Shared Assessments CTPRP Dumps

Remote access is any connection made to an organization’s internal network and systems from an external source by a device or host. Remote access can enable greater worker flexibility and productivity, but it also poses significant security risks, such as unauthorized access, data leakage, malware infection, or network compromise. Therefore, it is important to evaluate a third party’s use of remote access within their information security policy, which should define the roles, responsibilities, standards, and procedures for remote access.

One of the key components of evaluating a third party’s use of remote access within their information security policy is identifying the use of multifactor authentication. Multifactor authentication is a method of verifying the identity of a remote user by requiring two or more factors, such as something the user knows (e.g., password, PIN), something the user has (e.g., token, smart card), or something the user is (e.g., fingerprint, face). Multifactor authentication enhances the security of remote access by making it harder for attackers to impersonate or compromise legitimate users. According to the NIST Guide to Enterprise Telework, Remote Access, and Bring Your Own Device (BYOD) Security1, multifactor authentication should be used for all remote access, especially for high-risk situations, such as accessing sensitive data or privileged accounts.

The other options are not components of evaluating a third party’s use of remote access within their information security policy. Maintaining blocked IP address ranges, reviewing the testing and deployment procedures to networking components, and providing guidelines to configuring ports on a router are all examples of network security controls, but they are not specific to remote access. They may be part of the overall information security policy, but they are not sufficient to assess the security of remote access. References:

• NIST Guide to Enterprise Telework, Remote Access, and Bring Your Own Device (BYOD) Security
• How to Implement an Effective Remote Access Policy
• Why Managing Third-Party Access Requires A Better Approach

 When a vendor contract terminates, one of the most important requirements for managing risk is to ensure that the vendor securely destroys or returns any data or assets that belong to the organization or its customers. This is to prevent any unauthorized access, use, disclosure, or loss of sensitive information or resources that could result in legal, regulatory, reputational, or financial consequences. The organization should also verify that the vendor complies with this requirement by requesting evidence or conducting audits.

The other options are also important, but not as critical as ensuring data and asset security. Performing a financial review of outstanding invoices is necessary to avoid overpaying or underpaying the vendor, and to resolve any disputes or claims. Performing a final assessment based on due diligence standards is useful to evaluate the vendor’s performance, identify any issues or gaps, and document any lessons learned or best practices. Defining contract terms for transition services is helpful to facilitate a smooth and orderly handover of responsibilities, deliverables, or processes to another vendor or internal team.

References:

• 1: Shared Assessments, a leading provider of third party risk management solutions, offers a comprehensive guide for Certified Third Party Risk Professional (CTPRP) candidates, which covers the core concepts and best practices of third party risk management, including vendor offboarding and termination.
• 2: Prevalent, a platform for third party risk management, provides a blog post on vendor offboarding and termination risk management, which includes a checklist and a template for secure data and asset destruction or return.
• 3: Spendflo, a platform for vendor risk management, provides a guide on vendor risk management, which includes the importance of data and asset security when terminating vendor contracts.

According to the Shared Assessments Certified Third Party Risk Professional (CTPRP) Study Guide, physical security compliance is the process of ensuring that the physical assets and personnel of an organization are protected from unauthorized access, theft, damage, or harm1. Physical security compliance can be achieved by implementing various measures, such as locks, alarms, cameras, guards, fences, badges, etc. However, these measures need to be regularly monitored, tested, and verified to ensure their effectiveness and alignment with the defined standards and policies2. Therefore, maintaining a standardized schedule for confirming controls to defined standards demonstrates a greater maturity of physical security compliance, as it indicates a proactive and consistent approach to assessing and improving the physical security posture of an organization3.

The other options do not reflect a high level of physical security compliance maturity, as they either rely on reactive or ad hoc methods, or lack sufficient verification and validation mechanisms. Leveraging periodic reporting to schedule facility inspections based on reported events may indicate a lack of preventive and predictive measures, as well as a dependency on external or internal incidents to trigger the inspections. Providing a checklist for self-assessment may indicate a lack of independent and objective evaluation, as well as a potential for bias or error in the self-assessment process. Conducting unannounced checks on an ad hoc basis may indicate a lack of planning and coordination, as well as a potential for disruption or inconsistency in the checks.

References:

• 1: Shared Assessments Certified Third Party Risk Professional (CTPRP) Study Guide, page 24
• 2: Physical Security: Planning, Measures & Examples + PDF - Avigilon
• 3: Security Maturity Models: Levels, Assessment, and Benefits
• [4]: Best Practices for Planning and Managing Physical Security Resources - CISA, page 10
• [5]: Self-Assessment vs. Independent Assessment: What’s the Difference? | Linford & Company LLP
• [6]: The Pros and Cons of Unannounced Audits | NQA

 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”

 An IT asset management program is a set of processes and tools that help an organization manage its IT assets throughout their lifecycle, from acquisition to disposal. An IT asset management program should include the following components1234:

• Maintaining inventories of systems, connections, and software applications: This component involves creating and updating a comprehensive and accurate list of all IT assets owned or used by the organization, including their location, ownership, configuration, and status. This helps the organization optimize the use of its IT resources, reduce costs, and ensure compliance with licensing and regulatory requirements.
• Tracking and monitoring availability of vendor updates and any timelines for end of support: This component involves keeping track of the latest updates, patches, and security fixes provided by the vendors of the IT assets, as well as the end-of-life dates and support options for the assets. This helps the organization maintain the security, performance, and functionality of its IT assets, and plan for timely replacement or migration of obsolete or unsupported assets.
• Identifying and tracking adherence to IT asset end-of-life policy: This component involves defining and implementing a policy for retiring and disposing of IT assets that are no longer needed, useful, or supported by the organization. This helps the organization reduce risks, costs, and environmental impacts associated with IT asset disposal, and ensure compliance with data protection and disposal regulations.

