You are assessing your organization's Disaster Recovery and Business Continuity (BR/BCP) requirements based on the shift to remote work. Which statement is LEAST reflective of current practices in business resiliency?
Third party service providers should be included in the company’s exercise and testing program based on the criticality of the outsourced business function
The right to require participation in testing with third party service providers should be included in the contract
The contract is the only enforceable control to stipulate third party service provider obligations for DR/BCP since both programs were triggered by the pandemic
Management should request and receive artifacts that Gemonstrate successful test results and any remediation action plans
The contract is not the only enforceable control to stipulate third party service provider obligations for DR/BCP, nor are both programs necessarily triggered by the pandemic. According to the Shared Assessments Program, third party risk management (TPRM) is a continuous process that requires ongoing monitoring and assessment of third parties’ performance, compliance, and resilience. Therefore, the contract should be complemented by other controls, such as due diligence, audits, reviews, and reporting, to ensure that third parties meet the organization’s expectations and standards for DR/BCP. Moreover, DR/BCP are not only relevant for pandemic scenarios, but also for other types of disasters, such as natural disasters, cyberattacks, power outages, or human errors. Therefore, the contract should reflect the organization’s risk appetite and tolerance for different types of disruptions and scenarios, and not be limited to pandemic-related events.
Which statement is FALSE regarding the foundational requirements of a well-defined third party risk management program?
We conduct onsite or virtual assessments for all third parties
We have defined senior and executive management accountabilities for oversight of our TPRM program
We have established vendor risk ratings and classifications based on a tiered hierarchy
We have established Management and Board-level reporting to enable risk-based decisionmaking
A well-defined third party risk management program does not require conducting onsite or virtual assessments for all third parties, as this would be impractical, costly, and inefficient. Instead, a TPRM program should adopt a risk-based approach to determine the frequency, scope, and depth of assessments based on the inherent and residual risks posed by each third party. This means that some third parties may require more frequent and comprehensive assessments than others, depending on factors such as the nature, scope, and criticality of their services, the sensitivity and volume of data they access or process, the regulatory and contractual obligations they must comply with, and the results of previous assessments and monitoring activities. A risk-based approach to assessments allows an organization to allocate its resources and efforts more effectively and efficiently, while also ensuring that the most significant risks are adequately addressed and mitigated. References:
When working with third parties, which of the following requirements does not reflect a “Zero Trust" approach to access management?
Utilizing a solution that allows direct access by third parties to the organization's network
Ensure that access is granted on a per session basis regardless of network location, user, or device
Implement device monitoring, continual inspection and monitoring of logs/traffic
Require that all communication is secured regardless of network location
A Zero Trust approach to access management is based on the principle of verifying every access request as if it originates from an open network, regardless of the source, destination, or context. This means that no implicit trust is granted based on network location, user identity, or device status. Instead, every access request is evaluated based on multiple factors, such as user credentials, device health, data sensitivity, and threat intelligence. A Zero Trust approach also requires that all communication is encrypted and protected, and that access is granted on a per session basis with the least privilege principle123.
Utilizing a solution that allows direct access by third parties to the organization’s network does not reflect a Zero Trust approach, because it implies that the network perimeter is a reliable boundary for security and trust. This assumption is risky, because it exposes the organization to potential breaches and attacks from compromised or malicious third parties, who may have access to sensitive data and resources without proper verification or protection. A Zero Trust approach would require that third parties use secure and isolated channels to access the organization’s network, such as VPNs, proxies, or gateways, and that their access is monitored and controlled based on granular policies and conditions123. References:
Which of the following statements is TRUE regarding the accountabilities in a three lines of defense model?
The second line of defense is management within the business unit
The first line of defense is the risk or compliance team that provides an oversight or governance function
The third line of defense is an assurance function that has independence from the business unit
The third line of defense must be limited to an external assessment firm
The three lines of defense model is a way of explaining the relationship between functions and roles of risk management and control in an organization. It involves the first line of defense (owning and managing risks), the second line of defense (overseeing or specialising in risk), and the third line of defense (providing independent assurance)1. The third line of defense is typically the internal audit function, which provides objective and independent assurance to the governing body, management, regulators, and external auditors that the control culture across the organization is effective in its design and operation2. The third line of defense must have independence from the business unit, meaning that it is not involved in the execution of business activities or the design and implementation of controls, and that it reports to the highest level of governance, such as the board or the audit committee3. The third line of defense is not limited to an external assessment firm, although external assurance providers may complement or supplement the work of the internal audit function2. References:
Which type of contract termination is MOST likely to occur after failure to remediate assessment findings?
