Wednesday, May 7, 2025

Navigating Vendor Risk Assessments: Best Practices from the Frontlines of TPRM

 


In today’s interconnected business environment, vendors are often an extension of our own organization. As someone who has spent nearly two decades leading information security and risk assurance initiatives, I’ve seen firsthand how a well-executed Third-Party Risk Management (TPRM) program can safeguard a company’s data, reputation, and customer trust.

Whether onboarding a new vendor or renewing an existing relationship, risk assessments are critical. However, not all assessments are created equal. Through my journey across regulated industries and global compliance landscapes, I’ve gathered a set of best practices that blend regulatory expectations with practical experience.


1. Start with a Risk-Based Segmentation

One of the early mistakes I used to see — and admittedly made myself early on — was applying a one-size-fits-all risk assessment. This not only wastes resources but also creates fatigue across teams.

Best Practice:
Classify vendors based on their risk profile: Critical, High, Medium, Low. Factors include data access (PII, PHI, PCI), system integration, regulatory exposure, and business impact. Only critical/high-risk vendors should go through extensive due diligence.


2. Align Assessment Depth with Business Impact

While working with a cloud service provider for a sensitive healthcare client, I learned how essential it is to align assessment scope with potential business disruption.

Best Practice:
Use tiered questionnaires and leverage industry frameworks like:

  • ISO/IEC 27001

  • NIST Cybersecurity Framework

  • SIG-Lite / SIG-Core by Shared Assessments

  • CSA CAIQ for cloud vendors
    This ensures proportional effort and deeper focus where it matters most.


3. Involve Cross-Functional Stakeholders Early

A successful TPRM program is not just an InfoSec initiative — it's a collaborative effort.

Best Practice:
Loop in Procurement, Legal, Privacy, and Business Owners right from the risk assessment phase. Their inputs can highlight hidden dependencies, legal exposures, and operational nuances that security alone might overlook.


4. Verify, Don’t Just Trust Artifacts

I’ve come across vendors proudly waving their ISO27001 or SOC 2 Type II reports. While these are valuable, they’re not bulletproof.

Best Practice:

  • Review reports critically. Look for scope, carve-outs, and noted exceptions.

  • If possible, request evidence samples (e.g., redacted policies, screenshots, or audit logs).

  • Conduct interviews or virtual assessments for high-risk vendors, especially if they impact regulated data.


5. Don’t Underestimate Renewal Assessments

One of the biggest gaps I’ve noticed — especially in mature organizations — is the complacency during vendor renewals.

Best Practice:
Treat renewals as a checkpoint, not a rubber stamp. Reassess:

  • Changes in services or integrations

  • Breach history since the last review

  • Compliance with evolving regulations (e.g., DORA, GDPR updates, AI governance)

Pro tip from experience: Maintain a trigger-based reassessment model — any material change in the vendor’s environment should prompt a risk review outside the renewal cycle.


6. Automate Where Possible, but Humanize the Review

I’ve implemented automation through platforms like Archer, OneTrust, and ProcessUnity — and it’s saved countless hours. But, don’t automate judgment.

Best Practice:
Use tools to manage workflows, scoring, and document storage. But retain manual reviews for free-text responses, risk ratings, and red flags. Always involve a risk analyst or SME in final decisions.


7. Document Everything – It’s Your Audit Trail

During an audit for a large banking client, I once had to dig through email chains and chat logs to recreate a vendor decision. Not fun.

Best Practice:
Maintain a central repository for:

  • Completed questionnaires

  • Risk ratings and justification

  • Mitigation plans

  • Approval sign-offs
    This not only simplifies audits but also provides continuity if personnel change.


8. Monitor Post-Onboarding

Risk doesn’t end with onboarding — it evolves.

Best Practice:
Set up ongoing monitoring mechanisms:

  • Cybersecurity rating tools (e.g., BitSight, SecurityScorecard)

  • News and breach alerts

  • Annual reassessments or trigger-based reassessments
    Incorporate these insights into a Vendor Risk Register and regularly update senior stakeholders.


Closing Thoughts

Over the years, I’ve learned that TPRM is as much about relationships and risk culture as it is about checklists. The real value of a risk assessment lies in what you do with it — not just the fact that you did it.

By embedding context, collaboration, and continuous improvement into your risk assessment process, you don’t just check a compliance box — you protect your organization in a tangible, measurable way.


Sources and Frameworks Referenced:

  • ISO/IEC 27001:2022 – Information Security Management

  • NIST SP 800-53 Rev. 5 – Security and Privacy Controls

  • Shared Assessments SIG – Standardized Information Gathering

  • CSA CAIQ – Cloud Security Alliance’s Consensus Assessment Initiative Questionnaire

  • BitSight, SecurityScorecard – Vendor cyber risk monitoring platforms

  • DORA – Digital Operational Resilience Act (EU, 2025 compliance)

  • Personal experiences across banking, cloud, and healthcare sectors


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