Vendor Management. Outsourcing Technology Services
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1 Vendor Management Outsourcing Technology Services
2 Objectives Board and Senior Management Responsibilities Risk Management Program Risk Assessment Service Provider Selection Contracts Ongoing Monitoring Business Continuity Planning and Testing Other Available Resources
3 Board and Senior Management Responsibilities The Board can outsource a service, but cannot outsource the responsibility. Identify Develop and implement riskbased policies and procedures to govern the outsourcing process Report RISK Measure Monitor Mitigate
4 Board and Senior Management Responsibilities Board Responsibilities Develop and approve policies that establish an effective vendor management program framework Select a service provider that best meets the needs of the bank Negotiate a contract that protects the interests of the bank Oversee management s implementation of the program through regular board reporting
5 Board and Senior Management Responsibilities Board Reports Audits Business Continuity Plans and Testing Service Level Agreements Information Security Financial Statements Higher-risk Service Providers Regulatory IT Examination Reports
6 Board and Senior Management Responsibilities Management Responsibilities Evaluate prospective providers based on the type of services outsourced and how critical the function is to the bank Ensure each outsourced relationship supports business requirements and strategic plans, and is appropriate for the size and complexity of the bank Confirm the bank has sufficient expertise to oversee and manage the relationship Implement ongoing monitoring programs that prioritize activities based on the degree of risk and criticality of the services
7 Risk Management Overview Inform senior management and the board of the risks associated with outsourcing Ensure that outsourcing arrangements are prudent and consistent with business objectives Implement effective controls to address identified risks Perform ongoing risk monitoring to identify and evaluate changes in risk from the initial assessment Document procedures, roles, responsibilities, and reporting mechanisms
8 Risk Management Overview Monitoring Risk Assessment Vendor Management Contracts Selection
9 Risk Management Overview Monitoring Risk Assessment Vendor Management Contracts Selection
10 Risk Management Overview Monitoring Risk Assessment Vendor Management Contracts Selection
11 Risk Management Overview Monitoring Risk Assessment Vendor Management Contracts Selection
12 Risk Management Overview Monitoring Risk Assessment Vendor Management Contracts Selection
13 Risk Management Overview Monitoring Risk Assessment Vendor Management Contracts Selection
14 Risk Assessment Risks Strategic Compliance Reputational Interest Rate Liquidity Cyber Planning, implementation, scalability Legal and regulatory requirements Errors, delays, omissions, fraud, breaches Errors, inaccurate assumptions Service disruptions, settlement delays Disruption, malware
15 Risk Assessment Outsourced Function Criticality Data sensitivity Transaction volume Quantifying Risks Service Provider Financial strength Industry experience Location Technology Reliability Security Scalability
16 Vendor Selection Monitoring Risk Assessment Vendor Management Contracts Selection
17 Vendor Selection Corporate history, qualifications, references Financial condition Due Diligence: Key Considerations Service delivery capability Technology and system architecture Internal control environment, security history, audit coverage Reliance on and success in managing subcontractors Legal and regulatory compliance Insurance coverage Site visits Disaster recovery/business continuity
18 Contracts Monitoring Risk Assessment Vendor Management Contracts Selection
19 Contracts Scope of Service Rights and Responsibilities Description of Activities Timeframes for Implementation Assignment of Responsibilities Common Provisions Security and Confidentiality Responsibility and Controls Incident Response and Notification Requirements Appendix B to Part 364 (GLBA)
20 Contracts Internal Controls Records Maintenance System Monitoring Notification Requirements Cybersecurity Common Provisions Audit Types of Audits Financial General Controls Network Security Assessments Electronic Funds Transfer Disaster Recovery Tests Frequency Right to Receive Right to Audit
21 Contracts Reports Frequency and Types Performance Financials Compliance with regulatory guidance Common Provisions Business Resumption/ Contingency Plans Backup and Records Protections Equipment Programs and Data Files Maintenance and Testing Frequency Availability of Test Results Bank Participation
22 Contracts Sub-contracting Awareness Assessment Responsibility Common Provisions Performance Standards Regulatory Compliance Measurable Minimum Service Level Requirements Remedies Service Level Agreements (SLAs) Adherence to Regulatory Guidance Risk Management Consumer Compliance
23 Contracts Bank Service Company Act Notification Banks should notify their primary Federal regulator of the outsourcing relationship within: 30 days of entering into the contract, or performance of the services..whichever occurs first
24 Contracts SLAs Confidentiality of Data GLBA compliance, notifications, responsiveness Integrity and Availability Error rates, up time, processing timeliness System Changes Security Standards Business Continuity Help Desk Support Programming changes, system updates Compliance, independent testing Backup, retention, protection, restoration, recovery Responsiveness, availability, qualifications
25 Monitoring Monitoring Risk Assessment Vendor Management Contracts Selection
26 Monitoring Periodically reevaluate active service providers Tailor ongoing monitoring using a risk-based approach considering: Criticality of the services Sensitivity of data Degree of perceived risk Implement more frequent and stringent ongoing monitoring for higher-risk service providers Report results to the board
27 Monitoring Audit reports Performed by qualified and independent personnel Type, scope, and frequency consistent with: o o o Size and complexity Products and services Level of risk Review corrective actions
28 Monitoring Financial Condition Continuity of operations Support for the contracted services Investment in security controls Product updates
29 Monitoring Compliance with Service Level Agreements Performance standards Information security standards (GLBA) Incident response programs Business Continuity Plans
30 Monitoring Available only to client banks under contract Request from FDIC Regional Office Case Manager National and State-member banks may request from the bank s primary Federal regulator
31 Business Continuity Planning Monitoring Contracts Vendor Management Risk Assessment Selection Business Continuity Planning
32 Business Continuity Planning Review service provider plans Mission critical service restoration o Timeframes and recovery time objectives o Staffing, capacity, telecommunications, hardware, software, and facilities availability o Wide-scale disruptions Contingency plan testing and testing scenarios o Connectivity, functionality, volume, and capacity of alternate facilities o Annual or more frequent Interdependencies o Internal and external dependencies o Test where feasible
33 Outsourcing to Foreign Service Providers Arrangements should be subject to the same due diligence and assessment processes as domestic outsourcing relationships Identify Risks become unique Report RISK Measure Monitor Mitigate
34 Summary: Review Monitoring Risk Assessment Vendor Management Contracts Selection
35 Summary: Review Monitoring Risk Assessment Vendor Management Contracts Selection
36 Summary: Review Monitoring Risk Assessment Vendor Management Contracts Selection
37 Summary: Review Monitoring Risk Assessment Vendor Management Contracts Selection
38 Resources FFIEC IT Examination Handbook (
39 Resources FDIC Financial Institution Letters (FILs) FIL : Informational Tools for Community Bankers FIL : Guidance for Managing Third-Party Risk FIL : Guidance on Foreign-Based Third-Party Service Providers FIL : Computer Software Due Diligence FIL : Country Risk FIL : Risk Management of Technology Outsourcing FIL-49-99: Bank Service Company Act Website:
40 Resources Directors Resource Center Technical Assistance Video Program Information Technology (IT) Corporate Governance Third-Party Risk Cybersecurity Awareness Cyber Challenge: A Community Bank Cyber Exercise Questions [email protected]
VENDOR RISK MANAGEMENT UPDATE- ARE YOU AT RISK? Larry L. Llirán, CISA, CISM December 10, 2015 ISACA Puerto Rico Symposium
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9/13/2013. 20/20 Vision for Vendor Management & Oversight. Disclaimer. Bank Service Company Act - FIL-49-99
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