Third Party Risk Management 12 April 2012

Size: px
Start display at page:

Download "www.pwc.com Third Party Risk Management 12 April 2012"

Transcription

1 Third Party Risk Management 12 April 2012

2 Agenda 1. Introductions 2. Drivers of Increased Focus on Third Parties 3. Governance 4. Third Party Risks and Scope 5. Third Party Risk Profiling 6. Third Party Monitoring 7. Technology Enablers 8. Service Organization Reports and Standards

3 Globalization and business partnerships are increasingly being leveraged as strategic enablers According to s 14 th Annual Global CEO Survey: Companies are reshaping strategies and operating models focusing on innovation, collaboration, and talent to find new sources of revenue growth and competitive advantage Partnerships will be key - 40% of CEOs expect the majority of innovations over the next three years to be co-developed with partners - 50% said their companies will enter into a strategic alliance or JV in the coming year Roughly a third of CEOs indicated their companies plan to complete a cross-border merger or acquisition, or outsource a business process or function in the next year As organizational models shift and risk profiles evolve, executives and Boards seek greater transparency and increased assurance that the company s most significant risks are appropriately mitigated Slide 3

4 Some additional data points on third-parties and security 39% have established security baselines for partners/customers/vendors. Taking this one step further, only 23.6% of respondents stated they have security procedures partners/suppliers must comply with. 69% of respondents said somewhat to very confident when asked how confident they are in partners'/suppliers' information security. 35% of the time, respondents state their organizations were informed of security breaches by customers or suppliers, government officials, the media or perpetrator. What is the greatest security risk to your cloud computing strategy? Uncertain ability to enforce provider site security policies % Questionable privileged access control at provider site % Proximity of your data to someone else's % Uncertain ability to recover data - 9.0% Uncertain continued existence of provider - 3.7% Uncertain provider regulatory compliance - 3.5% Uncertain ability to audit provider - 2.8% Access across an untrusted network - 4.1% Slide 4

5 Managing security-related risks associated with business partners has always been an issue; however, it s getting worse Over the past 24 months, the number of security incidents attributed to customers, partners, and suppliers has nearly doubled. Customer 10% 12% 17% 2009 Partner or supplier 8% 11% 15% % 5% 10% 15% 20% Source: 2012 Global State of Information Security Survey. Question 22: Estimated likely source of incident. (Not all factors shown. Totals do not add up to 100%.) Slide 5

6 While risks associated with third parties continue to increase, many companies are less prepared to defend their data Over the past two years, organizations have allowed data privacy safeguards to degrade, exposing the enterprise to potential compromise. (Source: 2012 Global Information Security Survey) GISS Survey results Due diligence of third parties handling personal data 35% 32% 29% Inventory of all third parties handling personal data Require third parties to comply with our policies 29% 28% 24% 29% 34% 39% Incident response process to report and handle breaches 30% 27% 35% 0% 10% 20% 30% 40% 50% 60% Question 15: Which data privacy safeguards does your organization have in place? Question 16: What information security safeguards related to people does your organization currently have in place? Not all factors shown. Totals do not add up to 100%. Slide 6

7 Level-setting: definitions Third-party defined: For our purposes, we define a third-party as any entity not under direct business control of a given organization. Many people equate thirdparties with vendors, but that s not always the case; consider: Vendors / suppliers of products or services Business partners (JV partners, alliances, etc.) Marketing partners Strategic consultants Government agencies Regulatory bodies Customers Third-party risk management encompasses vendor risk management, but is more broadly focused on gaining a understanding of organizational risks and understanding which of those risks may be either positively or negatively affected by third-parties that the company does business with. Third-party risk assessment is the process determining the risk associated to a specific third party. Results of risk assessment are used to determine if a review is required. Third-party review is the process of evaluating third parties control environment. These may be performed on-site or remotely. How do you define third-party risk? Slide 7

8 Example third party risk management governance Enterprise Risk Committee Governance Critical Third Party Oversight Committee Third Party Management Office Third Party Relationship Officer Management & Oversight Business Unit Operational Risk Oversight Third Party Risk Manager (High & Critical Risk Services) Procurement Sourcing Contracts Management InfoSec TBD Subject Matter Specialists PhySec TBD Financial Due Diligence Reputational Due Diligence BCM TBD Legal & Compliance Internal Audit Vendors Slide 8

9 Governance Organization 1. Who leads IT control assessments of third-parties at your organization? 2. How does internal audit play a role? 3. How formal is your third-party security assessment function? Slide 9

10 Third Party Risk Management Information Technology Contracts Management Legal Information Security Business & Operations Privacy Business Continuity Compliance Vendor Risk Assessment Risk Prioritized Planning Process Determine risk factors Survey relationships Leverage internal stakeholder knowledge Develop prioritized assessment schedule Pre-visit activities Communicate review process, goals, and methodologies to third-party Prepare/process paperwork Survey third-party Arrange site visit schedule Reporting Document reviews Communicate findings with internal stakeholders Develop plan of action to address significant deficiencies Plan re-testing Site visit Meet third-party Review survey responses Physical walkthrough Contracts, policy, configuration examination Solution Delivery Foundation Risk-prioritized selection approach Third-Party Surveys Physical Security Walkthrough Policy & procedure Reviews Technical configuration validation Third-Party Sub-contract Review Reporting and Ranking Follow-up with Internal Customers Slide 10

11 Landscape of third party risk Focus on third parties that: Perform functions on behalf of the Company Provide products and services that the Company does not originate Franchise the Company s attributes (Brand) Risks to be managed when using third parties Reputation Technology Strategic Supply Chain Security Credit Compliance Privacy Other (liquidity, price, Fx, country) Transactional Operations Due Diligence Experience Audited financial statements Reputation, complaints, litigation Qualifications Internal controls Adequacy of MIS BCP/DR Cost of development, implementation and support Use of third parties Supply Chain Transparency Insurance Risk Assessment Integration with strategic objectives Expertise to oversee and manage activity Cost/Benefit Customer expectations Contract Scope of arrangement Performance measures Responsibility for management information reports Right to audit Cost and compensation Ownership and license Confidentiality and security Business resumption Indemnification Insurance Dispute resolution Limits on liability Default and termination Customer complaints Ongoing Oversight Financial condition Financial statements Supplier s obligations to sub-suppliers Insurance coverage Monitor controls Audit reports Supplier policies On-site visits Compliance risks BC/DR plans and test results Quality of service and support SLA reporting Problem management Alignment with organization s strategy Customer complaints Customer satisfaction survey Periodic performance meetings Expected documentation List of suppliers - valid, current and complete contracts Business plans identifying management s planning process, decisions and due diligence Evidence the firm evaluated supplier s controls and monitors supplier s performance Regular reports to board, or delegated committee, of the results of ongoing oversight activity Slide 11

