Which set of procedures is typically NOT addressed within data privacy policies?
Procedures to limit access and disclosure of personal information to third parties
Procedures for handling data access requests from individuals
Procedures for configuration settings in identity access management
Procedures for incident reporting and notification
Data privacy policies are documents that outline how an organization collects, uses, stores, shares, and protects personal information from its customers, employees, partners, and other stakeholders1. Data privacy policies should address the following key elements2:
The purpose and scope of data collection and processing
The legal basis and consent mechanism for data processing
The types and categories of personal data collected and processed
The data retention and deletion policies and practices
The data security and encryption measures and standards
The data sharing and disclosure practices and procedures, including the use of third parties and cross-border transfers
The data access, correction, and deletion rights and requests of individuals
The data breach and incident response and notification procedures and responsibilities
The data protection officer and contact details
The data privacy policy review and update process and frequency
Procedures for configuration settings in identity access management are typically not addressed within data privacy policies, as they are more related to the technical and operational aspects of data security and access control. Identity access management (IAM) is a framework of policies, processes, and technologies that enable an organization to manage and verify the identities and access rights of its users and devices3. IAM configuration settings determine how users and devices are authenticated, authorized, and audited when accessing data and resources. IAM configuration settings should be aligned with the data privacy policies and principles, but they are not part of the data privacy policies themselves. IAM configuration settings should be documented and maintained separately from data privacy policies, and should be reviewed and updated regularly to ensure compliance and security. References: 1: What is a Data Privacy Policy? | OneTrust 2: Privacy Policy Checklist: What to Include in Your Privacy Policy 3: What is identity and access management? | IBM : [Identity and Access Management Configuration Settings] : [Why data privacy and third-party risk teams need to work … - OneTrust] : [Privacy Risk Management - ISACA] : [What Every Chief Privacy Officer Should Know About Third-Party Risk …]
Which statement BEST describes the methods of performing due diligence during third party risk assessments?
Inspecting physical and environmental security controls by conducting a facility tour
Reviewing status of findings from the questionnaire and defining remediation plans
interviewing subject matter experts or control owners, reviewing compliance artifacts, and validating controls
Reviewing and assessing only the obligations that are specifically defined in the contract
Performing due diligence during third party risk assessments is a process of verifying and validating the information provided by the third parties, as well as identifying and assessing any potential risks or issues that may arise from the relationship. Due diligence methods may vary depending on the type, scope, and complexity of the third party engagement, but they generally involve the following steps123:
Interviewing subject matter experts or control owners: This method involves engaging with the relevant stakeholders from both the organization and the third party, such as business owners, project managers, legal counsel, compliance officers, security analysts, etc. The purpose of the interviews is to gather more information about the third party’s capabilities, processes, policies, performance, and challenges, as well as to clarify any questions or concerns that may arise from the questionnaire or other sources. The interviews can also help to establish rapport and trust between the parties, and to identify any gaps or discrepancies in the information provided.
Reviewing compliance artifacts: This method involves examining the evidence or documentation that supports the third party’s claims or assertions, such as certifications, accreditations, audit reports, policies, procedures, contracts, SLAs, etc. The purpose of the review is to verify the accuracy, completeness, and validity of the artifacts, as well as to assess the level of compliance with the applicable standards, regulations, and best practices. The review can also help to identify any areas of improvement or weakness in the third party’s controls or processes.
Validating controls: This method involves testing or inspecting the actual implementation and effectiveness of the third party’s controls or processes, such as security measures, quality assurance, data protection, incident response, etc. The purpose of the validation is to confirm that the controls are operating as intended and expected, and that they are sufficient to mitigate the risks or issues identified in the assessment. The validation can also help to identify any vulnerabilities or gaps in the third party’s controls or processes.