Regulatory/supervisory termination
Termination for convenience
Normal termination
Termination for cause
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:
An IT change management approval process includes all of the following components EXCEPT:
Application version control standards for software release updates
Documented audit trail for all emergency changes
Defined roles between business and IT functions
Guidelines that restrict approval of changes to only authorized personnel
Application version control standards for software release updates are not part of the IT change management approval process, but rather a technical aspect of the software development lifecycle. The IT change management approval process is a formal and structured way of evaluating, authorizing and scheduling changes to IT systems and infrastructure, based on predefined criteria and roles. The IT change management approval process typically includes the following components123:
If a system requires ALL of the following for accessing its data: (1) a password, (2) a
security token, and (3) a user's fingerprint, the system employs:
Biometric authentication
Challenge/Response authentication
One-Time Password (OTP) authentication
Multi-factor authentication
Multi-factor authentication (MFA) is an electronic authentication method that requires a user to present two or more pieces of evidence (or factors) to an authentication mechanism. The factors can be something the user knows (such as a password or a PIN), something the user has (such as a smartphone or a security token), or something the user is (such as a fingerprint or a facial recognition). MFA enhances the security of online accounts and applications by making it harder for attackers to gain access with stolen or guessed credentials. MFA is recommended as a best practice for third-party risk management, as it can reduce the risk of unauthorized access, data breaches, and identity theft. MFA is also a requirement for some regulatory standards and frameworks, such as PCI DSS, HIPAA, and NIST 800-63. References:
Select the risk type that is defined as: “A third party may not be able to meet its obligations due to inadequate systems or processes”.
Reliability risk
Performance risk
Competency risk
Availability risk
Performance risk, defined as the risk that a third party may not be able to meet its obligations due to inadequate systems or processes, accurately describes the situation. This type of risk involves concerns about the third party's ability to deliver services or products at the required performance level, potentially due to limitations in their technology infrastructure, operational procedures, or management practices. Identifying and managing performance risk is essential in Third-Party Risk Management (TPRM) to ensure that third-party vendors can reliably meet contractual and service-level agreements, thereby minimizing the impact on the organization's operations and service delivery.
References:
For services with system-to-system access, which change management requirement
MOST effectively reduces the risk of business disruption to the outsourcer?
Approval of the change by the information security department
Documenting sufficient time for quality assurance testing
Communicating the change to customers prior ta deployment to enable external acceptance testing
Documenting and legging change approvals
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:
Which statement is NOT an example of the purpose of internal communications and information sharing using TPRM performance metrics?
To communicate the status of findings identified in vendor assessments and escalate issues es needed
To communicate the status of policy compliance with TPRM onboarding, periodic assessment and off-boarding requirements
To document the agreed upon corrective action plan between external parties based on the severity of findings
To develop and provide periodic reporting to management based on TPRM results
The purpose of internal communications and information sharing using TPRM performance metrics is to inform and align the organization’s stakeholders on the status, progress, and outcomes of the TPRM program. This includes communicating the results of vendor assessments, the compliance level of the organization’s policies and procedures, and the periodic reporting to management and other relevant parties. However, documenting the corrective action plan between external parties is not an internal communication, but rather an external one. This is because the corrective action plan is a formal agreement between the organization and the vendor to address and resolve the issues identified in the assessment. Therefore, this statement is not an example of the purpose of internal communications and information sharing using TPRM performance metrics. References:
When conducting an assessment of a third party's physical security controls, which of the following represents the innermost layer in a ‘Defense in Depth’ model?
Public internal
Restricted entry
Private internal
Public external
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:
When defining third party requirements for transmitting Pll, which factors provide stranger controls?