12 Types of risk to consider Operational Risk Risk that arises from the potential that inadequate internal controls, operational problems, breaches in internal controls, unforeseen catastrophes, or decentralized operations could result in unexpected losses, the inability to maintain a competitive position, or the inability to maintain a well controlled IT processing environment. Associated with: Business locations Business units Business process Transaction processing Unauthorized activities Cost efficiencies Intellectual property Functionality Security Business continuity IT change management Compliance & Regulatory Risk Risk arising from the potential that unenforceable contracts, lawsuits, or adverse judgments can disrupt or otherwise negatively affect the operations of client and adverse consequences from nonconformance with rules and regulations. Associated with: HIPAA HITECH PCI Sarbanes-Oxley Litigation Human resource regulation Contracts Privacy laws and regulations Developing e-business laws and regulations (local, state, national, international) State laws Financial Risk Technology Risk Strategic Risk Risk arising from the potential that incomplete, inaccurate, or unauthorized transactions, fraud, or inadequate internal controls could affect the integrity of information regarding the financial condition of client. Associated with: Sarbanes-Oxley Transaction processing Unauthorized activities SEC and accounting governance standards Fair disclosure IT change management Security Interface Consolidations Data integrity Data sensitivity Risk arising from the potential that new systems, technologies, inter- and intra -connectivity, third-party connectivity, changes, and security threats could adversely affect the integrity and confidentially of client data and transactions, as well as the efficiency, effectiveness, and availability of the IT processing environment. Associated with: IT change management Operating platforms Databases Web-based applications Network connectivity Electronic communications and data transfers Security IT outsourcing / cloud Risk arising from the potential for negative publicity around client s business practices, adverse business decisions, or lack of responsiveness to changed business conditions that will cause a decline in the customer base, costly litigation, or revenue reductions. Associated with: Security or internal control breaches Intellectual property Fraud Competition Business development New products and markets Alliances Brand value Ethics and governance Third-party connections Slide 12

13 Profiling third party risk 1. Profile Third Party Data Collection Business Sponsor Previous Assessments Third party contacts Contracts Preliminary Entity Profiling Preliminary Service Profiling Preliminary Third Party Rating Output: Assessment Type Assessment Scope 2. Assess Technical Security Assessment Third Party Processes and Controls Periodic Review 3. Review and Decide Residual Risk Rating and Score Business Action: Accept Share / Transfer Reduce Remediation and Reassessment Assessment Report Third Party Report Risk Rating and Score Slide 13

14 Components of the third party risk profile Third Party Risk Profile Entity Profile (Max Score 100) Service Profile Experience & size etc. (10%) Familiarity to Company (Includes contract status) (35%) Prior Reviews (55%) Service Operation Data & Information Regulatory & Legal Depicts Category Weighting Service Scope (15%) Service Type (25%) Data Access (5%) Data Sensitivity (25%) Availability Impact (5%) Uptime Req. (5%) SOX GxP PCI PII HIPAA (2o%) Slide 14

15 Profile output (example) Slide 15 Slide 15

16 GRC & Third Party Risk Management Governance, Risk and Compliance (GRC) is an organization s response to integrated risk management Risk is managed throughout the business to better prepare the organization to be aware of and respond to risks should they materialize Common components of an operational GRC program are provided in the graphic below 3 rd party management is a key element in any formal GRC program Threat & Vulnerability Management Risk & Compliance Management Incident Management & Business Continuity Governance Third Party Management 3 rd party management is the active monitoring and evaluation of risk that pertains to the population of vendors that an organization chooses to conduct business with Risk elements specific to 3 rd party management can include such topics as: Data exchange, processing, sharing and storing A vendor s ability to recover from an incident or a disastrous event Types of data a 3 rd party manages on behalf of a company they do business with Slide 16

17 Using Technology to Improve Processes Technology solutions exist to support vendor management and the corresponding risks associated with contracted vendors Vendor management solutions can provide numerous features that allow an organization strategic advantages, as well as process efficiencies. Some of these key features include: Automated workflow routing processes such as review and approval using integrated functionality Central repository for all vendor management data a single repository containing all vendor management data allowing for consistency of data captured as well as a single data store for reports to query Ad-hoc, dashboard and schedule reporting multiple types of reports providing flexibility to look at specific vendor data details by different internal audiences Access control capabilities to control who can see what types of data and how can create, read, update or delete content records Vendor assessment the ability to create tailored questionnaires based on specific risk profiles allows an organization to gather the information they need to actively manage vendor relationships Offshoring Centers of Excellence - This support leverages an offshore model and can offload data entry, data aggregation, initial risk ranking/scoring exercises, and desktop reviews to lower costs amongst over services. Slide 17

18 Assessing third-parties: other forms of assurance Forms of assurance users may receive include: Payment Card Industry (PCI) Report of Compliance (ROC) ISO certification Safe Harbor Certification Opinions issued by CPAs under AT101 Organizations that operate information systems and provide services often provide assurance on the design and operating effectiveness via reporting under AICPA Attestation Standard No These providers typically collect, process, transmit, store, organize, maintain, or dispose of information for other entities. The AICPA recently clarified guidance under AT101 by describing three types of Service Organization Controls (SOC) reporting that may be relevant to user needs. Slide 18

19 Summary of Service Organization Control Reports SOC1 Reports SSAE No. 16, Reporting on Controls at a Service Organization establishes the requirements and guidance for a CPA examining and reporting on a service organization's description of its system and its controls that are likely to be relevant to user entities' internal control over financial reporting. SOC1 reports are needed by the auditors of the user entities' financial statements to obtain information about controls at the service organization that may affect assertions in the user entities' financial statements. SOC 1 reports are intended solely for the information and use of existing user entities, their financial statement auditors and management of the service organization. SOC 2 Reports Under AT 101 and the AICPA Guide Reporting on Controls at a Service Organization Relevant to Security, Availability, Processing Integrity, Confidentiality, or Privacy An examination engagement to report on controls at a service organization intended to mitigate risks related to security, availability, processing integrity, confidentiality, or privacy (trust services principles). Contains a detailed description of the service auditor's tests of the operating effectiveness of controls and the results of those tests, which may be necessary for a particular user to determine how it is affected by those controls. SOC 3 Reports Under AT101 following Trust Services Principles for Security, Availability, Processing Integrity, Confidentiality, or Privacy A practitioner may report on one or more of the five trust services principles. In the examination report, the opinion concludes whether the service organization maintained effective controls over its system, based on relevant TSP criteria. Slide 19

20 Questions? Rob Stouder (317) All rights reserved. In this document, "" refers to PricewaterhouseCoopers LLP, a Delaware limited liability partnership, which is a member firm of PricewaterhouseCoopers International Limited, each member firm of which is a separate legal entity. This document is for general information purposes only, and should not be used as a substitute for consultation with professional advisors.