The other options are not as comprehensive or accurate as the methods described above, as they may not cover all the aspects or dimensions of the third party risk assessment, or they may rely on incomplete or outdated information. Inspecting physical and environmental security controls by conducting a facility tour is only one part of the validation method, and it may not be applicable or feasible for all types of third parties, such as cloud service providers or remote workers. Reviewing status of findings from the questionnaire and defining remediation plans is more of a follow-up or monitoring activity, rather than a due diligence method, as it assumes that the questionnaire has already been completed and analyzed. Reviewing and assessing only the obligations that are specifically defined in the contract is a narrow and limited approach, as it may not capture the full scope or complexity of the third party relationship, or the dynamic and evolving nature of the risks or issues involved. References:
Third Party Due Diligence – a vital but challenging process
The guide to risk based third party due diligence - VinciWorks
Third Party Risk Assessment – Checklist & Best Practices
An outsourcer's vendor risk assessment process includes all of the following EXCEPT:
Establishing risk evaluation criteria based on company policy
Developing risk-tiered due diligence standards
Setting remediation timelines based on the severity level of findings
Defining assessment frequency based on resource capacity
An outsourcer’s vendor risk assessment process should include all the steps mentioned in options A, B, and C, as they are essential for ensuring a consistent, comprehensive, and effective evaluation of the vendor’s performance, compliance, and risk profile. However, option D is not a necessary or recommended part of the vendor risk assessment process, as it does not reflect the actual level of risk posed by the vendor, but rather the availability of resources within the outsourcer’s organization. Defining assessment frequency based on resource capacity could lead to under-assessing or over-assessing vendors, depending on the outsourcer’s workload, budget, and staff. This could result in missing critical issues, wasting time and money, or creating gaps in the vendor oversight program. Therefore, option D is the correct answer, as it is the only one that does not belong to the vendor risk assessment process. References: The following resources support the verified answer and explanation:
Shared Assessments’ CTPRP Job Guide, page 10, section 2.1.1, states that “The frequency of assessments should be based on the risk tier of the third party, not on the availability of resources.”
Guide to Vendor Risk Assessment, section “Step 3: Determine the Frequency of Vendor Risk Assessments”, explains that “The frequency of vendor risk assessments should be based on the level of risk each vendor poses to your organization, not on the availability of resources or convenience.”
How to Conduct a Successful Vendor Risk Assessment in 9 Steps, section “Step 8: Determine the Frequency of Vendor Risk Assessments”, advises that “The frequency of vendor risk assessments should be based on the level of risk each vendor poses to your organization, not on the availability of resources or convenience.”
Which statement is FALSE regarding the methods of measuring third party risk?
Risk can be measured both qualitatively and quantitatively
Risk can be quantified by calculating the severity of impact and likelihood of occurrence
Assessing risk impact requires an analysis of prior events, frequency of occurrence, and external trends to analyze and predict the potential of a particular event happening
Risk likelihood or probability is a critical element in quantifying inherent or residual risk
This statement is false because assessing risk impact does not require an analysis of prior events, frequency of occurrence, and external trends. These factors are relevant for assessing risk likelihood or probability, not impact. Risk impact is the potential consequence or damage that a risk event may cause to the organization or its stakeholders. Risk impact can be measured qualitatively (e.g., high, medium, low) or quantitatively (e.g., monetary value, percentage of revenue, number of customers affected). To assess risk impact, the organization needs to consider the nature and scope of the risk, the potential harm or loss, and the sensitivity or tolerance of the organization or its stakeholders to the risk. References:
How to Manage and Measure Third-Party Risk, OneTrust Blog
Third-party risk, Deloitte
Assessing Risks in Third Parties, ERM - Enterprise Risk Management Initiative
Which cloud deployment model is focused on the management of hardware equipment?
Function as a service
Platform as a service
Software as a service
Infrastructure as a service
Infrastructure as a service (IaaS) is a cloud deployment model that provides users with access to virtualized hardware resources, such as servers, storage, and network devices. Users can install and run their own operating systems and applications on the cloud infrastructure, and have full control over the configuration and management of the hardware equipment. IaaS is suitable for organizations that need high scalability, flexibility, and customization of their cloud environment. IaaS is different from other cloud deployment models, such as function as a service (FaaS), platform as a service (PaaS), and software as a service (SaaS), which provide users with higher-level services and abstract away the underlying hardware details. References:
Cloud Infrastructure: 4 Key Components and Deployment Models
Cloud Deployment Models - GeeksforGeeks
On-Premises Cloud Deployment Model: Organization-Owned Hardware Explained
Which statement is TRUE regarding the onboarding process far new hires?
New employees and contractors should not be on-boarded until the results of applicant screening are approved
it is not necessary to have employees, contractors, and third party users sign confidentiality or non-disclosure agreements
All job roles should require employees to sign non-compete agreements
New employees and contactors can opt-out of having to attend security and privacy awareness training if they hold existing certifications
The onboarding process for new hires is a key part of the third-party risk management program, as it ensures that the right people are hired and trained to perform their roles effectively and securely. One of the best practices for onboarding new hires is to conduct applicant screening, which may include background checks, reference checks, verification of credentials, and assessment of skills and competencies. Applicant screening helps to identify and mitigate potential risks such as fraud, theft, corruption, or data breaches that may arise from hiring unqualified, dishonest, or malicious individuals. Therefore, it is important to wait for the results of applicant screening before onboarding new employees and contractors, as this can prevent costly and damaging incidents in the future.
