in order to be able to give you all the statistics and reports you need to stay on top of your VRM program. Schedule a demo with us today so see how we can help with your VRM program!

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What it is, why you need it, and how to use it.

You might be thinking something like:

“Meh! We don’t need another policy that nobody will read! Policies are a waste of time, especially a Vendor Risk Management Policy!”

I get it. People aren’t thrilled by policies. They’re not exciting. They’re not fun either. For some, policies can even be painful.

Policies get a bad rap. Not because they’re evil or anything, but because people rarely use them well. The fact is, information security policies play a very important role in supporting all information security efforts, and a vendor risk management policy plays a very important role in supporting our vendor risk management efforts.

I don’t like wasting people’s time, so I’ll get right to the point. Most policy problems are founded in the confusion about what a policy is, why they need one, and how they should be used. So, let’s address this as simply as possible. After all, complexity is the enemy of good information security (remember this always).

NOTE: In some organizations, vendor risk management and third-party information security risk management have slightly different meanings. Third-party information security risk management is part of a greater vendor risk management effort. For the purposes of this article, we’re using vendor risk management and third-party information security risk management synonymously.

What a Vendor Risk Management Policy is

The “what” for any policy are the rules. Think of this in terms of a game. A policy defines the rules for the game. A vendor risk management policy defines the rules for the vendor risk management game. Simple.

If you’ve never played the vendor risk management game before, this could be a difficult policy for you to define. If this is you, ask someone you trust for help. Here are two options for you right now:

  1. You can download our template. Change the rules to fit the game that you’re willing to play and make it yours.
  2. Contact SecurityStudio – The experts at SecurityStudio will make sure you get all the answers you need.

There are some typical structural things that should found in every policy, including this one. Policies should contain a purpose statement, note the audience for the policy, the policy status (draft, approved, adopted, etc.), version, date, the policy itself (the rules), references (to standards and/or other documentation), enforcement intentions, and version history.

Your game, your policy. Don’t expect someone else’s policy to fit as-is, and don’t include rules that you don’t intend to play by.

Why you need a Vendor Risk Management Policy

If the “what” for policy are the rules, the “why” for policy is communication. Policies are used to communicate the rules to others. You don’t need a policy if you don’t have anyone to communicate the rules to. Good news, right?

Before you rejoice, it’s very unlikely that you have no one else to communicate the rules to. There’s almost certainly someone else who needs (or wants) to know the rules.

Think about who needs to know the rules for your vendor risk management game. The list could include:

  • Anyone else within your organization that participates in vendor risk management activities.
  • Anyone who’s interested in your organization’s vendor risk management activities (examiners, regulators, partners, etc.)
  • Anyone who’s ultimately responsible for your organization’s vendor risk management activities, including executive management and the board of directors (if one exists).

The more people who need to know about your rules, the more important the policy becomes. In a small organization where there is a single person who does all the vendor risk management activities, there’s less importance. Not “no” importance, just less importance.

How to use a Vendor Risk Management Policy

Once you’ve written a policy, it’s time to figure out how to use it. Every policy, including this one, must be approved, communicated, adopted, and adjusted (or revised). This is a policy lifecycle that is well understood by most.

  • Draft – The policy is drafted (as v1 in new policies, as incremented version in subsequent cycles).
  • Approve – The policy must be approved by someone with authority (executive management, BoD, etc.).
  • Communicate – The policy must be communicated to all personnel who are affected by it.
  • Adopt – Gap analysis (or audit) coupled with plans and projects to ensure compliance.
  • Review/Revise – Periodic (and regular) review of policy, suggested edits move forward.

Policies are reference documents and should be written this way. Let’s go back to our game comparison.

When you sit down with friends to play a new board game, how many people read the rules? Just one, and this is the de-facto person who oversees the game. How many people should read your policies (rules)? Just the person (or group) who oversees the game. As the game is played, the rules are referenced whenever a question comes up. Same goes for policies.

That’s it. Simple. Define the rules for vendor risk management, communicate the rules, and manage the rules. Vendor risk management policy in a nutshell.

Having a policy in place is great, but also having a workflow that evaluates all third-party vendors and brings your weakest links to the surface is even better. Schedule a demo with us today to get your easy-to-use vendor risk management program.

free information security risk assessment tool

Information security programs are around to protect the data of the businesses they are a part of. Understanding risk is an important part of that, but ultimately it’s the business’s job to make decisions on what types of risks they are willing to accept. It’s the information security program’s job to make informed recommendations about those risks. Sometimes, though,  those recommendations are ignored.

While it’s important to make decisions that are best for the business, deviating from security recommendations can pose challenges. It’s important that you maintain a simple, standardized, and defensible information security program (and vendor risk management specifically). Certain business decisions detract from that.

Simplify

We fully understand that a business’s first goal is to make money. That’s why businesses exist. Security programs are meant to create efficiencies that align with your business objectives to be a driving force for profit— not the other way around. However, if you chose to make decisions independent of our security teams’ recommendations, you can actually do the opposite.

