The Third Party Security Policy outlines [Organization Name]'s commitment to managing supply chain risks associated with third-party vendors and suppliers engaged by the organization. This policy aligns with the guidelines provided in NIST Special Publication 800-161, "Supply Chain Risk Management Practices for Federal Information Systems and Organizations," and aims to ensure that vendors with access to [Organization Name]'s information systems, data, or services adhere to stringent security practices, safeguarding the organization against potential cybersecurity threats.
1.1. Importance of Vendor Security
[Organization Name] recognizes the critical role that vendors play in supporting business operations and services. However, third-party engagements also introduce potential cybersecurity risks. The increasing complexity and interconnectedness of supply chains pose challenges in identifying and mitigating these risks. By implementing robust vendor security practices based on NIST 800-161, the organization seeks to mitigate supply chain risks and protect its information systems, sensitive data, and reputation.
1.2. Scope
This policy applies to all third-party vendors, suppliers, contractors, and service providers engaged by [Organization Name] to perform services, process data, or access information systems on behalf of the organization. It encompasses vendors providing hardware, software, cloud services, managed services, or any other critical services to [Organization Name].
1.3. Policy Alignment with NIST 800-161
[Organization Name] acknowledges the relevance and importance of NIST Special Publication 800-161 as a comprehensive guide for managing supply chain risks. This policy integrates the principles, controls, and best practices outlined in NIST 800-161 into [Organization Name]'s vendor security framework.
2. Vendor Risk Management
2.1. Vendor Risk Assessment
Prior to engaging any vendor, [Organization Name] shall conduct a comprehensive risk assessment to evaluate the vendor's supply chain risk. The assessment shall consider factors such as the nature of services provided, level of access to sensitive information, geographic locations, and the vendor's security posture. The risk assessment process shall align with the principles outlined in NIST 800-161.
2.2. Risk Categorization
Based on the vendor risk assessment, vendors shall be categorized into risk tiers (e.g., high-risk, medium-risk, and low-risk). The risk categorization will dictate the level of due diligence required during the vendor engagement process and the frequency of ongoing assessments.
2.3. Due Diligence in Vendor Selection
When selecting vendors, [Organization Name] shall prioritize security and supply chain risk considerations. Vendor selection decisions shall include an evaluation of the vendor's security capabilities, adherence to industry standards, previous security incidents, and compliance with relevant regulations.
2.4. Ongoing Risk Monitoring
Throughout the vendor engagement, [Organization Name] shall continually monitor and reassess the risks associated with each vendor. Changes in the vendor's services, security practices, or business operations shall be factored into the ongoing risk management process.
3. Security Requirements for Vendors
3.1. Security Controls and Requirements
[Organization Name] shall define minimum security requirements for vendors based on the risk categorization and NIST 800-161 controls. These requirements shall include, but not be limited to, access controls, encryption, incident response preparedness, personnel security, and vulnerability management. Vendors shall be required to meet these security controls as part of the engagement process.
3.2. Contractual Obligations
All vendor contracts and service-level agreements (SLAs) shall include specific security clauses that outline the security requirements and responsibilities of the vendor. These clauses shall align with the security controls identified in NIST 800-161 and any additional security measures relevant to the vendor's role. The contract shall explicitly state the consequences of non-compliance with security requirements.
3.3. Incident Reporting
Vendors shall promptly report any security incidents or data breaches related to [Organization Name]'s information or systems. Incident reporting procedures shall be defined in the contractual agreement, and vendors shall cooperate fully with [Organization Name]'s incident response team during any security incident investigation.
4. Ongoing Vendor Monitoring
4.1. Continuous Monitoring
[Organization Name] shall continuously monitor vendor compliance with security requirements throughout the vendor engagement period. This monitoring may include periodic security assessments, performance reviews, and incident response exercises. Vendor performance metrics shall include security-related KPIs and metrics to track adherence to security controls.
4.2. Performance Evaluation
Vendor performance evaluations shall include an assessment of their adherence to security requirements, their responsiveness to security incidents, and their overall contribution to supply chain risk management. The evaluation process shall consider any improvements made by the vendor based on the organization's recommendations.
4.3. Right to Audit
[Organization Name] reserves the right to conduct periodic security audits of vendors to verify compliance with security requirements. Vendors shall cooperate fully with audit requests and provide relevant documentation and evidence of their security practices.
5. Vendor Security Awareness
5.1. Vendor Training and Awareness
[Organization Name] shall encourage vendors to promote a culture of security awareness among their employees who have access to [Organization Name]'s information or systems. Vendors shall be encouraged to provide security training and awareness programs to their personnel to enhance their understanding of security risks and best practices.
6. Policy Review and Updates
This Vendor Security Policy will be reviewed and updated periodically to reflect changes in technology, regulations, or organizational needs. As the supply chain risk landscape evolves, [Organization Name] will continuously assess the policy's effectiveness and make adjustments to enhance vendor security practices. Feedback from stakeholders, insights from vendor assessments, and emerging threats will be considered during policy updates.
7. Policy Communication and Training
[Organization Name] shall communicate the Vendor Security Policy to all relevant stakeholders, including employees involved in vendor management, procurement, and legal teams. Employees shall receive training on the policy's requirements and their role in implementing and enforcing vendor security measures.