Forensic Services. Third Party Risks. March 2013

Forensic Services. Third Party Risks. March 2013 Forensic Services Third Party Risks Landscape of third party risk Focus on third parties that: perform functions on behalf of the company provide products and services that the company does not originate

More information

Vendor Management Best Practices

Vendor Management Best Practices 23 rd Annual and One Day Seminar Vendor Management Best Practices Catherine Bruder CPA, CITP, CISA, CISM, CTGA Michigan Texas Florida Insight. Oversight. Foresight. SM Doeren Mayhew Bruder 1 $100 billion

More information

HITRUST CSF Assurance Program

HITRUST CSF Assurance Program HITRUST CSF Assurance Program Simplifying the information protection of healthcare data 1 May 2015 2015 HITRUST LLC, Frisco, TX. All Rights Reserved Table of Contents Background CSF Assurance Program Overview

More information

VENDOR MANAGEMENT. General Overview

VENDOR MANAGEMENT. General Overview VENDOR MANAGEMENT General Overview With many organizations outsourcing services to other third-party entities, the issue of vendor management has become a noted topic in today s business world. Vendor

More information

Risk Management: IT Vendor Management and Outsourcing

Risk Management: IT Vendor Management and Outsourcing www.pwc.com Risk Management: IT Vendor Management and Outsourcing Definitions Third Party is any entity not under direct business control of a given organization. Many people equate third parties with

More information

Credit Union Liability with Third-Party Processors

Credit Union Liability with Third-Party Processors World Council of Credit Unions Annual Conference Credit Union Liability with Third-Party Processors Andrew (Andy) Poprawa CEO, Deposit Insurance Corporation of Ontario Canada 1 Credit Union Liability with

More information

Service Organization Control (SOC) Reports Focus on SOC 2 Reporting Standard

Service Organization Control (SOC) Reports Focus on SOC 2 Reporting Standard Information Systems Audit and Controls Association Service Organization Control (SOC) Reports Focus on SOC 2 Reporting Standard February 4, 2014 Tom Haberman, Principal, Deloitte & Touche LLP Reema Singh,

More information

Protecting your brand in the cloud Transparency and trust through enhanced reporting

Protecting your brand in the cloud Transparency and trust through enhanced reporting Protecting your brand in the cloud Transparency and trust through enhanced reporting Third-party Assurance November 2011 At a glance Cloud computing has unprecedented potential to deliver greater business

More information

GUIDANCE FOR MANAGING THIRD-PARTY RISK

GUIDANCE FOR MANAGING THIRD-PARTY RISK GUIDANCE FOR MANAGING THIRD-PARTY RISK Introduction An institution s board of directors and senior management are ultimately responsible for managing activities conducted through third-party relationships,

More information

Risk Management of Outsourced Technology Services. November 28, 2000

Risk Management of Outsourced Technology Services. November 28, 2000 Risk Management of Outsourced Technology Services November 28, 2000 Purpose and Background This statement focuses on the risk management process of identifying, measuring, monitoring, and controlling the

More information

Microsoft s Compliance Framework for Online Services

Microsoft s Compliance Framework for Online Services Microsoft s Compliance Framework for Online Services Online Services Security and Compliance Executive summary Contents Executive summary 1 The changing landscape for online services compliance 4 How Microsoft

More information

Developing National Frameworks & Engaging the Private Sector

Developing National Frameworks & Engaging the Private Sector www.pwc.com Developing National Frameworks & Engaging the Private Sector Focus on Information/Cyber Security Risk Management American Red Cross Disaster Preparedness Summit Chicago, IL September 19, 2012

More information

Any business relationship between a bank and another entity, by contract or otherwise

Any business relationship between a bank and another entity, by contract or otherwise An Overview for Bank Directors Managing the Third Party Relationship Patrick Neuman Boardman & Clark LLP Madison, Wisconsin Any business relationship between a bank and another entity, by contract or otherwise

More information

Information for Management of a Service Organization

Information for Management of a Service Organization Information for Management of a Service Organization Copyright 2011 American Institute of Certified Public Accountants, Inc. New York, NY 10036-8775 All rights reserved. For information about the procedure

More information

Risk Considerations for Internal Audit

Risk Considerations for Internal Audit Risk Considerations for Internal Audit Cecile Galvez, Deloitte & Touche LLP Enterprise Risk Services Director Traci Mizoguchi, Deloitte & Touche LLP Enterprise Risk Services Senior Manager February 2013

More information

HITRUST CSF Assurance Program You Need a HITRUST CSF Assessment Now What?

HITRUST CSF Assurance Program You Need a HITRUST CSF Assessment Now What? HITRUST CSF Assurance Program You Need a HITRUST CSF Assessment Now What? Introduction This material is designed to answer some of the commonly asked questions by business associates and other organizations

More information

Dodging Breaches from Dodgy Vendors: Tackling Vendor Risk Management in Healthcare

Dodging Breaches from Dodgy Vendors: Tackling Vendor Risk Management in Healthcare Dodging Breaches from Dodgy Vendors: Tackling Vendor Risk Management in Healthcare Strengthening Cybersecurity Defenders #ISC2Congress Healthcare and Security "Information Security is simply a personal

More information

Keeping watch over your best business interests.