Defining application security standards for internally developed applications is not a component of an IT asset management program, but rather a component of an application development and security program. An application development and security program is a set of processes and tools that help an organization design, develop, test, deploy, and maintain secure and reliable applications, whether they are internally developed or acquired from external sources. An application development and security program should include the following components5 :

• Defining application security standards for internally developed applications: This component involves establishing and enforcing a set of security requirements and best practices for the applications developed by the organization, such as secure coding, testing, and deployment methodologies, security controls, and vulnerability management. This helps the organization ensure the confidentiality, integrity, and availability of its applications and data, and prevent or mitigate security breaches and incidents.
• Performing application security assessments for externally acquired applications: This component involves conducting security reviews and audits of the applications acquired from external sources, such as vendors, partners, or open source communities, before integrating them into the organization’s IT environment. This helps the organization identify and address any security risks, gaps, or weaknesses in the applications, and ensure compatibility and compliance with the organization’s security policies and standards.

References:

• ITAM: The ultimate guide to IT asset management
• IT asset management: 10 best practices for success
• Asset Management: The Five Core Components
• The Fundamentals of Asset Management
• Application Development and Security Program
• Application Security Best Practices

Data Loss Prevention (DLP) programs are not based on default tool configuration, but on the specific needs and risks of the organization. DLP programs should be tailored to the data types, locations, flows, and users that are relevant to the business. DLP programs should also align with the regulatory and contractual obligations, as well as the data risk appetite, of the organization. Default tool configuration may not adequately address these factors and may result in either over-blocking or under-protecting data. Therefore, statement C is false about DLP programs. References:

• 1: The Best Data Loss Prevention Software Tools - Comparitech
• 2: Build a Successful Data Loss Prevention Program in 5 Steps - Gartner
• 3: What is data loss prevention (DLP)? | Microsoft Security

An Information Security Incident Management Program is a set of policies, procedures, and tools that enable an organization to prevent, detect, respond to, and recover from information security incidents. An information security incident is any event that compromises the confidentiality, integrity, or availability of information assets, systems, or services12. A formal Information Security Incident Management Program typically includes the following components12:

• The definition of internal escalation processes: This component defines the roles and responsibilities, communication channels, and reporting mechanisms for escalating and managing information security incidents within the organization. It also establishes the criteria and thresholds for determining the severity and impact of incidents, and the appropriate level of response and escalation.
• The protocols for disclosure of information to external parties: This component defines the rules and guidelines for disclosing information about information security incidents to external stakeholders, such as customers, regulators, law enforcement, media, or other third parties. It also specifies the legal and contractual obligations, the timing and frequency, the format and content, and the approval and authorization processes for disclosure.
• The mechanisms for notification to clients: This component defines the methods and procedures for notifying clients or customers who may be affected by information security incidents. It also specifies the objectives, scope, and content of notification, as well as the timing and frequency, the delivery channels, and the feedback and follow-up mechanisms.
• The processes in support of disaster recovery: This component defines the steps and actions for restoring the normal operations of the organization after a major information security incident that causes significant disruption or damage to the information assets, systems, or services. It also specifies the roles and responsibilities, the resources and tools, the backup and recovery plans, and the testing and validation procedures for disaster recovery.

The statement that reflects a requirement that is NOT typically found in a formal Information Security Incident Management Program is D. The program includes processes in support of disaster recovery. While disaster recovery is an important aspect of information security, it is not a specific component of an Information Security Incident Management Program. Rather, it is a separate program that covers the broader scope of business continuity and resilience, and may involve other types of disasters besides information security incidents, such as natural disasters, power outages, or pandemics3 . Therefore, the correct answer is D. The program includes processes in support of disaster recovery. References: 1: Computer Security Incident Handling Guide 2: Develop and Implement a Security Incident Management Program 3: Business Continuity Management vs Disaster Recovery : What is the difference between disaster recovery and security incident response?

Web content accessibility guidelines (WCAG) are a set of standards that aim to make web content more accessible to people with disabilities, such as visual, auditory, cognitive, or motor impairments. While WCAG is a good practice for web development and usability, it is not directly related to web application security. WCAG does not address the common security risks that web applications face, such as injection, broken authentication, misconfiguration, or vulnerable components. Therefore, adhering to WCAG is not a method of securing web applications, unlike the other options. References:

• 4: OWASP Top 10, a standard awareness document for web application security, lists the most critical security risks to web applications and provides best practices to prevent or mitigate them.
• 5: SANS Institute, a leading provider of cybersecurity training and certification, offers a security checklist for web application technologies (SWAT) that covers best practices for error handling, data protection, configuration, authentication, session management, input and output handling, and access control.
• 6: Built In, a platform for tech professionals, provides 13 web application security best practices, such as using a web application firewall, keeping track of APIs, enforcing expected application behaviors, and following the OWASP Top 10.