Full disk encryption and backup
Available bandwidth and redundancy
Strength of encryption cipher and authentication method
Logging and monitoring
Personally identifiable information (PII) is any data that can be used to identify, contact, or locate an individual, such as name, address, email, phone number, social security number, etc. PII is subject to various legal and regulatory requirements, such as the GDPR, HIPAA, PCI DSS, and others, depending on the industry and jurisdiction. PII also poses significant security and privacy risks, as it can be exploited by malicious actors for identity theft, fraud, phishing, or other cyberattacks. Therefore, organizations that collect, store, process, or transmit PII must implement appropriate safeguards to protect it from unauthorized access, disclosure, modification, or loss.
One of the key safeguards for PII protection is encryption, which is the process of transforming data into an unreadable format using a secret key. Encryption ensures that only authorized parties who have the key can access the original data. Encryption can be applied to data at rest (stored on a device or a server) or data in transit (moving across a network or the internet). Encryption can also be symmetric (using the same key for encryption and decryption) or asymmetric (using a public key for encryption and a private key for decryption).
Another key safeguard for PII protection is authentication, which is the process of verifying the identity of a user or a system that requests access to data. Authentication ensures that only legitimate and authorized parties can access the data. Authentication can be based on something the user knows (such as a password or a PIN), something the user has (such as a token or a smart card), something the user is (such as a fingerprint or a face scan), or a combination of these factors. Authentication can also be enhanced by using additional methods, such as one-time passwords, challenge-response questions, or multi-factor authentication.
When defining third party requirements for transmitting PII, the factors that provide stronger controls are the strength of encryption cipher and authentication method. These factors determine how secure and reliable the data transmission is, and how resistant it is to potential attacks or breaches. The strength of encryption cipher refers to the algorithm and the key size used to encrypt the data. The stronger the cipher, the more difficult it is to break or crack the encryption. The strength of authentication method refers to the type and the number of factors used to verify the identity of the user or the system. The stronger the authentication method, the more difficult it is to impersonate or compromise the user or the system.
The other factors, such as full disk encryption and backup, available bandwidth and redundancy, and logging and monitoring, are also important for PII protection, but they do not directly affect the data transmission process. Full disk encryption and backup are relevant for data at rest, not data in transit. They provide protection in case of device theft, loss, or damage, but they do not prevent data interception or modification during transmission. Available bandwidth and redundancy are relevant for data availability and performance, not data security and privacy. They ensure that the data transmission is fast and reliable, but they do not prevent data exposure or corruption during transmission. Logging and monitoring are relevant for data audit and compliance, not data encryption and authentication. They provide visibility and accountability for the data transmission activities, but they do not prevent data access or misuse during transmission. References:
When evaluating compliance artifacts for change management, a robust process should include the following attributes:
Approval, validation, auditable.
Logging, approvals, validation, back-out and exception procedures
Logging, approval, back-out.
Communications, approval, auditable.
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:
References:
Which factor is less important when reviewing application risk for application service providers?
Remote connectivity
The number of software releases
The functionality and type of data the application processes
APl integration
When reviewing application risk for application service providers, the most important factors are the functionality and type of data the application processes, the remote connectivity options, and the APl integration methods. These factors determine the level of exposure, sensitivity, and complexity of the application, and thus the potential impact and likelihood of a security breach or a compliance violation. The number of software releases is less important, as it does not directly affect the application’s security or functionality. However, it may indicate the maturity and quality of the software development process, which is another aspect of application risk assessment. References:
Which of the following data types would be classified as low risk data?
Sanitized customer data used for aggregated profiling
Non personally identifiable, but sensitive to an organizations significant process
Government-issued number, credit card number or bank account information
Personally identifiable data but stored in a test environment cloud container
Data classification is the process of categorizing data according to its type, sensitivity, and value to the organization if altered, stolen, or destroyed1. Data classification helps an organization understand the risk level of its data and implement appropriate controls to protect it. Data can be classified into three risk levels: low, moderate, and high23. Low risk data are data that are intended for public disclosure or have no adverse impact on the organization’s mission, safety, finances, or reputation if compromised23. Sanitized customer data used for aggregated profiling are an example of low risk data, as they do not contain any personally identifiable or sensitive information that could be exploited for criminal or other wrongful purposes. Sanitized data are data that have been modified to remove or obscure any confidential or identifying information, such as names, addresses, phone numbers, etc. Aggregated data are data that have been combined or summarized from multiple sources to provide statistical or analytical insights, such as trends, patterns, averages, etc. Sanitized and aggregated data are often used for research, marketing, or business intelligence purposes, and do not pose a significant threat to the organization or the customers if exposed. References:
Which statement is FALSE regarding analyzing results from a vendor risk assessment?