Keeping watch over your best business interests. Keeping watch over your best business interests. 0101010 1010101 0101010 1010101 IT Security Services Regulatory Compliance Services IT Audit Services Forensic Services Risk Management Services Attestation

More information

TO: Chief Executive Officers of National Banks, Federal Branches and Data-Processing Centers, Department and Division Heads, and Examining Personnel

TO: Chief Executive Officers of National Banks, Federal Branches and Data-Processing Centers, Department and Division Heads, and Examining Personnel AL 2000 12 O OCC ADVISORY LETTER Comptroller of the Currency Administrator of National Banks Subject: Risk Management of Outsourcing Technology Services TO: Chief Executive Officers of National Banks,

More information

9/14/2015. Before we begin. Learning Objectives. Kevin Secrest IT Audit Manager, University of Pennsylvania

9/14/2015. Before we begin. Learning Objectives. Kevin Secrest IT Audit Manager, University of Pennsylvania Evaluating and Managing Third Party IT Service Providers Are You Really Getting The Assurance You Need To Mitigate Information Security and Privacy Risks? Kevin Secrest IT Audit Manager, University of

More information

THIRD PARTY. T i m L i e t z R e g i o n a l P r a c t i c e L e a d e r R i s k A d v i s o r y S e r v i c e s

THIRD PARTY. T i m L i e t z R e g i o n a l P r a c t i c e L e a d e r R i s k A d v i s o r y S e r v i c e s MANAGING THIRD PARTY RISK T i m L i e t z R e g i o n a l P r a c t i c e L e a d e r R i s k A d v i s o r y S e r v i c e s Experis -- a different kind of talent company. Experis Tuesday, January 08,

More information

Cybersecurity The role of Internal Audit

Cybersecurity The role of Internal Audit Cybersecurity The role of Internal Audit Cyber risk High on the agenda Audit committees and board members are seeing cybersecurity as a top risk, underscored by recent headlines and increased government

More information

Information Security Management System for Microsoft s Cloud Infrastructure

Information Security Management System for Microsoft s Cloud Infrastructure Information Security Management System for Microsoft s Cloud Infrastructure Online Services Security and Compliance Executive summary Contents Executive summary 1 Information Security Management System

More information

PRINCIPLES ON OUTSOURCING OF FINANCIAL SERVICES FOR MARKET INTERMEDIARIES

PRINCIPLES ON OUTSOURCING OF FINANCIAL SERVICES FOR MARKET INTERMEDIARIES PRINCIPLES ON OUTSOURCING OF FINANCIAL SERVICES FOR MARKET INTERMEDIARIES TECHNICAL COMMITTEE OF THE INTERNATIONAL ORGANIZATION OF SECURITIES COMMISSIONS FEBRUARY 2005 Preamble The IOSCO Technical Committee

More information

OCC 98-3 OCC BULLETIN

OCC 98-3 OCC BULLETIN To: Chief Executive Officers and Chief Information Officers of all National Banks, General Managers of Federal Branches and Agencies, Deputy Comptrollers, Department and Division Heads, and Examining Personnel

More information

WELCOME TO SECURE360 2013

WELCOME TO SECURE360 2013 WELCOME TO SECURE360 2013 Don t forget to pick up your Certificate of Attendance at the end of each day. Please complete the Session Survey front and back, and leave it on your seat. Are you tweeting?

More information

Threat and Vulnerability Management (TVM) Protecting IT assets through a comprehensive program. Chicago IIA/ISACA

Threat and Vulnerability Management (TVM) Protecting IT assets through a comprehensive program. Chicago IIA/ISACA www.pwc.com Vulnerability Management (TVM) Protecting IT assets through a comprehensive program Chicago IIA/ISACA 2 nd Annual Hacking Conference Introductions Paul Hinds Managing Director Cybersecurity

More information

Impact of New Internal Control Frameworks

Impact of New Internal Control Frameworks Impact of New Internal Control Frameworks Webcast: Tuesday, February 25, 2014 CPE Credit: 1 0 With You Today Bob Jacobson Principal, Risk Advisory Services Consulting Leader West Region Bob.Jacobson@mcgladrey.com

More information

The Changing IT Risk Landscape Understanding and managing existing and emerging risks

The Changing IT Risk Landscape Understanding and managing existing and emerging risks The Changing IT Risk Landscape Understanding and managing existing and emerging risks IIA @ Noon Kareem Sadek Senior Manager, Deloitte Canada Chris Close Senior Manager, Deloitte Canada December 2, 2015

More information

OUTSOURCING DUE DILIGENCE FORM

OUTSOURCING DUE DILIGENCE FORM OUTSOURCING DUE DILIGENCE FORM SERVICE TO BE OUTSOURCED 1. Type of service to be outsourced: Accounting/Finance: Compliance Consulting: Legal Services: Administrative Functions: Information Technology:

More information

Top 10 Tips and Tools for Meeting Regulatory Requirements and Managing Cloud Computing Providers in the United States and Around the World

Top 10 Tips and Tools for Meeting Regulatory Requirements and Managing Cloud Computing Providers in the United States and Around the World Top 10 Tips and Tools for Meeting Regulatory Requirements and Managing Cloud Computing Providers in the United States and Around the World Web Hull Privacy, Data Protection, & Compliance Advisor Society

More information

Third-Party Cybersecurity and Data Loss Prevention

Third-Party Cybersecurity and Data Loss Prevention Third-Party Cybersecurity and Data Loss Prevention SESSION ID: DSP-W04A Brad Keller Sr. Vice President Santa Fe Group Jonathan Dambrot, CISSP CEO, Co-Founder Prevalent Networks 3rd Party Risk Management

More information

Consolidated Audit Program (CAP) A multi-compliance approach

Consolidated Audit Program (CAP) A multi-compliance approach Consolidated Audit Program (CAP) A multi-compliance approach ISSA CONFERENCE Carlos Pelaez, Director, Coalfire May 14, 2015 About Coalfire We help our clients recognize and control cybersecurity risk,

More information

SOC Readiness Assessments. SOC Report - Type 1. SOC Report - Type 2. Building Trust and Confidence in Third-Party Relationships

SOC Readiness Assessments. SOC Report - Type 1. SOC Report - Type 2. Building Trust and Confidence in Third-Party Relationships Building Trust and Confidence in Third-Party Relationships Today s businesses rely heavily on outsourcing certain business tasks or functions to service organizations, even those that are core to their

More information

MAINTAINING COMPLIANCE AND MANAGING RISK IN OUTSOURCED ENGAGEMENTS. Nick Harrahill PayPal Global Security Operations