The most important factor when scoping assessments of cloud-based third parties that access, process, and retain personal data is to identify the type of cloud hosting deployment or service model. This is because different cloud models have different implications for the allocation of security responsibilities between the third party and the cloud hosting provider. For example, in a Software as a Service (SaaS) model, the cloud provider is responsible for most of the security controls, while in an Infrastructure as a Service (IaaS) model, the third party is responsible for securing its own data and applications. Therefore, it is essential to understand the type of cloud model and the corresponding security roles and responsibilities before conducting an assessment. This will help to avoid gaps, overlaps, or conflicts in security controls and expectations. References:

• Guidance on Cloud Security Assessment and Authorization - ITSP.50.105, Canadian Centre for Cyber Security, May 2020, Section 2.1.1
• The Importance of Properly Scoping Cloud Environments, PCI Security Standards Council and Cloud Security Alliance, August 2021
• Third party and cloud: Regulatory challenges, KPMG, 2022, Section 2.1
• Certified Third Party Risk Professional (CTPRP) Study Guide, Shared Assessments, 2021, Section 4.2.2

When calculating residual risk, the best practice for an assessor is to adjust the vendor risk rating based on the changes to the risk level after analyzing the findings and considering the effectiveness of mitigating controls. Residual risk refers to the level of risk that remains after controls are applied to mitigate the initial (inherent) risk. By evaluating the findings from a third-party assessment and factoring in the mitigating controls implemented by the vendor, the assessor can more accurately determine the remaining risk level. This adjusted risk rating provides a more realistic view of the vendor's risk profile, aiding in informed decision-making regarding risk management and vendor oversight.

References:

• The concept of residual risk calculation is discussed in risk management frameworks such as ISO 31000 (Risk Management - Guidelines), which guides the assessment and treatment of risks.
• The "Third-Party Risk Management Guide" by ISACA outlines the process of assessing and managing risks associated with third parties, including the calculation of residual risk.

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

A change in company point of contact does not necessarily trigger an organization to prompt a third party contract provisions review, unless the contract specifically requires such a notification or approval. A change in company point of contact may affect the communication and relationship between the parties, but it does not affect the legal terms and obligations of the contract. However, other types of external events, such as business continuity events, data breaches/privacy incidents, and changes in regulations, may have a significant impact on the performance, compliance, and risk of the contract, and therefore may require a review of the contract provisions to ensure that they are still valid, enforceable, and aligned with the parties’ expectations and objectives. For example, a business continuity event may disrupt the delivery of goods or services, a data breach/privacy incident may expose confidential or personal information, and a change in regulations may impose new obligations or liabilities on the parties. These events may trigger clauses such as force majeure, termination, indemnification, or dispute resolution, and may require the parties to renegotiate or amend the contract accordingly. References:

• Third-Party Contract Reviews: Determining Your Best Options
• Third party contracts: best practices for third party paper
• What to Look For When Reviewing Third-Party Contracts
• CTPRP Job Guide

Asset management is the process of identifying, tracking, and managing the physical and digital assets of an organization. An asset management program is a set of policies, procedures, and tools that help to ensure the optimal use, security, and disposal of assets. According to the Shared Assessments CTPRP Study Guide1, an asset management program should include the following components:

• Asset inventories: A comprehensive and accurate list of all assets owned, leased, or used by the organization, including hardware, software, data, and services. Asset inventories should include connections to external parties, networks, or systems that process data, as this may introduce additional risks and dependencies12.
• Asset owners: A clear assignment of roles and responsibilities for each asset, including an organizational owner who is accountable for the asset throughout its life cycle. Asset owners should ensure that assets are properly maintained, updated, secured, and disposed of in accordance with the organization’s policies and standards13.
• Asset classification: A consistent and objective method of categorizing assets based on their criticality or data sensitivity. Asset classification helps to determine the appropriate level of protection, monitoring, and testing for each asset, as well as the potential impact of asset loss or compromise1 .
• Asset controls: A set of measures and mechanisms that help to safeguard assets from unauthorized access, use, modification, disclosure, or destruction. Asset controls may include physical, technical, administrative, or contractual means, such as locks, encryption, passwords, policies, or agreements1 .

The statement that is least likely to represent a component of an asset management program is D. Asset inventories should track the flow or distribution of items used to fulfill products and Services across production lines. This statement describes a supply chain management function, not an asset management function. Supply chain management is the process of planning, coordinating, and controlling the flow of materials, information, and services from suppliers to customers. Supply chain management may involve some aspects of asset management, such as inventory control, quality assurance, or vendor risk management, but it is not the same as asset management . Asset management focuses on the assets that the organization owns or uses, not the assets that the organization produces or delivers.

References:

• 1: Shared Assessments. (2020). Certified Third Party Risk Professional (CTPRP) Study Guide.
• 2: ISACA. (2019). COBIT 2019 Framework: Governance and Management Objectives. APO03 Manage enterprise architecture.
• 3: ISO. (2018). ISO/IEC 27001:2018 Information technology — Security techniques — Information security management systems — Requirements. Clause 8.1.2 Asset management roles and responsibilities.
• : NIST. (2013). NIST Special Publication 800-53 Revision 4 Security and Privacy Controls for Federal Information Systems and Organizations. RA-2 Security Categorization.
• : NIST. (2013). NIST Special Publication 800-53 Revision 4 Security and Privacy Controls for Federal Information Systems and Organizations. CM-8 Information System Component Inventory.
• : APICS. (2018). APICS Dictionary, 16th edition. Supply chain management.
• : ISACA. (2019). COBIT 2019 Framework: Governance and Management Objectives. APO13 Manage security.