The frequency for conducting a vendor reassessment is defined by regulatory obligations
Findings from a vendor risk assessment may be defined at the entity level, and are based o na Specific topic or control
Identifying findings from a vendor risk assessment can occur at any stage in the contract lifecycle
Risk assessment findings identified by controls testing or validation should map back to the information gathering questionnaire and agreed upon framework
The frequency for conducting a vendor reassessment is not necessarily defined by regulatory obligations, but rather by the risk rating and criticality of the vendor, as well as the changes in the vendor’s environment, performance, and controls. Regulatory obligations may provide some guidance or minimum requirements for vendor reassessment, but they are not the sole determinant of the reassessment frequency. According to the Shared Assessments Program Tools User Guide, "The frequency of reassessment should be based on the risk rating and criticality of the vendor, as well as any changes in the vendor’s environment, performance, or controls. Regulatory guidance may also influence the frequency of reassessment."1 Similarly, the CTPRP Study Guide states, "The frequency of reassessment should be based on the risk rating and criticality of the vendor, as well as any changes in the vendor’s environment, performance, or controls. Regulatory guidance may also influence the frequency of reassessment."2
References:
Which of the following BEST reflects components of an environmental controls testing program?
Scheduling testing of building access and intrusion systems
Remote monitoring of HVAC, Smoke, Fire, Water or Power
Auditing the CCTV backup process and card-key access process
Conducting periodic reviews of personnel access controls and building intrusion systems
Remote monitoring of HVAC, Smoke, Fire, Water, or Power systems best reflects components of an environmental controls testing program. These systems are critical to ensuring the physical security and operational integrity of data centers and IT facilities. Environmental controls testing programs are designed to verify that these systems are functioning correctly and can effectively respond to environmental threats. This includes monitoring temperature and humidity (HVAC), detecting smoke or fire, preventing water damage, and ensuring uninterrupted power supply. Regular testing and monitoring of these systems help prevent equipment damage, data loss, and downtime due to environmental factors.
References:
Which statement is FALSE regarding background check requirements for vendors or service providers?
Background check requirements are not applicable for vendors or service providers based outside the United States
Background checks should be performed prior to employment and may be updated after employment based upon criteria in HR policies
Background check requirements should be applied to employees, contract workers and temporary workers
Background check requirements may differ based on level of authority, risk, or job role
Background check requirements are applicable for vendors or service providers based outside the United States, as well as those based within the country. According to the Shared Assessments Program, background checks are a key component of third-party risk management and should be conducted for all third parties that have access to sensitive data, systems, or facilities, regardless of their location1. The FCRA also applies to background checks performed by U.S. employers on foreign nationals who work outside the U.S. for a U.S. employer or its affiliates2. Therefore, statement A is false and the correct answer is A. References:
Information classification of personal information may trigger specific regulatory obligations. Which statement is the BEST response from a privacy perspective:
Personally identifiable financial information includes only consumer report information
Public personal information includes only web or online identifiers
Personally identifiable information and personal data are similar in context, but may have different legal definitions based upon jurisdiction
Personally Identifiable Information and Protected Healthcare Information require the exact same data protection safequards
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:
Which statement BEST represents the primary objective of a third party risk assessment:
To assess the appropriateness of non-disclosure agreements regarding the organization's systems/data
To validate that the vendor/service provider has adequate controls in place based on the organization's risk posture
To determine the scope of the business relationship
To evaluate the risk posture of all vendors/service providers in the vendor inventory
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:
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:
Which statement BEST represents the roles and responsibilities for managing corrective actions upon completion of an onsite or virtual assessment?