MAINTAINING COMPLIANCE AND MANAGING RISK IN OUTSOURCED ENGAGEMENTS. Nick Harrahill PayPal Global Security Operations MAINTAINING COMPLIANCE AND MANAGING RISK IN OUTSOURCED ENGAGEMENTS Nick Harrahill PayPal Global Security Operations AGENDA Inception of an engagement The legal agreement Assessing the risk Customer call

More information

Statement of Guidance: Outsourcing All Regulated Entities

Statement of Guidance: Outsourcing All Regulated Entities Statement of Guidance: Outsourcing All Regulated Entities 1. STATEMENT OF OBJECTIVES 1.1. 1.2. 1.3. 1.4. This Statement of Guidance ( Guidance ) is intended to provide guidance to regulated entities on

More information

PCI Compliance for Cloud Applications

PCI Compliance for Cloud Applications What Is It? The Payment Card Industry Data Security Standard (PCIDSS), in particular v3.0, aims to reduce credit card fraud by minimizing the risks associated with the transmission, processing, and storage

More information

SSAE 16 for Transportation & Logistics Companies. Chris Kradjan Kim Koch

SSAE 16 for Transportation & Logistics Companies. Chris Kradjan Kim Koch SSAE 16 for Transportation & Logistics Companies Chris Kradjan Kim Koch 1 The material appearing in this presentation is for informational purposes only and should not be construed as advice of any kind,

More information

3 rd Party Vendor Risk Management

3 rd Party Vendor Risk Management 3 rd Party Vendor Risk Management Session 402 Tuesday, June 9, 2015 (11 to 12pm) Session Objectives The need for enhanced reporting on vendor risk management Current outsourcing environment Key risks faced

More information

Information Security Handbook

Information Security Handbook Information Security Handbook Adopted 6/4/14 Page 0 Page 1 1. Introduction... 5 1.1. Executive Summary... 5 1.2. Governance... 5 1.3. Scope and Application... 5 1.4. Biennial Review... 5 2. Definitions...

More information

THE BEST PRACTICES FOR DATA SECURITY AND PRIVACY IN VENDOR/ CLIENT RELATIONSHIPS

THE BEST PRACTICES FOR DATA SECURITY AND PRIVACY IN VENDOR/ CLIENT RELATIONSHIPS THE BEST PRACTICES FOR DATA SECURITY AND PRIVACY IN VENDOR/ CLIENT RELATIONSHIPS Data Law Group, P.C. Kari Kelly Deborah Shinbein YOU CAN T OUTSOURCE COMPLIANCE! Various statutes and regulations govern

More information

Vendor Risk Management Financial Organizations

Vendor Risk Management Financial Organizations Webinar Series Vendor Risk Management Financial Organizations Bob Justus Chief Security Officer Allgress Randy Potts Managing Consultant FishNet Security Bob Justus Chief Security Officer, Allgress Current

More information

Managing data security and privacy risk of third-party vendors

Managing data security and privacy risk of third-party vendors Managing data security and privacy risk of third-party vendors The use of third-party vendors for key business functions is here to stay. Routine sharing of critical information assets, including protected

More information

At a glance. A provision to require a written assertion from company management is the most notable difference between the two standards.

At a glance. A provision to require a written assertion from company management is the most notable difference between the two standards. At a glance While there are some differences, SAS 70 and SSAE 16 are substantially the same. SAS 70 is an audit standard while SSAE 16 is an attest standard. Out with the old SAS 70 and in with the new

More information

Understanding SOC Reports for Effective Vendor Management. Jason T. Clinton January 26, 2016

Understanding SOC Reports for Effective Vendor Management. Jason T. Clinton January 26, 2016 Understanding SOC Reports for Effective Vendor Management Jason T. Clinton January 26, 2016 MEMBER OF PKF NORTH AMERICA, AN ASSOCIATION OF LEGALLY INDEPENDENT FIRMS 2012 Wolf & Company, P.C. Before we

More information

Outsourced Third Party Relationship Management/ Vendor Management. TTS Webinar July 15, 2015 Susan Orr CISA, CISM, CRISC, CRP

Outsourced Third Party Relationship Management/ Vendor Management. TTS Webinar July 15, 2015 Susan Orr CISA, CISM, CRISC, CRP Outsourced Third Party Relationship Management/ Vendor Management TTS Webinar July 15, 2015 Susan Orr CISA, CISM, CRISC, CRP 1 Risk Management Guidance 2 3 Appendix J: 4 - Key Elements Third Party Management

More information

PRINCIPLES ON OUTSOURCING OF FINANCIAL SERVICES FOR MARKET INTERMEDIARIES

PRINCIPLES ON OUTSOURCING OF FINANCIAL SERVICES FOR MARKET INTERMEDIARIES PRINCIPLES ON OUTSOURCING OF FINANCIAL SERVICES FOR MARKET INTERMEDIARIES A CONSULTATION REPORT OF THE INTERNATIONAL ORGANIZATION OF SECURITIES COMMISSIONS STANDING COMMITTEE 3 ON MARKET INTERMEDIARIES

More information

Sample Financial institution Risk Management Policy 2011

Sample Financial institution Risk Management Policy 2011 Sample Financial institution Risk Management Policy 2011 1 Contents Risk Management Program...2 Internal Control and Risk Management Diagram... 2 General Control Environment... 2 Specific Internal Control

More information

SERVICE ORGANIZATION CONTROL REPORTS SM. Formerly SAS 70 Reports

SERVICE ORGANIZATION CONTROL REPORTS SM. Formerly SAS 70 Reports SERVICE ORGANIZATION CONTROL REPORTS SM Formerly SAS 70 Reports SAS No. 70, Service Organizations Standard for reporting on a service organization s controls affecting user entities financial statements

More information

White Paper THE FIVE STEPS TO MANAGING THIRD-PARTY RISK. By James Christiansen, VP, Information Risk Management

White Paper THE FIVE STEPS TO MANAGING THIRD-PARTY RISK. By James Christiansen, VP, Information Risk Management White Paper THE FIVE STEPS TO MANAGING THIRD-PARTY RISK By James Christiansen, VP, Information Management Executive Summary The Common Story of a Third-Party Data Breach It begins with a story in the newspaper.