 A regulation is a rule of order having the force of law, prescribed by a superior or competent authority, relating to the actions of those under the authority’s control. Regulations are issued by various government departments and agencies to carry out the intent of legislation enacted by the legislature of the applicable jurisdiction. Regulations also function to ensure uniform application of the law. A standard is a guideline established generally by private-sector bodies and that are available for use by any person or organization, private or government. The term includes what are commonly referred to as ‘industry standards’ as well as ‘consensus standards’. Standards are developed through a voluntary process of collaboration and consensus among stakeholders, such as manufacturers, consumers, regulators, and experts. Standards may reflect best practices, technical specifications, performance criteria, or quality requirements. Standards do not have the force of law unless they are adopted or referenced by a regulation. Therefore, a regulation must be adhered to by all companies subject to its requirements, but companies can voluntarily choose to follow standards that are relevant and beneficial to their operations, products, or services. References:

• The Difference Between Regulations and Standards
• Regulations vs Standards: Clearing Up the Confusion - AEM
• Standards vs. Regulations
• Certified Third Party Risk Professional (CTPRP) Study Guide

 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

 Questionnaires are one of the most common and effective tools for conducting third party risk assessments. They help organizations gather information about the security and compliance practices of their vendors and service providers, as well as identify any gaps or weaknesses that may pose a risk to the organization. However, not all questionnaires are created equal. Depending on the nature and scope of the third party relationship, different types and levels of questions may be required to adequately assess the risk. Therefore, it is important to configure the assessment questionnaires based on the risk rating and type of service being evaluated12.

The risk rating of a third party is determined by various factors, such as the criticality of the service they provide, the sensitivity of the data they handle, the regulatory requirements they must comply with, and the potential impact of a breach or disruption on the organization. The higher the risk rating, the more detailed and comprehensive the questionnaire should be. For example, a high-risk third party that processes personal or financial data may require a questionnaire that covers multiple domains of security and privacy, such as data protection, encryption, access control, incident response, and audit. A low-risk third party that provides a non-critical service or does not handle sensitive data may require a questionnaire that covers only the basic security controls, such as firewall, antivirus, and password policy12.

The type of service that a third party provides also influences the configuration of the questionnaire. Different services may have different security and compliance standards and best practices that need to be addressed. For example, a third party that provides cloud-based services may require a questionnaire that covers topics such as cloud security architecture, data residency, service level agreements, and disaster recovery. A third party that provides software development services may require a questionnaire that covers topics such as software development life cycle, code review, testing, and vulnerability management12.

By configuring the assessment questionnaires based on the risk rating and type of service being evaluated, organizations can ensure that they ask the right questions to the right third parties, and obtain relevant and meaningful information to support their risk management decisions. Therefore, the statement that assessment questionnaires should be configured based on the risk rating and type of service being evaluated is TRUE12. References: 1: How to Use SIG Questionnaires for Better Third-Party Risk Management 2: Third-party risk assessment questionnaires - KPMG India

 Risk culture is the term used to describe the collective way that an organization thinks about, manages, and responds to risk. It is influenced by the organization’s values, beliefs, norms, and practices, as well as the external environment and stakeholders. Risk culture affects how employees perceive, communicate, and act on risk issues, and how they balance risk and reward in their decision making. A strong risk culture is one that supports the organization’s strategic objectives, fosters accountability and transparency, and promotes learning and improvement. A weak risk culture is one that undermines the organization’s risk management framework, creates silos and conflicts, and exposes the organization to excessive or unnecessary risks. References:

• Shared Assessments CTPRP Study Guide, page 13, section 2.1.1
• GARP Best Practices Guidance for Third Party Risk, page 5, section 2.1
• Organizational culture | Definition, Benefits and Challenges

A cloud hosting vendor assessment program is a process of evaluating the security, compliance, and performance of a cloud service provider (CSP) that hosts an organization’s data or applications. A cloud hosting vendor assessment program typically includes the following components123:

• Reviewing the entity’s image snapshot approval and management process: This component involves verifying how the CSP creates, approves, stores, and deletes image snapshots of the virtual machines or containers that run the organization’s workloads. Image snapshots can contain sensitive data or configuration settings that need to be protected from unauthorized access or modification.
• Requiring security services documentation and audit attestation reports: This component involves requesting and reviewing the CSP’s documentation and reports that demonstrate the security controls and practices that the CSP implements to protect the organization’s data and applications. These may include service level agreements (SLAs), security policies and procedures, security certifications and standards, vulnerability scanning and patching reports, incident response and disaster recovery plans, and independent audit reports such as SOC 2 or ISO 27001.
• Requiring compliance evidence that provides the definition of patching responsibilities: This component involves asking and verifying how the CSP handles the patching of the operating systems, applications, and libraries that run on the cloud infrastructure. Patching is a critical activity to prevent security breaches and ensure compliance with regulatory requirements. The organization needs to understand the roles and responsibilities of the CSP and the organization in patching the cloud environment, and the frequency and scope of patching activities.

The component that is typically NOT part of a cloud hosting vendor assessment program is conducting customer performed penetration tests. Penetration testing is a method of simulating a cyberattack on a system or network to identify and exploit vulnerabilities and weaknesses. While penetration testing can be a valuable tool to assess the security posture of a CSP, it is not usually included in a cloud hosting vendor assessment program for the following reasons :

• Penetration testing may violate the CSP’s terms of service or acceptable use policy, which may prohibit or restrict the customer from performing any unauthorized or disruptive activities on the cloud infrastructure. The customer may face legal or contractual consequences if they conduct penetration testing without the CSP’s consent or knowledge.
• Penetration testing may interfere with the CSP’s normal operations or affect the availability and performance of the cloud services for other customers. The customer may cause unintended damage or disruption to the CSP’s systems or networks, or trigger false alarms or alerts that may divert the CSP’s resources or attention.
• Penetration testing may not provide a comprehensive or accurate assessment of the CSP’s security, as the customer may have limited visibility or access to the CSP’s internal systems or networks, or may encounter security mechanisms or countermeasures that prevent or limit the penetration testing activities. The customer may also face ethical or legal issues if they access or compromise the data or systems of other customers or the CSP.

