Which of the following statements BEST represent the relationship between incident response and incident notification plans?
Cybersecurity incident response programs have the same scope and objectives as privacy incident notification procedures
All privacy and security incidents should be treated alike until analysis is performed to quantify the number of records impacted
Security incident response management is only included in crisis communication for externally reported events
A security incident may become a security breach based upon analysis and trigger the organization's incident notification or crisis communication process
Incident response and incident notification are two related but distinct processes that organizations should follow when dealing with security incidents. Incident response is the process of identifying, containing, analyzing, eradicating, and recovering from security incidents, while incident notification is the process of communicating the relevant information about the incident to the appropriate internal and external stakeholders, such as senior management, regulators, customers, and media12.
Not all security incidents are security breaches, which are defined as unauthorized access to or disclosure of sensitive or confidential information that could result in harm to the organization or individuals3. A security incident may become a security breach based on the analysis of the impact, scope, and severity of the incident, as well as the applicable legal and regulatory requirements. When a security breach is confirmed or suspected, the organization should trigger its incident notification or crisis communication process, which should include the following elements:
A clear definition of roles and responsibilities for notification and communication
A list of internal and external stakeholders who need to be notified and their contact information
A set of predefined templates and messages for different types of incidents and audiences
A communication strategy and timeline that aligns with the incident response plan and the business continuity plan
A feedback mechanism to monitor and measure the effectiveness of the communication and adjust as needed
Incident notification and communication are critical for managing the reputation, trust, and compliance of the organization, as well as for mitigating the potential legal, financial, and operational consequences of a security breach. References:
1: Incident Response Plan: Frameworks and Steps
2: A Guide to Incident Response Plans, Playbooks, and Policy
3: What is Incident Response? Plan and Steps
: Incident Response and Breach Notification
: Incident Response Communication: Best Practices
: The Importance of Incident Response Communication
Which of the following data types would be classified as low risk data?
Sanitized customer data used for aggregated profiling
Non personally identifiable, but sensitive to an organizations significant process
Government-issued number, credit card number or bank account information
Personally identifiable data but stored in a test environment cloud container
Data classification is the process of categorizing data according to its type, sensitivity, and value to the organization if altered, stolen, or destroyed1. Data classification helps an organization understand the risk level of its data and implement appropriate controls to protect it. Data can be classified into three risk levels: low, moderate, and high23. Low risk data are data that are intended for public disclosure or have no adverse impact on the organization’s mission, safety, finances, or reputation if compromised23. Sanitized customer data used for aggregated profiling are an example of low risk data, as they do not contain any personally identifiable or sensitive information that could be exploited for criminal or other wrongful purposes. Sanitized data are data that have been modified to remove or obscure any confidential or identifying information, such as names, addresses, phone numbers, etc. Aggregated data are data that have been combined or summarized from multiple sources to provide statistical or analytical insights, such as trends, patterns, averages, etc. Sanitized and aggregated data are often used for research, marketing, or business intelligence purposes, and do not pose a significant threat to the organization or the customers if exposed. References:
1: What is Data Classification? | Best Practices & Data Types | Imperva
2: Data Classification Guideline (1604 GD.01) - Yale University
3: Risk Classifications | University IT
: Data Classification Policy - Shared Assessments
: What is Data Sanitization? | Definition and Examples | Imperva
: What is Data Aggregation? | Definition and Examples | Imperva
Which factor is the LEAST important attribute when classifying personal data?
The volume of data records processed or retained
The data subject category that identifies the data owner
The sensitivity level of specific data elements that could identify an individual
The assignment of a confidentiality level that differentiates public or non-public information
According to the GDPR, personal data is any information relating to an identified or identifiable natural person (data subject). The GDPR does not consider the volume of data records as a relevant factor for classifying personal data, but rather the nature and context of the data. The GDPR requires data controllers and processors to apply appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing personal data, taking into account factors such as the state of the art, the costs of implementation, the nature, scope, context and purposes of processing, and the risks of varying likelihood and severity for the rights and freedoms of natural persons. Therefore, the volume of data records is not a decisive attribute for classifying personal data, but rather an indicator of the potential impact of a data breach or misuse.