More information

HIPAA and HITECH Compliance for Cloud Applications

HIPAA and HITECH Compliance for Cloud Applications What Is HIPAA? The healthcare industry is rapidly moving towards increasing use of electronic information systems - including public and private cloud services - to provide electronic protected health

More information

Vendor Management Compliance Top 10 Things Regulators Expect

Vendor Management Compliance Top 10 Things Regulators Expect Vendor Management Compliance Top 10 Things Regulators Expect Paul M. Phillips, CFA Attorney, Adams and Reese Pamela T. Rodriguez, AAP, CIA, CISA EVP, Risk Management & Education, EastPay 2014 EastPay.

More information

IT audit updates. Current hot topics and key considerations. IT risk assessment leading practices

IT audit updates. Current hot topics and key considerations. IT risk assessment leading practices IT audit updates Current hot topics and key considerations Contents IT risk assessment leading practices IT risks to consider in your audit plan IT SOX considerations and risks COSO 2013 and IT considerations

More information

Are your business partners watching your back when you are watching your front?

Are your business partners watching your back when you are watching your front? Are your business partners watching your back when you are watching your front? Danny Shaw SE Practice Leader IT Risk Advisory Services Experis Thursday, October 4, 2012 1 Objectives: Organizations frequently

More information

VISP Vendor Information Security Plan: A tool for IT and Institutions to evaluate third party vendor capacity and technology to protect research data

VISP Vendor Information Security Plan: A tool for IT and Institutions to evaluate third party vendor capacity and technology to protect research data VISP Vendor Information Security Plan: A tool for IT and Institutions to evaluate third party vendor capacity and technology to protect research data 1 Table of Contents Executive Summary... 3 Template

More information

CYBER SECURITY AND RISK MANAGEMENT. An Executive level responsibility

CYBER SECURITY AND RISK MANAGEMENT. An Executive level responsibility CYBER SECURITY AND RISK MANAGEMENT An Executive level responsibility Cyberspace poses risks as well as opportunities Cyber security risks are a constantly evolving threat to an organisation s ability to

More information

Vendor Risk Management in the New Regulatory Environment. kpmg.com

Vendor Risk Management in the New Regulatory Environment. kpmg.com Vendor Risk Management in the New Regulatory Environment kpmg.com Vendor Risk Management in the New Regulatory Environment 2 Vendor Risk Management in the New Regulatory Environment Background Regulators

More information

Exercising Your Enterprise Cyber Response Crisis Management Capabilities

Exercising Your Enterprise Cyber Response Crisis Management Capabilities Exercising Your Enterprise Cyber Response Crisis Management Capabilities Ray Abide, PricewaterhouseCoopers, LLP 2015 PricewaterhouseCoopers LLP, a Delaware limited liability partnership. All rights reserved.

More information

CAYMAN ISLANDS. Supplement No. 5 published with Gazette No. 19 dated 14 September, STATEMENT OF GUIDANCE: OUTSOURCING REGULATED ENTITIES

CAYMAN ISLANDS. Supplement No. 5 published with Gazette No. 19 dated 14 September, STATEMENT OF GUIDANCE: OUTSOURCING REGULATED ENTITIES CAYMAN ISLANDS Supplement No. 5 published with Gazette No. 19 dated 14 September, 2015. STATEMENT OF GUIDANCE: OUTSOURCING REGULATED ENTITIES Statement of Guidance: Outsourcing Regulated Entities 1. STATEMENT

More information

Outsourcing Technology Services A Management Decision

Outsourcing Technology Services A Management Decision Outsourcing Technology Services A Management Decision A Telephone Seminar for National Banks Tuesday, July 20, 2004 And again on Wednesday, July 21, 2004 Agenda Outsourcing activities and relationships

More information

IT Insights. Managing Third Party Technology Risk

IT Insights. Managing Third Party Technology Risk IT Insights Managing Third Party Technology Risk According to a recent study by the Institute of Internal Auditors, more than 65 percent of organizations rely heavily on third parties, yet most allocate

More information

www.pwc.com The data breach lifecycle: From prevention to response IAPP global privacy summit March 6, 2014 (4:30-5:30) Draft v8 2-25-14

www.pwc.com The data breach lifecycle: From prevention to response IAPP global privacy summit March 6, 2014 (4:30-5:30) Draft v8 2-25-14 www.pwc.com The data breach lifecycle: From prevention to response IAPP global privacy summit (4:30-5:30) Draft v8 2-25-14 Common Myths 1. You have not been hacked. 2. Cyber security is about keeping the

More information

ASTRAZENECA GLOBAL POLICY SAFEGUARDING COMPANY ASSETS AND RESOURCES

ASTRAZENECA GLOBAL POLICY SAFEGUARDING COMPANY ASSETS AND RESOURCES ASTRAZENECA GLOBAL POLICY SAFEGUARDING COMPANY ASSETS AND RESOURCES THIS POLICY SETS OUT THE REQUIREMENTS FOR SAFEGUARDING COMPANY ASSETS AND RESOURCES TO PROTECT PATIENTS, STAFF, PRODUCTS, PROPERTY AND

More information

The Emergence of the ISO in Community Banking Patrick H. Whelan CISA IT Security & Compliance Consultant

The Emergence of the ISO in Community Banking Patrick H. Whelan CISA IT Security & Compliance Consultant THE MARKET LEADER IN IT, SECURITY AND COMPLIANCE SERVICES FOR COMMUNITY FINANCIAL INSTITUTIONS The Emergence of the ISO in Community Banking Patrick H. Whelan CISA IT Security & Compliance Consultant Agenda

More information

VENDOR RISK MANAGEMENT UPDATE- ARE YOU AT RISK? Larry L. Llirán, CISA, CISM December 10, 2015 ISACA Puerto Rico Symposium

VENDOR RISK MANAGEMENT UPDATE- ARE YOU AT RISK? Larry L. Llirán, CISA, CISM December 10, 2015 ISACA Puerto Rico Symposium 1 VENDOR RISK MANAGEMENT UPDATE- ARE YOU AT RISK? Larry L. Llirán, CISA, CISM December 10, 2015 ISACA Puerto Rico Symposium 2 Agenda Introduction Vendor Management what is? Available Guidance Vendor Management

More information

3rd Party Assurance & Information Governance 2014-2016 outlook IIA Ireland Annual Conference 2014. Straightforward Security and Compliance

3rd Party Assurance & Information Governance 2014-2016 outlook IIA Ireland Annual Conference 2014. Straightforward Security and Compliance 3rd Party Assurance & Information Governance 2014-2016 outlook IIA Ireland Annual Conference 2014 Continuous Education Services (elearning/workshops) Compliance Management Portals Information Security

More information

6/8/2016 OVERVIEW. Page 1 of 9

6/8/2016 OVERVIEW. Page 1 of 9 OVERVIEW Attachment Supervisory Guidance for Assessing Risk Management at Supervised Institutions with Total Consolidated Assets Less than $50 Billion [Fotnote1 6/8/2016 Managing risks is fundamental to

More information

Vendor Management: An Enterprise-wide Focus. Susan Orr, CISA CISM CRISC CRP Susan Orr Consulting, Ltd.