Therefore, the verified answer to the question is D. Conducting customer performed penetration tests.

References:

• Four Important Best Practices for Assessing Cloud Vendors
• Top 11 Questionnaires for IT Vendor Assessment in 2024
• Cloud Vendor Assessments | Done The Right Way
• [Penetration Testing in the Cloud: What You Need to Know]
• [Cloud Penetration Testing: Challenges and Best Practices]

In the ‘Defense in Depth’ security model, the innermost layer typically focuses on protecting the most sensitive and critical assets, which are often categorized as 'Private internal'. This layer includes security controls and measures that are designed to safeguard the core, confidential aspects of an organization's infrastructure and data. It encompasses controls such as access controls, encryption, and monitoring of sensitive systems and data to prevent unauthorized access and ensure data integrity and confidentiality. The 'Private internal' layer is crucial for maintaining the security of critical information and systems that are essential to the organization's operations and could have the most significant impact if compromised. Implementing robust security measures at this layer is vital for mitigating risks associated with physical access to critical infrastructure and sensitive information.

References:

• Security frameworks and standards, including NIST SP 800-53 (Security and Privacy Controls for Federal Information Systems and Organizations) and the SANS Institute's guidelines on implementing 'Defense in Depth', provide detailed recommendations on securing the innermost layers of an organization's information systems.
• Publications such as "Physical Security Principles" by ASIS International offer insights into best practices for securing the private internal layer, including access control systems, surveillance, and intrusion detection mechanisms.

Application security design standards are a set of principles for software development that address the top application security risks and industry web requirements. They provide guidance on how to design, develop, and deploy secure applications that meet the security objectives of the organization and the expectations of the customers and regulators. Application security design standards cover topics such as secure design principles, threat modeling, encryption, identity and access management, logging and auditing, coding standards and conventions, safe functions, data handling, error handling, third-party components, and testing and validation. Application security design standards help developers avoid common security pitfalls, reduce vulnerabilities, and enhance the quality and reliability of the software. Application security design standards also facilitate the alignment of the software development lifecycle with the third-party risk management framework, by ensuring that security requirements are defined, implemented, verified, and maintained throughout the development process. References:

• Fundamental Practices for Secure Software Development
• Secure Coding Practices
• Secure Software Development Best Practices
• Certified Third Party Risk Professional (CTPRP) Study Guide

Physical access procedures and activity logs are important components of third-party risk management, as they help to ensure the security and integrity of the physical assets and data of the organization and its third parties. However, requiring physical access logs to be retained indefinitely for audit purposes is not a best practice, as it may pose legal, regulatory, and operational challenges. According to the Supplemental Examination Procedures for Risk Management of Third-Party Relationships, physical access logs should be retained for a reasonable period of time, consistent with the organization’s policies and procedures, and in compliance with applicable laws and regulations1. Retaining physical access logs indefinitely may increase the risk of unauthorized access, data breaches, privacy violations, and litigation2. Therefore, the statement B is the correct answer, as it is the only one that does not reflect a best practice for physical access procedures and activity logs.

References:

• 1: How to Write Third-Party Risk Management (TPRM) Policies and Procedures - SecurityScorecard Blog
• 2: Five Best Practices to Manage and Control Third-Party Risk - Broadcom Inc.
• 3: A checklist for third-party risk management platforms - Crowe LLP
• 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

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

Termination for cause is the type of contract termination that is most likely to occur after failure to remediate assessment findings. This is because termination for cause is based on a breach of contract by the third-party, such as non-compliance, poor performance, fraud, or misconduct. Failure to remediate assessment findings indicates that the third-party has not met the contractual obligations or expectations of the entity, and thus exposes the entity to increased risk and liability. Termination for cause allows the entity to end the contract immediately or after a notice period, and to seek damages or remedies from the third-party. Termination for cause is different from other types of contract termination, such as:

• Regulatory/supervisory termination, which is triggered by a change in law or regulation that affects the legality or feasibility of the contract.
• Termination for convenience, which is exercised by the entity without any fault or breach by the third-party, usually for strategic or operational reasons.
• Normal termination, which is the natural expiration of the contract term or the completion of the contract scope. References:
• Shared Assessments. (2020). Certified Third Party Risk Professional (CTPRP) Study Guide1
• Fusion Risk Management. (2021). Exit Strategy for Terminating a Third Party2
• Volkov, M. (2016). Third-Party Risk Management – Part 2: Contract Termination3

The primary objective of a third party risk assessment is to validate that the vendor/service provider has adequate controls in place based on the organization’s risk posture. A third party risk assessment (also known as supplier risk assessment) quantifies the risks associated with third-party vendors and suppliers that provide products or services to your organization1. This assessment is useful for analyzing both new and ongoing supplier relationships. The growing risk of supply chain attacks makes it critical to conduct thorough and regular risk assessments of your third parties. A third party risk assessment helps you identify, measure, and mitigate the potential risks that your third parties pose to your organization, such as data breaches, cyberattacks, compliance violations, operational disruptions, reputational damage, or financial losses. A third party risk assessment also helps you align your third party risk management (TPRM) program with your organization’s risk appetite, policies, standards, and procedures. A third party risk assessment typically involves the following steps1:

• Scoping: Define the scope of the assessment based on the type, nature, and criticality of the third party relationship. Determine the relevant risk domains, such as security, privacy, compliance, business continuity, etc.
• Data collection: Gather information from the third party using various methods, such as questionnaires, surveys, interviews, audits, tests, or evidence reviews.
• Analysis: Analyze the data collected and compare it with your organization’s risk criteria, benchmarks, and best practices. Identify any gaps, weaknesses, or issues in the third party’s controls, processes, or performance.
• Reporting: Document the findings and recommendations of the assessment in a clear and concise report. Communicate the results to the relevant stakeholders, such as senior management, business owners, or regulators.
• Remediation: Follow up with the third party to ensure that they implement the necessary actions to address the identified risks. Monitor and track the progress and effectiveness of the remediation plan.
• Review: Review and update the assessment periodically or whenever there are significant changes in the third party relationship, the risk environment, or the regulatory requirements.