All findings and remediation plans should be reviewed with internal audit prior to issuing the assessment report
All findings and remediation plans should be reviewed with the vendor prior to sharing results with the line of business
All findings and need for remediation should be reviewed with the line of business for risk acceptance prior to sharing the remediation plan with the vendor
All findings should be shared with the vendor as quickly as possible so that remediation steps can be taken as quickly as possible
According to the Certified Third Party Risk Professional (CTPRP) Job Guide, one of the key tasks of a third party risk professional is to “manage the corrective action process for identified issues and ensure timely resolution” (p. 10). This task involves the following steps:
Therefore, the statement that best represents the roles and responsibilities for managing corrective actions is C, as it reflects the need to review the findings and need for remediation with the LOB for risk acceptance before sharing the remediation plan with the vendor. This ensures that the LOB is aware of the risks and their impact, and that the vendor is committed to resolving the issues in a timely and satisfactory manner.
References:
Which statement is FALSE regarding the different types of contracts and agreements between outsourcers and service providers?
Contract addendums are not sufficient for addressing third party risk obligations as each requirement must be outlined in the Master Services Agreement (MSA)
Evergreen contracts are automatically renewed for each party after the maturity period, unless terminated under existing contract provisions
Requests for Proposals (RFPs) for outsourced services should include mandatory requirements based on an organization's TPRM program policies, standards and procedures
Statements of Work (SOWs) define operational requirements and obligations for each party
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:
Which example of a response to external environmental factors is LEAST likely to be managed directly within the BCP or IT DR plan?
Protocols for social media channels and PR communication
Response to a natural or man-made disruption
Dependency on key employee or supplier issues
Response to a large scale illness or health outbreak
A BCP or IT DR plan is a set of procedures and actions that an organization takes to ensure the continuity and recovery of its critical business functions and IT systems in the event of a disruption. A BCP or IT DR plan typically covers the following aspects12:
Among the four examples of a response to external environmental factors, protocols for social media channels and PR communication are the least likely to be managed directly within the BCP or IT DR plan. This is because social media and PR communication are not critical business functions or IT systems that need to be restored or maintained during a disruption. They are rather supplementary tools that can be used to inform and engage with the public, customers, partners, and media about the organization’s situation and actions3. Therefore, protocols for social media and PR communication are more likely to be part of a crisis communication plan, which is a separate but related document that outlines the strategies and tactics for communicating with various audiences during a crisis.
The other three examples are more likely to be managed directly within the BCP or IT DR plan, as they directly affect the organization’s ability to perform its critical business functions and IT systems. For instance, a response to a natural or man-made disruption would involve activating the BCP or IT DR plan, assessing the impact and extent of the damage, deploying backup and recovery solutions, and restoring normal operations as soon as possible. A response to a dependency on key employee or supplier issues would involve identifying and managing the single points of failure, implementing contingency plans, and ensuring the availability and redundancy of essential skills and resources. A response to a large scale illness or health outbreak would involve implementing health and safety measures, enabling remote work arrangements, and ensuring the resilience and continuity of the workforce. References:
Which factor in patch management is MOST important when conducting postcybersecurity incident analysis related to systems and applications?
Configuration
Log retention
Approvals
Testing
In patch management, testing is the most crucial factor when conducting post-cybersecurity incident analysis related to systems and applications. Proper testing of patches before deployment ensures that they effectively address vulnerabilities without introducing new issues or incompatibilities that could impact system functionality or security. Testing allows organizations to verify that the patch resolves the identified security issue without adversely affecting the system or application's performance. It also helps in identifying potential conflicts with existing configurations or dependencies. Effective testing strategies include regression testing, performance testing, and security testing to ensure comprehensive validation of the patch's effectiveness and safety before widespread deployment. This approach aligns with best practices in patch management, emphasizing the importance of thorough testing to mitigate the risk of unintended consequences and ensure the continued security and stability of systems and applications.
References:
Which statement is TRUE regarding the use of questionnaires in third party risk assessments?
The total number of questions included in the questionnaire assigns the risk tier
Questionnaires are optional since reliance on contract terms is a sufficient control
Assessment questionnaires should be configured based on the risk rating and type of service being evaluated
All topic areas included in the questionnaire require validation during the assessment
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
Which of the following BEST describes the distinction between a regulation and a standard?
A regulation must be adhered to by all companies subject to its requirements, but companies “can voluntarily choose to follow standards.
There is no distinction, regulations and standards are the same and have equal impact
Standards are always a subset of a regulation
A standard must be adhered to by companies based on the industry they are in, while regulations are voluntary.
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:
Which type of contract provision is MOST important in managing Fourth-Nth party risk after contract signing and on-boarding due diligence is complete?
