Kernel of Truth

Category: Governance, Risk & Compliance (GRC)

  • How to Conduct Vendor Security Assessments Using the NIST Framework

    Third-party vendors often handle sensitive data, manage critical services, or integrate directly into your systems. The NIST Cybersecurity Framework (CSF) and SP 800-53 / 800-171 provide guidance for managing and reducing third-party risk.

    This guide outlines how to conduct vendor security assessments and periodic audits using NIST-aligned controls and best practices.

    🧩 1. Identify (ID): Understand the Risk

    Per the NIST CSF Identify (ID) function, you must first understand:

    • The criticality of each vendor
    • What systems and data they access
    • Applicable compliance obligations (e.g. GDPR, HIPAA, CMMC)

    Key NIST references:

    • ID.RA-3: Identify third-party dependencies and risk.
    • ID.BE-4: Prioritise vendors based on business mission impact.

    📌 Action: Create a Vendor Inventory with tiered classification:

    • Tier 1: Access to PII or critical systems
    • Tier 2: Moderate impact vendors
    • Tier 3: Low-risk services or commodities

    📋 2. Protect (PR): Perform Pre-engagement Reviews

    Under the Protect (PR) function, assess vendor controls before granting access.

    Steps:

    • Send a security questionnaire based on NIST SP 800-171 or tailored to your internal policies.
    • Request evidence like:
      • ISO 27001 or SOC 2 reports
      • Penetration test summaries
      • Encryption policies
      • Secure development practices

    Key NIST references:

    • PR.IP-12: A vulnerability management plan is developed and implemented.
    • PR.AT-3: Third-party personnel are trained on your security expectations.
    • AC-20 / AC-4: Enforce access control for external providers.

    📌 Action: Establish minimum security criteria for vendor approval.

    🔍 3. Detect (DE): Monitor Third-Party Activity

    Once vendors are onboarded, the Detect (DE) function focuses on ongoing visibility.

    Monitor for:

    • Unusual access patterns
    • Expired or unused vendor accounts
    • Vendor-related alerts or incidents

    Key NIST references:

    • DE.CM-7: Monitor external service provider activity.
    • AU-12: Enable auditing and logging for third-party access.

    📌 Action: Integrate third-party accounts into your SIEM or monitoring stack.

    🧪 4. Respond (RS): Prepare for Vendor-Related Incidents

    If a vendor is involved in a security incident, you must act fast. NIST’s Respond (RS) function supports structured action.

    Prepare by:

    • Including incident response clauses in contracts
    • Having clear escalation paths
    • Running tabletop exercises involving third parties

    Key NIST references:

    • RS.CO-2: Ensure stakeholders know their roles.
    • IR-4 / IR-3: Test response plans involving vendors.

    📌 Action: Document vendor breach response expectations in SLAs.

    🔁 5. Recover (RC): Ensure Continuity and Lessons Learned

    The Recover (RC) function ensures you learn and adapt post-incident.

    Post-breach vendor steps:

    • Conduct a root cause analysis
    • Reassess the vendor’s risk score
    • Consider contract renegotiation or termination

    Key NIST references:

    • RC.IM-1: Review strategies for recovery with third parties.
    • CP-2 / CP-4: Verify vendor continuity plans.

    📌 Action: Schedule regular recovery testing or failover exercises for critical vendors.

    📆 6. Audit and Reassess Regularly

    Under CA-7 and CA-5 from NIST 800-53:

    • Perform annual reassessments
    • Request updated compliance documentation
    • Conduct on-site audits (for critical vendors)
    • Reevaluate whenever there’s:
      • A change in service scope
      • A known security incident
      • Contract renewal

    📌 Action: Maintain a Vendor Risk Register and track corrective actions.

    ✅ Summary: Aligning Vendor Risk with NIST

    NIST CSF FunctionAction
    IdentifyVendor classification and inventory
    ProtectRisk-based assessment and access control
    DetectMonitor vendor activity
    RespondPrepare for vendor-involved incidents
    RecoverPost-incident improvement and testing

    Using NIST helps formalise your third-party risk process, strengthens compliance, and improves resilience.

  • Vendor Security Assessments and Third-Party Risk Reviews

    How to Conduct Vendor Security Assessments and Third-Party Risk Reviews

    In today’s interconnected digital world, third-party vendors play a vital role in operations—but they can also introduce risk. A strong vendor security assessment process ensures that external partners meet your organisation’s security requirements and regulatory obligations.

    Below is a structured approach to evaluating third-party risk and conducting periodic security audits.

    🔍 1. Define Your Assessment Criteria

    Before engaging with vendors, clearly outline what you’re assessing. This includes:

    • Data sensitivity: What type of data will the vendor access or process?
    • Regulatory requirements: e.g. GDPR, HIPAA, PCI-DSS.
    • Business impact: Would a compromise affect your operations or reputation?

    Create a vendor classification system:

    • Tier 1: High-risk vendors (access to sensitive data or systems).
    • Tier 2: Medium-risk (limited access, non-critical services).
    • Tier 3: Low-risk (no data or system access, e.g. office supplies).

    📄 2. Distribute Security Questionnaires

    Send a tailored security questionnaire (or use a framework like CAIQ or SIG) that covers:

    • Access controls and user management
    • Data encryption (at rest and in transit)
    • Incident response capability
    • Vulnerability management
    • Business continuity and disaster recovery
    • Compliance with standards (ISO 27001, SOC 2, etc.)

    Tools such as OneTrust, Prevalent, or Whistic can streamline this process.

    🔐 3. Review Evidence and Validate Claims

    Don’t just take answers at face value. Ask for:

    • Security policy documentation
    • Third-party audit reports (SOC 2 Type II, ISO 27001, etc.)
    • Penetration test summaries
    • Data flow diagrams

    Validate that controls align with your risk tolerance. Look for gaps or red flags, such as unencrypted backups or poor access control.

    🔁 4. Perform Periodic Security Audits

    For high-risk vendors, schedule annual or semi-annual audits. These can include:

    • Onsite assessments (if possible)
    • Vulnerability scans
    • Review of logs or access records
    • Interviews with vendor security personnel

    Document findings and track remediation progress through a risk register or GRC platform.

    🛡 5. Manage and Track Risk

    Assign a risk rating to each vendor (e.g. low, medium, high) and maintain a Vendor Risk Register. Actions include:

    • Requiring remediation plans
    • Applying compensating controls
    • Terminating the relationship if risk is unacceptable

    Use tools like ServiceNow VRM, Archer, or even Excel + SharePoint for tracking if budget is limited.

    📆 6. Reassess on Contract Renewal or Major Changes

    Re-evaluate security posture when:

    • A contract is renewed
    • The vendor experiences a breach
    • Services or scope of data changes

    Always include security terms in your contracts, such as breach notification timelines, right to audit, and data handling clauses.

    ✅ Summary

    Vendor security assessments help reduce your organisation’s exposure to third-party risk. A mature process should include:

    • Clear risk classification
    • Structured questionnaires
    • Evidence review
    • Periodic audits
    • Ongoing risk tracking and governance

    Implementing this process ensures compliance, builds trust, and enhances your overall cybersecurity posture.