Information security programs (and their vendor risk management initiatives in particular) can have a monumental impact on the efficiencies of an organization— especially as it pertains to employee time.

People in information security programs are often required to chase down vendors. You need to have an inventory of all of our vendors so that we know who poses threats to you. In order to do that, your security team will start at accounts payable, get a list of the current vendors your business works on, and then spend ludicrous amounts of time trying to understand the level of risk that vendor poses.

Because your information security professionals have a limited understanding of what each vendor does, they have to get an idea from the person who works with them most closely how their interactions may pose security threats. You now have two employees taking up their time to get this information figured out.

Once this is finally determined, the information security employee is going to send out a questionnaire or spreadsheet to the vendor in hopes that the person on the other end is the right contact, that they’ll fill it out correctly, and that they won’t have to be chased down every three weeks to see if it’s been completed yet.

Do you see how time-consuming this can be?

A vendor risk management tool automates many of these processes. It eliminates the chasing, the back-and-forth, and the manual entry your information security employees would otherwise go through. Because of this, their time can instead be used on the things that will make the most positive impact on your bottom line. The same is true with the non-security employees that have to assist.

You may decide that you don’t want to spend the money on an automated solution to help you smooth down these processes. Doing these things without systems, though, creates unnecessary complexities— and complexity is the enemy of security and business.

Standardize

Standards are crucial when it comes to information security. There are rules, guidelines, principles, and best practices that should help feed your information security decision-making.

Information Security Industry Standards

Certain industries have requirements and regulations they are asked to follow with regards to information security. If your organization fits their threshold, you likely have no choice but to comply. While these standards don’t necessarily provide the perfect example of what security is, they do provide good foundational rules to follow. Deviating from the rules of industry standards can have two effects.

This is actually an example of where deviating from rules and standards can be a good thing. As mentioned before, security standards often provide a good foundational base for your security programs, but they are often just that— a minimum requirement that helps you get started. Businesses can (and should) deviate from industry standards by adding to them. Adding measures on top of what the industry standards suggest you accomplish in your security program is an important step in bolstering your protections.

The opposite side of that coin is choosing to skip or ignore standards that are required by your industry regulations. Doing this can severely damage your business. Payment card industry (PCI) compliance is a good example of this. Many small businesses choose not to go through the steps of being PCI compliant because of the time, effort, and money that goes into complying. However, a breach that impacts your customers’ credit card information often creates irreprehensible financial and reputational losses that could end up forcing you to close your doors permanently.

When it comes to vendor risk management, the same concern applies. You can choose to deviate from acceptable industry norms, here too. Some organizations choose to change up the assessment questions that they ask their vendors to complete regarding their risk. Doing so may push you outside the compliance threshold within your industry standards and it also requires someone to justify the changes. Justification relies on subjectivity, rather than objectivity, and makes it significantly more challenging to explain if you needed to defend your decision.

Internal Standards

Standards are one way to get everyone within your business on the same page about things like acceptable risk levels, information security spending, incident response measures, and more. Implementing a set of policies and procedures that are standard across your organization, and across organizations similar to yours, ensures that you’re taking the appropriate measures to mitigate risks and protect your business.

Deviating from your internal standards proves that they aren’t the right standards. If you feel that you need to make decisions that go against the standards of your organization, they clearly aren’t working for your business. And you won’t be able to expect others to follow them if you aren’t either.

Your risk increases as you deviate from standards too. Take the S2SCORE for example. You can use risk assessment metrics like S2SCORE to set a risk threshold you want your organization and vendors to uphold. You might make a decision that everyone needs to be above a 650 in order to continue working with them. Sometimes, though, the business might feel the need to make a decision outside the standards set in place. You may work with an organization whose business is critical to the success of yours. Therefore, you may want to accept them as a vendor despite their S2SCORE being 550 instead. While it’s important you make these kinds of decisions if you feel they’re critical to the business, it’s also important to understand that this increases the likelihood your data is compromised.

Defend

Ultimately, creating standards and sticking to them is all about making your organization more defensible in the event that something does go awry and your data is compromised. Breaches do happen. Often. It’s impossible to prevent all breaches.

Deviating from standards makes your business less defensible when a breach happens.

If your business feels they need to make exceptions to rules for its benefit, that’s fine. If you make a system standard, you just have to defend the standard. Make sure you’re taking a logical and objective approach to all of your exceptions before implementing them. This will help you stay defensible (and help you ensure that your decisions aren’t going to have a negative impact on your security).

If you make decisions that deviate from standards, customize systems too much, etc., it becomes increasingly more difficult to explain your case to those who are asking. Unfortunately, a breach’s impact stretches beyond your boardroom. Customers, news outlets, lawyers, and more will be asking questions about how and why things happened the way they did— and what you plan to do about it.

Particularly on the legal side and the industry regulator side of this, you’re going to have to explain why this incident happened. If you make exceptions to rules, you have to defend the logic behind the exception. Why you didn’t go with your standard? This is important to think about as we consider making decisions that extend beyond the scope of industry and internal standards that have already been implemented.