Subcontractor notice and approval
Indemnification and liability
Breach notification
Right to audit
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:
When defining due diligence requirements for the set of vendors that host web applications which of the following is typically NOT part of evaluating the vendor's patch
management controls?
The capability of the vendor to apply priority patching of high-risk systems
Established procedures for testing of patches, service packs, and hot fixes prior to installation
A documented process to gain approvals for use of open source applications
The existence of a formal process for evaluation and prioritization of known vulnerabilities
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:
The following statements reflect user obligations defined in end-user device policies
EXCEPT:
A statement specifying the owner of data on the end-user device
A statement that defines the process to remove all organizational data, settings and accounts alt offboarding
A statement detailing user responsibility in ensuring the security of the end-user device
A statement that specifies the ability to synchronize mobile device data with enterprise systems
End-user device policies are policies that establish the rules and requirements for the use and management of devices that access organizational data, networks, and systems. These policies typically include user obligations that define the responsibilities and expectations of the users regarding the security, privacy, and compliance of the devices they use. According to the web search results from the search_web tool, some common user obligations defined in end-user device policies are:
However, option D, a statement that specifies the ability to synchronize mobile device data with enterprise systems, is not a user obligation defined in end-user device policies. Rather, this statement is a feature or functionality that may be enabled or disabled by the organization or the device manager, depending on the security and compliance needs of the organization. This statement may also be part of a device configuration policy or a mobile device management policy, which are different from end-user device policies. Therefore, option D is the correct answer, as it is the only one that does not reflect a user obligation defined in end-user device policies. References: The following resources support the verified answer and explanation:
At which level of reporting are changes in TPRM program metrics rare and exceptional?
Business unit
Executive management
Risk committee
Board of Directors
TPRM program metrics are the indicators that measure the performance, effectiveness, and maturity of the TPRM program. They help to monitor and communicate the progress, achievements, and challenges of the TPRM program to various stakeholders, such as business units, executive management, risk committees, and board of directors. However, the level of reporting and the frequency of changes in TPRM program metrics vary depending on the stakeholder’s role, responsibility, and interest123:
Therefore, the correct answer is D. Board of Directors, as this is the level of reporting where changes in TPRM program metrics are rare and exceptional. References:
All of the following processes are components of controls evaluation in the Third Party Risk Assessment process EXCEPT:
Reviewing compliance artifacts for the presence of control attributes
Negotiating contract terms for the right to audit
Analyzing assessment results to identify and report risk
Scoping the assessment based on identified risk factors
Controls evaluation is the process of verifying and validating the effectiveness of the controls implemented by the third party to mitigate the identified risks. It involves reviewing the evidence provided by the third party, such as policies, procedures, certifications, attestations, or test results, to determine if the controls are adequate, consistent, and compliant with the requirements and standards of the organization. Controls evaluation also involves analyzing the assessment results to identify any gaps, weaknesses, or issues in the third party’s controls, and reporting the findings and recommendations to the relevant stakeholders. Negotiating contract terms for the right to audit is not a component of controls evaluation, but rather a component of contract management. Contract management is the process of establishing, maintaining, and enforcing the contractual agreements between the organization and the third party. It involves defining the roles, responsibilities, expectations, and obligations of both parties, as well as the terms and conditions for service delivery, performance measurement, risk management, dispute resolution, and termination. Negotiating contract terms for the right to audit is a key aspect of contract management, as it allows the organization to monitor and verify the third party’s compliance with the contract and the applicable regulations and standards. It also enables the organization to conduct independent audits or assessments of the third party’s controls, processes, and performance, and to request remediation actions if necessary. References:
Which of the following statements is FALSE regarding a virtual assessment:
Virtual assessment agendas and planning should identify who should be available for interviews
Virtual assessment planning should identify what documentation is available for review prior to and during the assessment
Virtual assessments should be used to validate or confirm understanding of key controls, and not be used simply to review questionnaire responses
Virtual assessments include using interviews with subject matter experts since controls evaluation and testing cannot be performed virtually
Virtual assessments are a method of conducting third party risk assessments remotely, using various tools and techniques to collect and verify information about the third party’s controls, processes, and performance. Virtual assessments can be used to evaluate various risk domains, such as information security, privacy, resiliency, and compliance, depending on the scope and objectives of the assessment. Virtual assessments can also be used to complement or supplement onsite assessments, especially when travel or access restrictions are in place.
