Managing Third Party Risk in the Now

Managing Third Party
Risk in the Now
Justine Lowe
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Justine Lowe
Executive Director, Executive Advisory
Optiv
With more than 19 years of information risk and security experience,
Lowe has developed a strong business understanding and skills to
mitigate risks to the business to reduce and respond to cyber risks.
Her core competencies include leadership, security policy and
awareness, governance, risk and compliance programs.
Lowe is the former lead of policy, awareness and compliance for a big
four firm, KPMG, where she had enterprise wide responsibility for
setting policy aligned to ISO27001/2: 2013 and ensuring that the
KPMG firms worldwide and third parties had required information
security and privacy controls. Her prior role at KPMG was as CISO
for the Africa region which included setting strategy, security incident
management, secure application development and risk assessments.
Proprietary and Confidential. Do Not Distribute. © 2016 Optiv Inc. All Rights Reserved.
MANAGING THIRD PARTY RISK
Relationship
with Third
Party
Third-Party
Business
Profile
IT Controls
Analysis
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Current Practices & The Future
Growing Problem
•
•
•
•
•
Over
Sheer volume
Costly third-party due-diligence
Global regulatory requirements
Data and privacy security breaches
Fiduciary board - top of mind
The Future
%
50
•
•
•
•
•
of all breaches
come from third parties(1)
(former and current service providers, consultants,
suppliers and partners)
5 (1) Source: Key findings from The Global State of Information Security® Survey 2016
Automation of manual processes
Global scale
Ability to make informed risk decisions
Due-diligence matched to level of risk
Single source for all third-party risk data
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Third-Party Targeted Attacks
“Insider”
“Trusted”
“Outsourcer”
Supplier with
Trusted Access
Service Provider
Your Business
Third-Party Attacks
Target of Opportunity
Breach a major supplier
and you gain access to
multiple companies’ data
Global Problem
A supplier anywhere in
the world can be the
cause of, or suffer from
a security breach
Economic Conditions
Increased outsourcing
and financial stress on
third parties can lower
defenses
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Are You Responsible for a Breach at a Third Party?
Customers don’t care about your business
partners.
Consequences:
They entrust you with the information.
Loss of Customer Loyalty
Eroded Share Value
Increased
Scrutiny
Litigation
Brand Damage
Lawsuits
Higher Audit Costs
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Exploiting the “Trusted” Third Party
THIRD
PARTY or
“INSIDER”
THE ATTACKER’S
TARGET
Capture
Login
Credentials
External Facing
Application
Use
Credentials
to Get Inside
Critical
Data
Lateral
Escalate
 Movement
Privileges
ACTORS and METHODS:
=
12
Hacktivists
Criminal Orgs
State Sponsored
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Risk Based /
Data Centric
The TPRM
Journey
Lifecycle
Focused
Ultimate Goal is Risk Based/Data
Centric supporting the lifecycle with
automation
Technology
Hopeful
Spreadsheet
Based
Ad Hoc
Program
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STRATEGIC
TPRM
Engaging at
Every Level
Program Level
• Business strategy and management
• Managed Service
Problems Level
• Program Development
• Integration product with intelligence
Project Level
• TPRM Intelligence Product Evaluation
• Product Deployment
• Manual assessment of a Third Party
TACTICAL
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The Five Steps of Third-Party Risk Lifecycle
5. Renewal
Management
1. Inherent Risk
Evaluation
Portfolio Management
Consistently evaluate
and classify inherent
business risks
2. Technical Diligence
3. Risk
Reduction
Risk Assessment
Remediation
Assessment
Automation and
Tracking
Validation
Automation and
Scaling
Remediation
Management and
Signoff
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4. Monitoring
and Reporting
Operational
Visibility
Customizable
Dashboard & Reporting
Plan, Develop and Manage Third-Party
Risk Programs
Discovery
and Analysis
Program
Development
Maturity
Assessment
•
•
•
•
Program review
High level gap
Maturity assessment
Program Roadmap
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Develop tool set
• Policy/standard
• Procedure
• Methodology
• Risk scoring
• Risk register
• Questionnaire
• Identify vendors
• Define assets
• Tier rank
vendors
• Action plan
Risk
Assessments
Third Party Risk
Managed Service
• Enterprise view of risk
to provide consistent
risk decisions
• Questionnaire
development
• Services reduce cost
• Interact with
and resources
vendors
necessary to manage
third party risk
• Review
questionnaires
• Common process and
structure based on
• Onsite assessment
best practices
as appropriate
• Monitor and manage
• Analysis
vendor progress
• Findings and
recommendations
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Third-Party Contracts
Restrictions on
Outsourcing
Security
Service Level
Agreement
Breach
Notification
Security Safeguards
Right to
Audit
Indemnification,
Cyber Insurance, etc.