The other factors listed in the question are more important attributes for classifying personal data, as they relate to the identification, protection, and rights of the data subjects. The data subject category that identifies the data owner refers to the type of natural person whose personal data is processed, such as customers, employees, patients, students, etc. This factor is important for determining the purpose and legal basis of processing, as well as the data subject’s rights and expectations1. The sensitivity level of specific data elements that could identify an individual refers to the degree of harm or discrimination that could result from the disclosure or misuse of such data, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, sex life or sexual orientation, or criminal convictions or offenses2. The GDPR imposes stricter rules and obligations for the processing of such special categories of personal data, as they pose a higher risk to the data subject’s fundamental rights and freedoms. The assignment of a confidentiality level that differentiates public or non-public information refers to the degree of access and disclosure that is permitted or required for the personal data, depending on the data subject’s consent, the legitimate interests of the data controller or processor, or the applicable laws and regulations1. The GDPR requires data controllers and processors to implement data protection by design and by default, meaning that they should only process the personal data that is necessary for the specific purpose and limit the access to those who need to know.
References:
4: 5 Types of Data Classification (With Examples) | Indeed.com
7: Special Categories of Personal Data - GDPR EU
[8]: Data Classification for GDPR Explained [Full Breakdown] - DataGrail
Which statement is TRUE regarding defining vendor classification or risk tiering in a TPRM program?
Vendor classification and risk tiers are based upon residual risk calculations
Vendor classification and risk tiering should only be used for critical third party relationships
Vendor classification and corresponding risk tiers utilize the same due diligence standards for controls evaluation based upon policy
Vendor classification and risk tier is determined by calculating the inherent risk associated with outsourcing a specific product or service
Vendor classification or risk tiering is a process of categorizing vendors based on the level of security risk they introduce to an organization12. It is a key component of a third-party risk management (TPRM) program, as it helps to prioritize and allocate resources for vendor assessment, monitoring, and remediation12. The statement D is true, as it reflects the first step of vendor classification or risk tiering, which is to determine the inherent risk of each vendor relationship based on the nature, scope, and complexity of the product or service being outsourced3 . Inherent risk is the risk that exists before any controls or mitigating factors are applied3 . By calculating the inherent risk, an organization can assign each vendor to a risk tier that reflects the potential impact and likelihood of a security breach or incident involving the vendor3 .
The other statements are false, as they do not accurately describe the vendor classification or risk tiering process. The statement A is false, as vendor classification and risk tiers are not based on residual risk calculations, but on inherent risk calculations. Residual risk is the risk that remains after controls or mitigating factors are applied3 . Residual risk is used to evaluate the effectiveness of the controls and the need for further action, but not to classify or tier vendors3 . The statement B is false, as vendor classification and risk tiering should be used for all third party relationships, not only for critical ones. Vendor classification and risk tiering helps to identify and prioritize the critical vendors, but also to manage the low and medium risk vendors according to their respective risk profiles12. The statement C is false, as vendor classification and corresponding risk tiers do not utilize the same due diligence standards for controls evaluation based upon policy, but different ones. Due diligence standards are the criteria and methods used to assess the security posture and performance of vendors. Due diligence standards should vary according to the risk tier of the vendor, as higher risk vendors require more rigorous and frequent evaluation than lower risk vendors.
References:
1: What is Vendor Tiering? Optimize Your Vendor Risk Management | UpGuard Blog
2: Vendor Tiering Best Practices: Categorizing Vendor Risks | UpGuard Blog
3: Third-Party Risk Management (TPRM): A Complete Guide - BlueVoyant
[4]: Supplemental Examination Procedures for Risk Management of Third-Party Relationships
[5]: Third Party Risk Management: Why It’s Important And What Features To Look For - Expert Insights
Which of the following factors is MOST important when assessing the risk of shadow IT in organizational security?