One of the key components of virtual assessments is the use of interviews with subject matter experts (SMEs) from the third party, who can provide insights and clarifications on the third party’s policies, procedures, practices, and evidence. Interviews can also be used to validate or confirm the understanding of key controls, and not just to review questionnaire responses. However, interviews are not the only way to perform controls evaluation and testing in virtual assessments. Other methods include:
Therefore, the statement that virtual assessments include using interviews with SMEs since controls evaluation and testing cannot be performed virtually is false, as there are other ways to perform controls evaluation and testing in virtual assessments, besides interviews.
References:
Which requirement is NOT included in IT asset end-of-life (EOL) processes?
The requirement to conduct periodic risk assessments to determine end-of-life
The requirement to track status using a change initiation request form
The requirement to track updates to third party provided systems or applications for any planned end-of-life support
The requirement to establish defined procedures for secure destruction al sunset of asset
In IT asset end-of-life (EOL) processes, the requirement to conduct periodic risk assessments specifically to determine end-of-life is not typically included. EOL processes generally focus on managing the decommissioning and secure disposal of IT assets that have reached the end of their useful life or support period. This includes tracking the status of assets, managing updates and support for third-party systems and applications, and establishing procedures for the secure destruction of assets at sunset. While risk assessments are crucial in overall IT asset management, they are not usually a direct component of determining an asset's EOL status, which is more often based on operational effectiveness, manufacturer support, and technological obsolescence.
References:
Which approach demonstrates GREATER maturity of physical security compliance?
Leveraging periodic reporting to schedule facility inspections based on reported events
Providing a checklist for self-assessment
Maintaining a standardized scheduled for confirming controls to defined standards
Conducting unannounced checks an an ac-hac basis
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:
Which of the following indicators is LEAST likely to trigger a reassessment of an existing vendor?
Change in vendor location or use of new fourth parties
Change in scope of existing work (e.g., new data or system access)
Change in regulation that impacts service provider requirements
Change at outsourcer due to M&A
This answer is correct because a change at outsourcer due to merger and acquisition (M&A) is the least likely indicator to trigger a reassessment of an existing vendor. This is because the outsourcer is not the direct vendor of the organization, but rather a third party that the vendor uses to perform some of its services. Therefore, the impact of the change at the outsourcer on the vendor’s performance and risk level may not be significant or immediate. However, the other indicators (A, B, and C) are more likely to trigger a reassessment of an existing vendor, as they directly affect the vendor’s operations, capabilities, and compliance status. For example:
Which of the following data safeguarding techniques provides the STRONGEST assurance that data does not identify an individual?
Data masking
Data encryption
Data anonymization
Data compression
Data anonymization is the process of removing or altering any information that can be used to identify an individual from a data set. This technique provides the strongest assurance that data does not identify an individual, as it makes it impossible or extremely difficult to link the data back to the original source. Data anonymization can be achieved by various methods, such as generalization, suppression, perturbation, or pseudonymization12. Data anonymization is often used for privacy protection, compliance with data protection regulations, and data sharing purposes3. References:
The BEST way to manage Fourth-Nth Party risk is:
Include a provision in the vender contract requiring the vendor to provide notice and obtain written consent before outsourcing any service
Include a provision in the contract prohibiting the vendor from outsourcing any service which includes access to confidential data or systems
Incorporate notification and approval contract provisions for subcontracting that require evidence of due diligence as defined by a TPRM program
Require the vendor to maintain a cyber-insurance policy for any service that is outsourced which includes access to confidential data or systems
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 partners. This can create a complex network of dependencies and exposures that can affect the organization’s security, data protection, and business resilience. To manage this risk effectively, organizations should conduct comprehensive due diligence on their extended vendor and supplier network, and include contractual stipulations that require notification and approval for any subcontracting activities. This way, the organization can ensure that the subcontractors meet the same standards and expectations as the direct third-party partners, and that they have adequate controls and safeguards in place to protect the organization’s data and systems. Additionally, the organization should monitor and assess the performance and compliance of the subcontractors on a regular basis, and update the contract provisions as needed to reflect any changes in the risk environment. References:
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