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Relationship Exposure Inventory
• Relationship Exposure Inventory – Risk Register
•
Maintain a relationship list (type and quantity)
• Relationship “Creep”
•
•
•
Due diligence is performed during the first contract
Relationship grows over time
Increased liability without updating the risk exposure
metrics
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Business Profile Risk
• Purpose: Who is The Third Party?
• Understand the Risk of Doing Business With Third Party





Financial Strength/Credit Risk
Regulatory Oversight
Geopolitical/Economic Risk
Business Risk
Breach History, Crime, Legal Suit
• Most often performed outside of Information Security
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Mapping Risk Tiers
Tier 1
Tier 2
Tier 3
High
Medium
Low
Reputational Risk
High
Medium
Low
Transaction Risk
$$$$$
$$$$
$$$
Compliance Risk
High
Medium
Low
Data Privacy Risk
High
Medium
Low
Credit Risk
$$$$$
$$$$
$$$
Country Risk
High
Medium
Low
Other Risks
High
Medium
Low
Relationship Risk
Strategic Risk
Business Profile Risk
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Tiering Third Parties
Average Enterprise Has 1000s of Third-Parties
1.5%
- 2%
90% - 95%
6% - 8%
Tier 1
Tier 2
Tier 3
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Third Party Tiered Management
Tier 1
Annual Questionnaire
Control Validation
(evidence)
Site Visit
External Audit (e.g. SOC1)
External pen tests
Internal pen tests
Documentation request
Tier 2
Tier 3
Extended Standar
d
Full
Partial
Short
Yes
Yes
No
No
No
No
Yes
Yes
Full
Yes
Yes
Partial
Yes
No
Brief
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No
Control Assessments
Standardized Assessments
• Match Due-Diligence to Risk and Type of Service
•
•
•
•
Full Assessment - Large
Full Assessment - Light
Cloud Computing
Application Development
• Call Center
• Small Office
• Single Person Office
• No Ambiguity
• How You Ask Questions is as Important as What You
Ask
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When to Review
During the RFP /
Evaluation Process
When the Business
Relationship Changes
When the Business
Risk Profile Changes
When a Regulation
Changes
At Least Annually
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Third-Party Risk Monitoring
Threat
Intelligence
Financial
Data
Level 1
(unintrusive)
Use web
information as
indicator on level
of control maturity
External ThirdParty Sites
Level 2
(Semi-intrusive)
Direct Interaction
with Third Party
People
Process
Tool
Risk Reports
M&A
Maturity Assessments
Risk Assessment
Threat Modeling
Application Security
Breach Reports
Maturity of
security program;
people, process
and technology
Technology
Level 3
(intrusive)
Direct Interaction
with Technology
Use technology to
scan system
configuration and
controls
Economic
Data
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Social Data
ERM
Third-Party Risk Management Solutions’ Mission:
Plan
Determine the third-party risk
management capabilities
required by the business
Build
Develop the capabilities and
governance for a cost effective
program
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Run
Manage the process and
reporting to determine inherent
risk, assess the controls and
drive remediation
Optiv - A Full Service Security Firm
- Based in North America with Global Reach
- Formerly Accuvant and Fishnet Security
Architecture and
Implementation
Advisory Services
Program strategy
Risk Management
Compliance
Penetration testing
Vulnerability assessment
Software security
Incident response
Cloud security
Identity access management
Planning and design
Identification and selection
Implementation and migration
Integration
Optimization
Product support
Applied Research
Education and Awareness
Solution research
Technical product research
Advanced research
End user security
Technology training
Secure development
Advanced security
Solution Architectures to Programmatic Blueprints
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Confidential
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Questions?
[email protected]
www.optiv.com
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Proprietary and Confidential. Do Not Distribute. © 2016 Optiv Inc. All Rights Reserved.