The organization maintains adequate policies and procedures that communicate required controls for security functions
The organization requires security training and certification for security personnel
The organization defines staffing levels to address impact of any turnover in security roles
The organization's resources and investment are sufficient to meet security requirements
Shadow IT is the use and management of any IT technologies, solutions, services, projects, and infrastructure without formal approval and support of internal IT departments. Shadow IT can pose significant security risks to the organization, such as data breaches, compliance violations, malware infections, or network disruptions. Therefore, assessing and mitigating the risk of shadow IT is an essential part of organizational security.
One of the most important factors when assessing the risk of shadow IT is whether the organization maintains adequate policies and procedures that communicate required controls for security functions. Policies and procedures are the documents that define the organization’s security objectives, standards, roles, responsibilities, and processes. They provide guidance and direction for the organization’s security activities, such as risk assessment, vendor management, incident response, data protection, access control, etc. They also establish the expectations and requirements for the organization’s employees, vendors, and other stakeholders regarding the use and management of IT resources.
By maintaining adequate policies and procedures that communicate required controls for security functions, the organization can:
Educate and inform its employees about the security risks and implications of shadow IT, and the benefits and advantages of using authorized and supported IT resources.
Establish and enforce clear and consistent rules and boundaries for the use and management of IT resources, and the consequences and penalties for violating them.
Monitor and audit the compliance and performance of its employees, vendors, and other stakeholders regarding the use and management of IT resources, and identify and address any deviations or issues.
Review and update its policies and procedures regularly, and communicate any changes or updates to its employees, vendors, and other stakeholders.
By doing so, the organization can reduce the likelihood and impact of shadow IT, and increase the visibility and accountability of its IT environment. The organization can also foster a culture of security awareness and responsibility among its employees, vendors, and other stakeholders, and encourage them to report and resolve any shadow IT incidents or problems.
The other factors, such as the organization’s security training and certification, staffing levels, and resources and investment, are also relevant for assessing the risk of shadow IT, but they are not as important as the organization’s policies and procedures. Security training and certification can help the organization’s security personnel to acquire and maintain the necessary skills and knowledge to deal with shadow IT, but they do not address the root causes or motivations of shadow IT. Staffing levels can affect the organization’s ability to detect and respond to shadow IT, but they do not prevent or deter shadow IT from occurring. Resources and investment can enable the organization to provide adequate and appropriate IT resources to its employees, vendors, and other stakeholders, but they do not guarantee the satisfaction or compliance of those parties. References:
: Shadow IT Explained: Risks & Opportunities - BMC Software
: What is Shadow IT? | IBM
: Shadow IT: What Are the Risks and How Can You Mitigate Them? - Ekran System
: Policies and Procedures - Shared Assessments
In which phase of the TPRM lifecycle should terms for return or destruction of data be defined and agreed upon?
During contract negotiation
At third party selection and initial due diligence
When deploying ongoing monitoring
At termination and exit
Terms for return or destruction of data should be defined and agreed upon during contract negotiation, as this is the phase where the organization and the third party establish the expectations, obligations, and responsibilities for the relationship, including the handling of data. According to the Shared Assessments CTPRP Study Guide, contract negotiation is the phase where "the organization and the third party negotiate and execute a contract that clearly defines the expectations and responsibilities of both parties, including the scope of work, service level agreements, performance measures, reporting requirements, compliance obligations, security and privacy controls, incident response procedures, dispute resolution mechanisms, termination rights, and other relevant terms and conditions."1 One of the key contractual terms that should be addressed is the return or destruction of data, which specifies how the third party will return or dispose of the organization’s data at the end of the relationship, or upon request, in a secure and timely manner. This term is important for ensuring the organization’s data protection, confidentiality, and compliance, as well as reducing the risk of data breaches, leaks, or misuse by the third party or unauthorized parties.