The other statements are false regarding the onboarding process for new hires. It is necessary to have employees, contractors, and third-party users sign confidentiality or non-disclosure agreements, as this protects the company’s sensitive information and intellectual property from unauthorized disclosure or misuse. Non-compete agreements may not be required for all job roles, as they may limit the employee’s ability to work for other companies or in the same industry after leaving the current employer. They may also be subject to legal challenges depending on the jurisdiction and the scope of the agreement. Security and privacy awareness training is essential for all new employees and contractors, regardless of their existing certifications, as it educates them on the company’s policies, procedures, and standards for protecting data and systems from cyber threats. It also helps to foster a culture of security and compliance within the organization. References:
5 Steps to Effective Third-Party Onboarding
Using a third-party onboarding tool to address new challenges in third-party risk
Onboarding and terminating third parties
CTPRP Job Guide
Minimum risk assessment standards for third party due diligence should be:
Set by each business unit based on the number of vendors to be assessed
Defined in the vendor/service provider contract or statement of work
Established by the TPRM program based on the company’s risk tolerance and risk appetite
Identified by procurement and required for all vendors and suppliers
According to the CTPRP Job Guide, the TPRM program should establish minimum risk assessment standards for third party due diligence based on the company’s risk tolerance and risk appetite. This means that the TPRM program should define the scope, depth, frequency, and methodology of the risk assessment process for different categories of third parties, taking into account the potential impact and likelihood of various risks. The risk assessment standards should be consistent, transparent, and aligned with the company’s strategic objectives and regulatory obligations. The TPRM program should also monitor and update the risk assessment standards as needed to reflect changes in the business environment, risk profile, and best practices. The other options are not correct because they do not reflect a holistic and risk-based approach to third party due diligence. Setting the standards by each business unit may result in inconsistency, duplication, or gaps in the risk assessment process. Defining the standards in the contract or statement of work may limit the flexibility and adaptability of the risk assessment process to changing circumstances. Identifying the standards by procurement may overlook the input and involvement of other stakeholders and functions in the risk assessment process. References:
CTPRP Job Guide, page 17
Third-Party Risk Management and ISO Requirements for 2022, section “Benefits of Implementing Risk Management”
Managing third-party risk through effective due diligence, section “Complying with regulators’ demands”
Third-Party Due Diligence Checklist: 3 Essential Steps, section “Step 2: Conduct a Risk Assessment”
You are reviewing assessment results of workstation and endpoint security. Which result should trigger more investigation due to greater risk potential?
Use of multi-tenant laptops
Disabled printing and USB devices
Use of desktop virtualization
Disabled or blocked access to internet
Workstation and endpoint security refers to the protection of devices that connect to a network from malicious actors and exploits1. These devices include laptops, desktops, tablets, smartphones, and IoT devices. Workstation and endpoint security can involve various measures, such as antivirus software, firewalls, encryption, authentication, patch management, and device management1.
Among the four options, the use of multi-tenant laptops poses the greatest risk potential for workstation and endpoint security. Multi-tenant laptops are laptops that are shared by multiple users or organizations, such as in a cloud-based environment2. This means that the laptop’s resources, such as memory, CPU, storage, and network, are divided among different tenants, who may have different security policies, requirements, and access levels2. This can create several challenges and risks, such as:
Data leakage or theft: If the laptop is not properly isolated or encrypted, one tenant may be able to access or compromise another tenant’s data or applications2. This can result in data breaches, identity theft, or compliance violations.
Malware infection or propagation: If one tenant’s laptop is infected by malware, such as ransomware, spyware, or viruses, it may spread to other tenants’ laptops through the shared network or storage2. This can disrupt the laptop’s performance, functionality, or availability, and cause damage or loss of data or applications.
Resource contention or exhaustion: If one tenant’s laptop consumes more resources than allocated, it may affect the performance or availability of other tenants’ laptops2. This can result in slow response, poor user experience, or service degradation or interruption.
Configuration or compatibility issues: If one tenant’s laptop has different or conflicting settings, preferences, or applications than another tenant’s laptop, it may cause errors, crashes, or compatibility problems2. This can affect the laptop’s functionality, reliability, or usability.
Therefore, the use of multi-tenant laptops should trigger more investigation due to greater risk potential, and require more stringent and consistent security controls, such as:
Segmentation or isolation: The laptop should be logically or physically separated into different segments or zones for each tenant, and restrict the communication or interaction between them2. This can prevent unauthorized access or interference between tenants, and limit the impact of a security incident to a specific segment or zone.
Encryption or obfuscation: The laptop should encrypt or obfuscate the data and applications of each tenant, and use strong encryption keys or algorithms2. This can protect the confidentiality and integrity of the data and applications, and prevent data leakage or theft.