Vendor Management: An Enterprise-wide Focus. Susan Orr, CISA CISM CRISC CRP Susan Orr Consulting, Ltd. Vendor Management: An Enterprise-wide Focus Susan Orr, CISA CISM CRISC CRP Susan Orr Consulting, Ltd. Why Focus on Vendor Management Increased financial regulatory scrutiny GLBA and Identity Theft Red

More information

Information Security Policy. Document ID: 3809 Version: 1.0 Owner: Chief Security Officer, Security Services

Information Security Policy. Document ID: 3809 Version: 1.0 Owner: Chief Security Officer, Security Services Information Security Policy Document ID: 3809 Version: 1.0 Owner: Chief Security Officer, Security Services Contents 1 Purpose / Objective... 1 1.1 Information Security... 1 1.2 Purpose... 1 1.3 Objectives...

More information

WHITE PAPER Leveraging GRC for PCI DSS Compliance. By: Chris Goodwin, Co-founder and CTO, LockPath

WHITE PAPER Leveraging GRC for PCI DSS Compliance. By: Chris Goodwin, Co-founder and CTO, LockPath WHITE PAPER Leveraging GRC for PCI DSS Compliance By: Chris Goodwin, Co-founder and CTO, LockPath The Payment Card Industry Data Security Standard ( PCI DSS ) is set forth by a consortium of payment card

More information

SECURITY RISK MANAGEMENT

SECURITY RISK MANAGEMENT SECURITY RISK MANAGEMENT ISACA Atlanta Chapter, Geek Week August 20, 2013 Scott Ritchie, Manager, HA&W Information Assurance Services Scott Ritchie CISSP, CISA, PCI QSA, ISO 27001 Auditor Manager, HA&W

More information

IT Risk Management Life Cycle and enabling it with GRC Technology. 21 March 2013

IT Risk Management Life Cycle and enabling it with GRC Technology. 21 March 2013 IT Risk Management Life Cycle and enabling it with GRC Technology 21 March 2013 Overview IT Risk management lifecycle What does technology enablement mean? Industry perspective Business drivers Trends

More information

Sound Practices for the Management of Operational Risk

Sound Practices for the Management of Operational Risk 1 Sound Practices for the Management of Operational Risk Authority 1.1 Section 316 (4) of the International Business Corporations Act (IBC Act) requires the Commission to take any necessary action required

More information

Office of the Auditor General Performance Audit Report. Statewide UNIX Security Controls Department of Technology, Management, and Budget

Office of the Auditor General Performance Audit Report. Statewide UNIX Security Controls Department of Technology, Management, and Budget Office of the Auditor General Performance Audit Report Statewide UNIX Security Controls Department of Technology, Management, and Budget December 2015 State of Michigan Auditor General Doug A. Ringler,

More information

Third Party Relationships

Third Party Relationships 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 A B D INTRODUCTION AND PURPOSE Background Yes/No Comments 1. Does the credit union maintain a list of the third party

More information

Do you know your privacy risks? How new technologies, changing business models, and emerging regulations are changing the data-protection landscape

Do you know your privacy risks? How new technologies, changing business models, and emerging regulations are changing the data-protection landscape January 2013 Do you know your privacy risks? How new technologies, changing business models, and emerging regulations are changing the data-protection landscape At a glance Threats to data security both

More information

Cloud Computing: Legal Risks and Best Practices

Cloud Computing: Legal Risks and Best Practices Cloud Computing: Legal Risks and Best Practices A Bennett Jones Presentation Toronto, Ontario Lisa Abe-Oldenburg, Partner Bennett Jones LLP November 7, 2012 Introduction Security and Data Privacy Recent

More information

Moving Forward with IT Governance and COBIT

Moving Forward with IT Governance and COBIT Moving Forward with IT Governance and COBIT Los Angeles ISACA COBIT User Group Tuesday 27, March 2007 IT GRC Questions from the CIO Today s discussion focuses on the typical challenges facing the CIO around

More information

www.pwc.com Governance, Risk and Compliance Update & Hot Topics Pittsburgh Chapter IIA December 3, 2012

www.pwc.com Governance, Risk and Compliance Update & Hot Topics Pittsburgh Chapter IIA December 3, 2012 www.pwc.com Governance, Risk and Compliance Update & Hot Topics Pittsburgh Chapter IIA December 3, 2012 Agenda Introduction Mark Gibbons 12:00 12:05 Governance, Risk and Compliance Overview Mark Gibbons

More information

Services Providers. Ivan Soto

Services Providers. Ivan Soto SOP s for Managing Application Services Providers Ivan Soto Learning Objectives At the end of this session we will have covered: Types of Managed Services Outsourcing process Quality expectations for Managed

More information

The CIPM certification is comprised of two domains: Privacy Program Governance (I) and Privacy Program Operational Life Cycle (II).