The other statements are not the primary objective of a third party risk assessment, although they may be related or secondary objectives. Assessing the appropriateness of non-disclosure agreements regarding the organization’s systems/data is a legal objective that may be part of the contract negotiation or review process. Determining the scope of the business relationship is a strategic objective that may be part of the vendor selection or due diligence process. Evaluating the risk posture of all vendors/service providers in the vendor inventory is a holistic objective that may be part of the vendor risk management or governance process. References:

• 1: Third-Party Risk Assessment: A Practical Guide - BlueVoyant
• : What Is Third-Party Risk Management (TPRM)? 2024 Guide | UpGuard
• : What is Third-Party Risk Management? | Blog | OneTrust

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.”

Fourth-Nth party risk refers to the potential threats and vulnerabilities associated with the subcontractors, vendors, or service providers of an organization’s direct third-party partners12. After contract signing and on-boarding due diligence is complete, the most important type of contract provision to manage Fourth-Nth party risk is subcontractor notice and approval. This provision requires the third party to inform the organization of any subcontracting arrangements and obtain the organization’s consent before engaging any Fourth-Nth parties345. This provision enables the organization to have visibility and control over the extended network of suppliers and service providers, and to assess the potential risks and impacts of any outsourcing decisions. Subcontractor notice and approval also helps the organization to ensure that the Fourth-Nth parties comply with the same standards and expectations as the third party, and to hold the third party accountable for the performance and security of the Fourth-Nth parties345. References:

• 1: Understanding 4th- and Nth-Party Risk: What Do You Need to Know? | Mitratech
• 2: Understanding 4th- and Nth-Party Risk: What Do You Need to Know? | Mitratech Holdings, Inc - JDSupra
• 3: First, 2nd , 3rd , 4th, 5th Parties: How to Measure the Tiers of Risk
• 4: Managing 4th Party Risk with Vendor Insurance Verification - Evident ID
• 5: How to Write Fourth-Party Vendor Requirements Into the Contract - Venminder

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

Contract addendums are supplementary documents that modify or amend the original contract terms. They can be used to address third party risk obligations, such as security, privacy, compliance, or performance standards, without having to rewrite the entire MSA. However, contract addendums should be consistent with the MSA and clearly specify the scope, duration, and responsibilities of each party. Contract addendums can also be used to update or revise the contract terms in response to changing business needs or regulatory requirements12.

The other statements are true regarding the different types of contracts and agreements between outsourcers and service providers. Evergreen contracts are contracts that do not have a fixed end date and are automatically renewed unless one party decides to terminate them under the existing contract provisions3. RFPs are documents that solicit proposals from potential service providers for a specific project or service. RFPs should include mandatory requirements based on an organization’s TPRM program policies, standards and procedures, such as risk assessment, due diligence, monitoring, reporting, and remediation . SOWs are documents that define the operational requirements and obligations for each party, such as the scope, deliverables, timelines, costs, quality, and performance metrics . References:

• 1: Contracts and third-party risk - KPMG UK
• 2: Third-Party Risk & Contract Management: A Comprehensive Beginner’s Guide - Trackado
• 3: What Is an Evergreen Contract? | Legal Beagle
• : [Best Practices Guidance for Third Party Risk - GARP]
• : Third-Party Risk Management: A Comprehensive Guide - UpGuard
• : Statement of Work (SOW) - Definition, Contents & Examples
• : How to Write a Statement of Work for Any Industry | Smartsheet

 An Asset Management program is a set of policies, procedures, and practices that aim to optimize the value, performance, and lifecycle of the organization’s assets, such as physical, financial, human, or information assets123. An Asset Management program typically defines policy requirements for the following aspects of asset management:

• The Policy states requirements for the reuse of physical media (e.g., devices, servers, disk drives, etc.): This requirement ensures that the organization follows proper procedures for sanitizing, wiping, or destroying physical media that contain sensitive or confidential data before reusing, recycling, or disposing of them123. This requirement helps prevent data leakage, theft, or loss, and protects the organization’s reputation and compliance123.
• The Policy requires that employees and contractors return all company data and assets upon termination of their employment, contract or agreement: This requirement ensures that the organization recovers all the data and assets that were assigned, loaned, or accessed by the employees and contractors during their employment, contract, or agreement123. This requirement helps maintain the security, integrity, and availability of the organization’s data and assets, and prevents unauthorized or inappropriate use or disclosure of them123.
• The Policy defines requirements for the inventory, identification, and disposal of equipment and/or physical media: This requirement ensures that the organization maintains an accurate and up-to-date record of all the equipment and physical media that it owns, leases, or uses, and assigns unique identifiers to them123. This requirement also ensures that the organization follows proper procedures for disposing of equipment and physical media that are no longer needed, useful, or functional123. This requirement helps improve the efficiency, effectiveness, and accountability of the organization’s asset management processes, and reduces the risks of waste, fraud, or misuse of the organization’s resources123.