Antivirus or anti-malware: The laptop should install and update antivirus or anti-malware software, and scan the laptop regularly for any malicious or suspicious activities2. This can detect and remove any malware infection or propagation, and prevent damage or loss of data or applications.
Resource allocation or management: The laptop should allocate or manage the resources of each tenant, and monitor the resource consumption and utilization2. This can ensure the performance or availability of the laptop, and prevent resource contention or exhaustion.
Configuration or standardization: The laptop should configure or standardize the settings, preferences, or applications of each tenant, and ensure the compatibility or interoperability between them2. This can avoid errors, crashes, or compatibility issues, and improve the functionality, reliability, or usability of the laptop.
References: 1: What is Desktop Virtualization? | IBM1 2: Multitenant organization scenario and Microsoft Entra capabilities2
When defining due diligence requirements for the set of vendors that host web applications which of the following is typically NOT part of evaluating the vendor's patch
management controls?
The capability of the vendor to apply priority patching of high-risk systems
Established procedures for testing of patches, service packs, and hot fixes prior to installation
A documented process to gain approvals for use of open source applications
The existence of a formal process for evaluation and prioritization of known vulnerabilities
A documented process to gain approvals for use of open source applications is typically not part of evaluating the vendor’s patch management controls, because it is not directly related to the patching process. Patch management controls are the policies, procedures, and tools that enable an organization to identify, acquire, install, and verify patches for software vulnerabilities. Patch management controls aim to reduce the risk of exploitation of known software flaws and ensure the functionality and compatibility of the patched systems. A documented process to gain approvals for use of open source applications is more relevant to the software development and procurement processes, as it involves assessing the legal, security, and operational implications of using open source software components in the vendor’s products or services. Open source software may have different licensing terms, quality standards, and support levels than proprietary software, and may introduce additional vulnerabilities or dependencies that need to be managed. Therefore, a documented process to gain approvals for use of open source applications is a good practice for vendors, but it is not a patch management control per se. References:
Guide to Enterprise Patch Management Planning
Governance of Key Aspects of System Patch Management
Certified Third Party Risk Professional (CTPRP) Study Guide
When updating TPRM vendor classification requirements with a focus on availability, which
risk rating factors provide the greatest impact to the analysis?
Type of data by classification; volume of records included in data processing
Financial viability of the vendor; ability to meet performance metrics
Network connectivity; remote access to applications
impact on operations and end users; impact on revenue; impact on regulatory compliance
TPRM vendor classification is the process of categorizing vendors based on their criticality, risk level, and service type. Vendor classification helps to prioritize and allocate resources for vendor assessment, monitoring, and remediation. Vendor classification should be updated periodically to reflect changes in the business environment, vendor performance, and regulatory requirements.
When updating TPRM vendor classification requirements with a focus on availability, the risk rating factors that provide the greatest impact to the analysis are the impact on operations and end users, the impact on revenue, and the impact on regulatory compliance. This is because:
Availability is the degree to which a system or service is accessible and functional when required by authorized users. Availability is a key component of information security and business continuity, as it ensures that the business can operate normally and deliver value to its customers and stakeholders.
Impact on operations and end users measures the extent to which a vendor’s service disruption or failure affects the business processes, functions, and activities that depend on the vendor’s service. A high impact on operations and end users means that the vendor’s service is essential for the business to perform its core functions and meet its objectives, and that any downtime or degradation of the service would cause significant operational delays, inefficiencies, or losses.
Impact on revenue measures the extent to which a vendor’s service disruption or failure affects the business’s income, profitability, and market share. A high impact on revenue means that the vendor’s service is directly or indirectly linked to the business’s revenue generation, and that any downtime or degradation of the service would cause substantial financial losses, reduced customer satisfaction, or competitive disadvantage.
Impact on regulatory compliance measures the extent to which a vendor’s service disruption or failure affects the business’s adherence to the laws, regulations, standards, and contractual obligations that govern its industry, sector, or jurisdiction. A high impact on regulatory compliance means that the vendor’s service is subject to strict regulatory requirements, and that any downtime or degradation of the service would cause serious legal penalties, fines, sanctions, or reputational damage.
Therefore, these three factors are the most important to consider when updating TPRM vendor classification requirements with a focus on availability, as they reflect the potential consequences and risks of vendor unavailability for the business.
References:
CTPRP Job Guide
Criticality and Risk Rating Vendors 101
The Third-Party Vendor Risk Management Lifecycle
What Is Third-Party Risk Management (TPRM)? 2024 Guide
Third-Party Risk Management and ISO Requirements for 2022