The CIPM certification is comprised of two domains: Privacy Program Governance (I) and Privacy Program Operational Life Cycle (II). Page 1 of 7 The CIPM certification is comprised of two domains: Privacy Program Governance (I) and Privacy Program Operational Life Cycle (II). Domain I provides a solid foundation for the governance of

More information

Cloud Security Trust Cisco to Protect Your Data

Cloud Security Trust Cisco to Protect Your Data Trust Cisco to Protect Your Data As cloud adoption accelerates, organizations are increasingly placing their trust in third-party cloud service providers (CSPs). But can you fully trust your most sensitive

More information

CORL Dodging Breaches from Dodgy Vendors

CORL Dodging Breaches from Dodgy Vendors CORL Dodging Breaches from Dodgy Vendors Tackling Vendor Security Risk Management in Healthcare Introductions Cliff Baker 20 Years of Healthcare Security experience PricewaterhouseCoopers, HITRUST, Meditology

More information

SOC on Amazon Web Services (AWS) What You Need To Know Understanding the regulatory roadmap for SOC on AWS

SOC on Amazon Web Services (AWS) What You Need To Know Understanding the regulatory roadmap for SOC on AWS SOC on Amazon Web Services (AWS) What You Need To Know Understanding the regulatory roadmap for SOC on AWS Jeff Cook November 2015 Summary Service Organization Control (SOC) reports (formerly SAS 70 or

More information

Best Practices for Protecting Sensitive Data in an Oracle Applications Environment. Presented by: Jeffrey T. Hare, CPA CISA CIA

Best Practices for Protecting Sensitive Data in an Oracle Applications Environment. Presented by: Jeffrey T. Hare, CPA CISA CIA Best Practices for Protecting Sensitive Data in an Oracle Applications Environment Presented by: Jeffrey T. Hare, CPA CISA CIA Webinar Logistics Hide and unhide the Webinar control panel by clicking on

More information

Written Information Security Programs: Compliance with the Massachusetts Data Security Regulation

Written Information Security Programs: Compliance with the Massachusetts Data Security Regulation View the online version at http://us.practicallaw.com/7-523-1520 Written Information Security Programs: Compliance with the Massachusetts Data Security Regulation MELISSA J. KRASNOW, DORSEY & WHITNEY LLP

More information

GUIDANCE NOTE ON OUTSOURCING

GUIDANCE NOTE ON OUTSOURCING GN 14 GUIDANCE NOTE ON OUTSOURCING Office of the Commissioner of Insurance Contents Page I. Introduction.. 1 II. Application...... 1 III. Interpretation.... 2 IV. Legal and Regulatory Obligations... 3

More information

IDENTIFYING VENDOR RISK THE CRITICAL FIRST STEP IN CREATING AN EFFECTIVE VENDOR RISK MANAGEMENT PROGRAM

IDENTIFYING VENDOR RISK THE CRITICAL FIRST STEP IN CREATING AN EFFECTIVE VENDOR RISK MANAGEMENT PROGRAM IDENTIFYING VENDOR RISK THE CRITICAL FIRST STEP IN CREATING AN EFFECTIVE VENDOR RISK MANAGEMENT PROGRAM HEADQUARTERS 33 Bradford Street Concord, MA 01742 PHONE: 978-451-7655 THE CRITICAL FIRST STEP IN

More information

The Value of Vulnerability Management*

The Value of Vulnerability Management* The Value of Vulnerability Management* *ISACA/IIA Dallas Presented by: Robert Buchheit, Director Advisory Practice, Dallas Ricky Allen, Manager Advisory Practice, Houston *connectedthinking PwC Agenda

More information

WHITE PAPER Third-Party Risk Management Lifecycle Guide

WHITE PAPER Third-Party Risk Management Lifecycle Guide WHITE PAPER Third-Party Risk Management Lifecycle Guide Develop and maintain compliant third-party relationships by following these foundational components of a best-practice assessment program. Third

More information

Mitigating and managing cyber risk: ten issues to consider

Mitigating and managing cyber risk: ten issues to consider Mitigating and managing cyber risk: ten issues to consider The board of directors is responsible for managing and mitigating risk exposure. A recent study conducted by the Ponemon Institute 1 revealed

More information

The Seven Elements of a Vendor Oversight Program

The Seven Elements of a Vendor Oversight Program The Seven Elements of a Oversight Program DST Health Solutions September 2014 The Seven Elements of a Oversight Program The Seven Elements of a Oversight Program Medicare Advantage plans must gain efficiencies

More information

The silver lining: Getting value and mitigating risk in cloud computing

The silver lining: Getting value and mitigating risk in cloud computing The silver lining: Getting value and mitigating risk in cloud computing Frequently asked questions The cloud is here to stay. And given its decreased costs and increased business agility, organizations

More information

08/10/2013. Data protection and compliance. Agenda. Data protection life cycle and goals. Introduction. Data protection overview

08/10/2013. Data protection and compliance. Agenda. Data protection life cycle and goals. Introduction. Data protection overview Data protection and compliance In the cloud and in your data center 1 November 2013 Agenda 1 Introduction 2 Data protection overview 3 Understanding the cloud 4 Where do I start? 5 Wrap-up Page 2 Data

More information

Understanding the Entity and Its Environment and Assessing the Risks of Material Misstatement

Understanding the Entity and Its Environment and Assessing the Risks of Material Misstatement Understanding the Entity and Its Environment 267 AU-C Section 315 Understanding the Entity and Its Environment and Assessing the Risks of Material Misstatement Source: SAS No. 122; SAS No. 128. Effective

More information

IIA Conference. September 18, 2015. Paige Needling Director, Global Information Security Recall, Inc.

IIA Conference. September 18, 2015. Paige Needling Director, Global Information Security Recall, Inc. IIA Conference September 18, 2015 Paige Needling Director, Global Information Security Recall, Inc. IT SECURITY UMBRELLA Compliance for IT Data Privacy Protection Privacy Risk Assessment Vulnerability

More information

Vendor Management Challenge Doing More with Less

Vendor Management Challenge Doing More with Less Vendor Management Challenge Doing More with Less Megan Hertzler Assistant General Counsel Director of Data Privacy Xcel Energy Boris Segalis Partner InfoLawGroup LLP Session ID: GRC-402 Insert presenter

More information

Morgan Stanley. Policy for the Management of Third Party Residential Mortgage Servicing Providers

Morgan Stanley. Policy for the Management of Third Party Residential Mortgage Servicing Providers Morgan Stanley Policy for the Management of Third Party Residential Mortgage Servicing Providers Title Policy for the Management of Third Party Residential Mortgage Servicing Providers Effective Date Owner

More information

Information Technology

Information Technology Information Technology Information Technology Session Structure Board of director actions Significant and emerging IT risks Practical questions Resources Compensating Controls at the Directorate Level

More information

GUIDANCE NOTE FOR DEPOSIT-TAKERS. Operational Risk Management. March 2012

GUIDANCE NOTE FOR DEPOSIT-TAKERS. Operational Risk Management. March 2012 GUIDANCE NOTE FOR DEPOSIT-TAKERS Operational Risk Management March 2012 Version 1.0 Contents Page No 1 Introduction 2 2 Overview 3 Operational risk - fundamental principles and governance 3 Fundamental

More information