Conclusion

While it’s important for businesses to take information security recommendations seriously, it’s also important to remember that information security programs are around to supplement the business’s objectives. For that reason, businesses should be allowed to make decisions outside the scope of industry and internal security regulations. If they do though, there can and will be consequences. Weighing those consequences can be challenging, and it can be difficult to defend the logic behind any deviations. At the end of the day, make if you’re going to make decisions outside the recommendations of information security standards, ensure they still help your business simplify, standardize, and defend.

free information security risk assessment tool

Vendor security risk management is not easy. It’s often a monotonous combination of spreadsheets, questionnaires, following up with people, and uncertainty. It’s often frustratingly tedious, and it can actually cause otherwise strong information security programs to falter. The best relief is to take a three-step approach to vendor risk management. Simplify. Standardize. Defend.

Simplify

Managing information security risk amongst a population of vendors and third-parties is a complex problem for most organizations, and therefore most organizations either don’t manage vendor information security risk management at all, or they don’t do it well.

Don’t Manage Vendor Information Security Risk at All

There are five common reasons why organizations don’t manage vendor information security risk:

  • They don’t have enough confidence in their own information security program.
  • They don’t have experience managing vendor information security risk; where to start or what it’s supposed to look like.
  • They don’t know what questions or things that they should inquire about.
  • They don’t know who all their vendors are.
  • They have other priorities, and don’t get the time to tackle vendor information security risk management.

Question: Why don’t you do vendor information security risk management?

Don’t Manage Vendor Information Security Well

There are five common reasons why organizations don’t manage vendor information security well:

  • Their vendor information security risk management program is incomplete; missing vendors, missing parts of information security, incomplete questionnaires, no scoring/comparison, shortcut inherent risk and/or residual risk, etc.
  • The vendor information security risk management program is painful to manage.
  • The vendor information security risk management is program is disorganized.
  • The vendor information security risk management program relies too much on subjectivity or opinion.
  • They’re just doing something for the sake of doing something. There’s no commitment to doing it right.

Question: What pains do you experience, or what concerns do you have about your vendor information security risk management approach?

Standardize

A vendor information security risk management program must be repeatable and standardized. Standardization enables the other two important features (Simplify and Defend). You need to be doing vendor information security risk management first to truly appreciate the value in standardization. A lack of standardization leads to run-away complexity and a program that is not defensible (against litigation, inquiry from regulators, etc.).

Defend

Defense comes in two forms:

  • Defense against the breach risk posed by your vendors
  • Defense against the lawyers, regulators, and angry customers if or when a breach occurs.

Defense from Vendors

We know that no matter what we do, we cannot possibly prevent all breaches from occurring. So, where are breaches most likely to occur?  According to a recent study conducted by Soha Systems, 63% of all breaches are attributed to a vendor, directly or indirectly. * It’s hard to deny the fact that a breach occurring through a vendor is one of the most likely breach events. There’s no excuse for ignoring the risks posed by vendors or taking a half-hearted approach to vendor risk.

There are five common mistakes organizations make in assessing risk related to vendors:

  • Vendor information security risk management is primarily done to meet a regulatory requirement or to “check the box.”
  • Shortcut solutions are implemented to assess and manage information security vendor risk.
  • The logic behind the vendor information security risk decisions is not tied to how risk works (inherent risk or residual risk).
  • Vendor information security risks are accepted without a clear understanding of the risks or the most effective methods of remediation.
  • High (inherent) risk vendor responses are not adequately validated.

Question: Where are there gaps in your vendor information security risk management program?

Defense from the Crowd

We already know that the most likely source of a breach is through a vendor. Even if we do everything that we can to reduce this risk, some risk will remain. When a breach inevitably happens, we need a defense against a whole new breed of attackers. Lawyers, regulators, public opinion, and our own customers become our attackers. They want answers and they want retribution.

Our defense becomes something called due care. Due care refers to the effort made by an ordinarily prudent or reasonable party to avoid harm to another, taking the circumstances into account.

Nobody expects perfection, but everyone should expect due care. Due care is where defensibility lives, and it’s imperative in our vendor information security risk management program. The question becomes, what would an ordinarily prudent or reasonable party do if they knew a vendor breach was eventual? Not accounting for vendor information security risk is indefensible.

For organizations with vendor information security risk management programs, here are some of the most common reasons why they could be less defensible:

  • Vendor information security risk decisions are subjective— or opinion-based.
  • Seemingly obvious information security risks are not adequately considered.
  • The personnel making risk decisions are not qualified to do so.
  • Roles and responsibilities for vendor information security risk management are not shared amongst qualified groups or are not formally defined at all.
  • The methodology used for vendor information security risk management is not shared by a group outside of your organization, or it is shared by a small group or organizations.

Question: Where is your vendor information security risk management program defensible, and where is it not?

Conclusion

SecurityStudio is the most comprehensive solution to simplify, standardize, and defend. It’s a vendor information security management solution that was built by former vendor risk managers who have walked the walk.

To learn more about how a solution like SecurityStudio can help your vendor information security risk management processes, schedule a demo.

free information security risk assessment tool