However, option D, a policy requirement that requires visitors (including other tenants and maintenance personnel) to sign-in and sign-out of the facility, and to be escorted at all times, is typically not defined in an Asset Management program. Rather, this requirement is more likely to be defined in a Physical Security program, which is a set of policies, procedures, and practices that aim to protect the organization’s premises, assets, and personnel from unauthorized access, damage, or harm . A Physical Security program typically defines policy requirements for the following aspects of physical security:

• The Policy requires visitors (including other tenants and maintenance personnel) to sign-in and sign-out of the facility, and to be escorted at all times: This requirement ensures that the organization controls and monitors the access of visitors to the facility, and verifies their identity, purpose, and authorization . This requirement also ensures that the organization prevents visitors from accessing restricted or sensitive areas, equipment, or information, and escorts them throughout their visit . This requirement helps enhance the security, safety, and compliance of the organization’s facility, assets, and personnel, and prevents potential threats, incidents, or breaches .
• The Policy defines requirements for the locking, alarming, and surveillance of the facility and its entrances and exits: This requirement ensures that the organization secures the perimeter and the interior of the facility, and detects and responds to any unauthorized or suspicious activity or intrusion . This requirement also ensures that the organization uses appropriate and effective physical security measures, such as locks, alarms, cameras, guards, or barriers, to deter, prevent, or delay unauthorized access . This requirement helps protect the organization’s facility, assets, and personnel from theft, vandalism, sabotage, or attack .
• The Policy specifies requirements for the emergency preparedness and response of the facility and its occupants: This requirement ensures that the organization plans and implements procedures for dealing with emergencies, such as fire, flood, earthquake, power outage, or active shooter, that may affect the facility and its occupants . This requirement also ensures that the organization provides adequate and accessible equipment, resources, and training for the emergency preparedness and response, such as fire extinguishers, first aid kits, evacuation routes, emergency contacts, or drills . This requirement helps ensure the safety, health, and continuity of the organization’s facility, assets, and personnel, and minimizes the impact and damage of emergencies .

Therefore, option D is the correct answer, as it is the only one that does not reflect a policy requirement that is typically defined in an Asset Management program. References: The following resources support the verified answer and explanation:

• 1: Asset Management Policy Guide + Free Template | Fiix
• 2: Asset Management Policy: How to Build One From Scratch - Limble CMMS
• 3: How to develop an asset management policy, strategy and governance framework: Set up a consistent approach to asset management in your municipality
• : Physical Security Policy - SANS
• : Physical Security Policy - IT Governance

Change management is the process of controlling and documenting any changes to the scope, objectives, requirements, deliverables, or resources of a project or a program. Change management ensures that the impact of any change is assessed and communicated to all stakeholders, and that the changes are implemented in a controlled and coordinated manner. Compliance artifacts are the documents, records, or reports that demonstrate the adherence to the change management process and the regulatory or industry standards.

A robust change management process should include the following attributes:

• Logging: This means that any change request or proposal is recorded in a change log or a change register, along with the details of the change initiator, the change description, the change category, the change priority, the change status, and the change history. Logging helps to track and monitor the progress and outcome of each change, and to provide an audit trail for compliance purposes.
• Approvals: This means that any change request or proposal is reviewed and approved by the appropriate authority or stakeholder, such as the project manager, the sponsor, the customer, the steering committee, or the regulatory body. Approvals help to ensure that the change is justified, feasible, aligned with the project or program objectives, and acceptable to the affected parties.
• Validation: This means that any change request or proposal is verified and tested to ensure that it meets the quality standards, the functional and non-functional requirements, and the expected benefits and outcomes. Validation helps to ensure that the change is implemented correctly, effectively, and efficiently, and that it does not introduce any errors, defects, or risks.
• Back-out and exception procedures: This means that any change request or proposal has a contingency plan or a rollback plan in case the change fails, causes problems, or is rejected. Back-out and exception procedures help to minimize the negative impact of the change, and to restore the original state or the baseline of the project or program. They also help to handle any deviations or issues that may arise during the change implementation or the change review.

References:

• CTPRP Job Guide
• An Agile Approach to Change Management
• CM Overview
• Management Artifacts and its Types
• Achieving Regulatory and Industry Standards Compliance with the Scaled Agile Framework
• 8 Steps for an Effective Change Management Process

For services with system-to-system access, ensuring sufficient time for quality assurance (QA) testing before implementing changes is crucial to reducing the risk of business disruption to the outsourcer. This requirement ensures that any modifications to the system are thoroughly vetted for potential issues that could impact the outsourcer's operations. QA testing allows for the identification and remediation of bugs, compatibility issues, and other potential problems that could lead to operational disruptions or security vulnerabilities. By allocating adequate time for QA testing, organizations can ensure that changes are fully functional and secure, thereby maintaining the integrity and availability of services provided to the outsourcer. This practice is aligned with industry standards for change management, which advocate for comprehensive testing and validation processes to ensure the reliability and stability of system changes.

References:

• Industry standards such as ITIL (Information Technology Infrastructure Library) emphasize the importance of thorough testing and validation within the change management process to minimize the risk of disruptions and ensure the smooth operation of services.
• Guides like "Managing Change in IT Outsourcing Arrangements: The TPRM Perspective" provide insights into best practices for change management in third-party relationships, including the critical role of QA testing in mitigating risks associated with system changes.

