Understanding Third-Party Risks
- Operational Risks: The risk of a third-party causing disruption to the business operations. This is typically managed through contractually bound service level agreements (SLAs) and business continuity and incident response plans. Depending on the criticality of the vendor, you may opt to have a backup vendor in place, which is common practice in the financial services industry.
- Cybersecurity Risks: The risk of exposure or loss resulting from a cyberattack, security breach, or other security incidents. Cybersecurity risk is often mitigated via a due diligence process before onboarding a vendor and continuous monitoring throughout the vendor lifecycle.
- Compliance Risks: The risk of a third-party impacting your compliance with local legislation, regulation, or agreements. This is particularly important for financial services, healthcare, government organizations, and business partners.
- Financial Risks: The risk that a third party will have a detrimental impact on the financial success of your organization. For example, your organization may be unable to sell a new product due to poor supply chain management.
- Reputational risk: The risk of negative public opinion due to a third party. Dissatisfied customers, inappropriate interactions, and poor recommendations are only the tip of the iceberg. The most damaging events are third-party data breaches resulting from poor data security, like Target's 2013 data breach.
Best Practices for Managing Third-Party Risks
Effectively managing third-party risks involves a proactive approach that includes the following best practices:1. Identify and Classify Third-Party Vendors
First, identify all third-parties who play role in the software supply chain and classify them based on their criticality of the components and services that are sourced from them . It would be also be importnt to consider the criticality of the system for which such components or services are consumed for. Like most risk mitigation plans, a sound strategy involves categorizing the threats by priority. In terms of third parties, the goal is to determine which third-party relationship is riskiest. This helps prioritize risk management efforts by planning and allocating necessary resources.2. Conduct Thorough Due Diligence
As next step, conduct a comprehensive due diligence to assess the security posture, financial stability, compliance with regulatory requirements, and overall reliability of the third-parties. This process should include reviewing their security policies, secure coding practices, supply chain risk management plans, previous incident reports, and financial statements. Based on the assessment, either require the third-party to implement necessary policies, processes and controls or put in place appropriate compensating controls to keep the risk under control. Besides, the duediligence shall be conducted in periodic intervals or upon happening of any event or incident impacting the components or services consumed.3. Establish Clear Contracts and SLAs
Another important step is to ensure that contracts and Service Level Agreements (SLAs) are executed with the third parties and the contract should clearly contain clauses detailing the expectations, responsibilities, indemnities, and penalties. Such contracts should cover aspects such as data security, incident response, confidentiality, and applicable regulatory compliance. The entity shall also be required to report or notify significant security incidents within reasonable time, so that appropriate action as may be necessary to prevent the cascading impact of such incident can be taken.4. Monitor and Assess Continuously
Continuous monitoring of third-party vendors is essential to ensure ongoing compliance and risk management. This involves regular audits, assessments, and reviews of the vendor's performance, security practices, and financial health. Besides, after analyzing your organization’s relationships with vendors and suppliers and grouping them based on their risk level, the risk management strategy should be reviewed and revised to make it more efficient. Properly managing supplier risks is essential for interconnected businesses and helps address cybersecurity vulnerabilities throughout the supply chain ecosystem.5. Implement a Third-Party Risk Management (TPRM) Program
Develop and implement a comprehensive third-party risk management program that includes policies, procedures, and tools to manage and mitigate risks. This program should be integrated with the organization's overall risk management strategy and updated regularly to address emerging threats and vulnerabilities. A well-designed third party risk management program framework provides a win-win situation. It helps in predicting third-party risks and high-risk vendors prior to risk assessment. The risk management planning framework saves time and provides insightful risk assessment.6. Foster Strong Relationships and Communication
Suppliers who feel valued are more likely to work with you to solve problems, share information, and adapt to changes. This can lead to a more resilient supply chain. Communication between stakeholders and external suppliers can improve the process by bringing more creative ideas to the table. By fostering open communication and transparency, you can create a foundation of trust that enables better information sharing and risk management. Regular meetings, feedback sessions, and open channels of communication can help address issues promptly and improve overall risk management.7. Prepare for Incident Response
In an ideal world, a well-defined supply chain incident response plan, complete with well-tested procedures, SBOMs, and comprehensive software inventories would be in place. However, reality often catches us off-guard. Despite best efforts, incidents may still occur. This is where timely notification of the incidents by the third-party is essential. The incident response plan should include steps for notifying affected parties, containing the incident, and conducting post-incident analysis.