The other phases of the TPRM lifecycle are not the best choices for defining and agreeing upon terms for return or destruction of data, because:
B. At third party selection and initial due diligence: This is the phase where the organization identifies, evaluates, and selects the third party that best meets its needs, objectives, and risk appetite. This phase involves conducting due diligence on the third party’s capabilities, qualifications, reputation, performance, security, and compliance, as well as assessing the inherent risk of the relationship. While this phase is important for screening and choosing the right third party, it does not involve defining and agreeing upon the specific terms and conditions of the relationship, such as the return or destruction of data, which are usually done in the contract negotiation phase.
C. When deploying ongoing monitoring: This is the phase where the organization monitors and reviews the third party’s performance, service delivery, risk management, and compliance on a regular basis, as well as identifies and addresses any issues, gaps, or changes that may arise during the relationship. This phase involves collecting and analyzing data and information from various sources, such as reports, audits, assessments, surveys, feedback, incidents, and metrics, as well as communicating and collaborating with the third party to ensure alignment and improvement. While this phase is important for ensuring the quality and security of the relationship, it does not involve defining and agreeing upon the terms and conditions of the relationship, such as the return or destruction of data, which are usually done in the contract negotiation phase.
D. At termination and exit: This is the phase where the organization terminates and exits the relationship with the third party, either by mutual agreement, expiration of contract, breach of contract, or other reasons. This phase involves executing the termination and exit plan, which may include notifying the third party, transferring or discontinuing the services, settling the financial obligations, returning or destroying the data, revoking the access rights, and conducting a post-termination review. While this phase is important for ensuring a smooth and secure transition and closure of the relationship, it does not involve defining and agreeing upon the terms and conditions of the relationship, such as the return or destruction of data, which are usually done in the contract negotiation phase.
References:
1: Shared Assessments CTPRP Study Guide, page 59, section 5.1: TPRM Lifecycle
: Third-Party Risk Management: Vendor Contract Terms and Conditions, section: Data Ownership, Return and Destruction
: [Third-Party Risk Management: The 3rd Party Ecosystem: How to Manage the Risk While Keeping the Benefit], section: Contract Negotiation
: [Third-Party Risk Management: The 3rd Party Ecosystem: How to Manage the Risk While Keeping the Benefit], section: Termination and Exit
Which statement is FALSE regarding the risk factors an organization may include when defining TPRM compliance requirements?
Organizations include TPRM compliance requirements within vendor contracts, and periodically review and update mandatory contract provisions
Organizations rely on regulatory mandates to define and structure TPRM compliance requirements
Organizations incorporate the use of external standards and frameworks to align and map TPRM compliance requirements to industry practice
Organizations define TPRM policies based on the company’s risk appetite to shape requirements based on the services being outsourced
TPRM compliance requirements are the rules and expectations that an organization must follow when engaging with third parties, such as vendors, suppliers, partners, or contractors. These requirements are derived from various sources, such as laws, regulations, standards, frameworks, contracts, policies, and best practices. However, relying solely on regulatory mandates to define and structure TPRM compliance requirements is a false statement, because123:
Regulatory mandates are not the only source of TPRM compliance requirements. Organizations may also need to consider other factors, such as industry benchmarks, customer expectations, stakeholder interests, ethical principles, and social responsibility.
Regulatory mandates are not always comprehensive, clear, or consistent. Organizations may face different or conflicting regulations across jurisdictions, sectors, or domains. Organizations may also need to interpret and apply the regulations to their specific context and risk profile, which may require additional guidance or expertise.
Regulatory mandates are not always sufficient, effective, or efficient. Organizations may need to go beyond the minimum requirements of the regulations to achieve their business objectives, mitigate their risks, or enhance their performance. Organizations may also need to adopt more flexible, scalable, and innovative approaches to TPRM compliance, rather than following a rigid, one-size-fits-all, or check-the-box model.
Therefore, the correct answer is B. Organizations rely on regulatory mandates to define and structure TPRM compliance requirements, as this is a false statement regarding the risk factors an organization may include when defining TPRM compliance requirements. References:
1: Understanding TPRM Compliance: A Comprehensive Guide | Prevalent
2: What Is Third-Party Risk Management (TPRM)? 2024 Guide | UpGuard
3: Third-Party Risk Management and ISO Requirements for 2022 | Reciprocity