 Personal information is any information that can be used to identify an individual, either directly or indirectly, such as name, address, email, phone number, ID number, etc. Personal data is a term used in some jurisdictions, such as the European Union, to refer to personal information that is subject to data protection laws and regulations. However, the scope and definition of personal data may vary depending on the jurisdiction and the context. For example, the GDPR defines personal data as “any information relating to an identified or identifiable natural person” and includes online identifiers, such as IP addresses, cookies, or device IDs, as well as special categories of data, such as biometric, genetic, health, or political data. On the other hand, the US does not have a single federal law that regulates personal data, but rather a patchwork of sector-specific and state-level laws that may have different definitions and requirements. For example, the California Consumer Privacy Act (CCPA) defines personal information as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household” and excludes publicly available information from its scope. Therefore, from a privacy perspective, it is important to understand the different legal definitions and obligations that may apply to personal information or personal data depending on the jurisdiction and the context of the data processing activity. References:

• GDPR personal data – what information does this cover?
• Personal Information, Data Classification, Life Cycle and Best Practices
• 5 Types of Data Classification (With Examples)

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

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 …]

An emergency response plan (ERP) is a document that outlines the procedures and actions to be taken by an organization in the event of a disruptive incident that threatens its operations, assets, reputation, or stakeholders1. An ERP should be aligned with the organization’s business continuity and disaster recovery plans, and should cover the roles and responsibilities, communication channels, escalation processes, resources, and recovery strategies for different types of emergencies2.

The first step in developing an ERP is to conduct an assessment that includes an inventory of the types of events that have the greatest potential to trigger an ERP3. This assessment should consider the likelihood and impact of various scenarios, such as natural disasters, cyberattacks, pandemics, civil unrest, terrorism, or supply chain disruptions, and identify the critical functions, processes, assets, and dependencies that could be affected by these events4. The assessment should also evaluate the existing capabilities and gaps in the organization’s preparedness and response, and prioritize the areas that need improvement or enhancement5. The assessment should be based on a comprehensive risk analysis and a business impact analysis, and should involve input from relevant stakeholders, such as senior management, business units, IT, security, legal, compliance, human resources, and third parties.

The other options are not the first step in developing an ERP, but rather subsequent or complementary steps that should be performed after the initial assessment. Considering work-from-home parameters, incorporating periodic crisis management team tabletop exercises, and using the results of continuous monitoring tools are all important aspects of an ERP, but they are not the starting point for creating one. These steps should be based on the findings and recommendations of the assessment, and should be updated and tested regularly to ensure the effectiveness and relevance of the ERP. References: 1: What is an Emergency Response Plan? | IBM 2: Emergency Response Plan | Ready.gov 3: 8 Steps to Building a Third-Party Incident Response Plan | Prevalent 4: How to create an effective business continuity plan | CIO 5: Emergency Response Planning: 4 Steps to Creating a Plan : Third-Party Risk Management: Final Interagency Guidance : Improving Third-Party Incident Response | Prevalent

The frequency of cyclical assessments is one of the key factors that determines the effectiveness and efficiency of a TPRM program. Cyclical assessments are periodic reviews of the vendor’s performance, compliance, and risk posture that are conducted after the initial onboarding assessment. The frequency of cyclical assessments should be aligned with the organization’s risk appetite and tolerance, and should reflect the level of risk and criticality of the vendor to the organization’s operations. A common approach to determine the frequency of cyclical assessments is to use a vendor risk score, which is a numerical value that represents the vendor’s inherent and residual risk based on various criteria, such as the type, scope, and complexity of the services or products provided, the vendor’s security and privacy controls, the vendor’s compliance with relevant regulations and standards, the vendor’s past performance and incident history, and the vendor’s business continuity and disaster recovery capabilities. The vendor risk score can be used to categorize the vendors into different risk tiers, such as high, medium, and low, and assign appropriate frequencies for cyclical assessments, such as annually, biannually, or quarterly. For example, a high-risk vendor may require an annual assessment, while a low-risk vendor may require a biannual or quarterly assessment. The vendor risk score and the frequency of cyclical assessments should be reviewed and updated regularly to account for any changes in the vendor’s risk profile or the organization’s risk appetite.

The other three statements do not best reflect the factors that help you determine the frequency of cyclical assessments, as they are either too rigid, too vague, or too reactive. Statement A implies that vendor assessments are only necessary during onboarding and can be replaced by continuous monitoring afterwards. However, continuous monitoring alone is not sufficient to ensure the vendor’s compliance and risk management, as it may not capture all the aspects of the vendor’s performance and risk posture, such as contractual obligations, service level agreements, audit results, and remediation actions. Therefore, vendor assessments should be conducted during onboarding and at regular intervals thereafter, complemented by continuous monitoring. Statement C suggests that vendor assessments should be scheduled based on the type of services or products provided, without considering the other factors that may affect the vendor’s risk level and criticality, such as the vendor’s security and privacy controls, the vendor’s compliance with relevant regulations and standards, the vendor’s past performance and incident history, and the vendor’s business continuity and disaster recovery capabilities. Therefore, statement C is too vague and does not provide a clear and consistent basis for determining the frequency of cyclical assessments. Statement D indicates that vendor assessment frequency may need to be changed if the vendor has disclosed a data breach, implying that the frequency of cyclical assessments is only adjusted in response to a negative event. However, this approach is too reactive and may not prevent or mitigate the impact of the data breach, as the vendor’s risk level and criticality may have already increased before the data breach occurred. Therefore, statement D does not reflect a proactive and risk-based approach to determining the frequency of cyclical assessments. References:

• Third-Party Risk Management 101: Guiding Principles
• Mastering the TPRM Lifecycle
• Third Party Risk Management Maturity Assessment

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