Perimeter
11/26/2011
12:02 PM
Commentary
Commentary
Commentary
50%
50%

Partner Management: Compliance Program Is Essential

Understanding the risk associated with a partner relationship and managing it accordingly is key

If you look at almost every regulation or contract, from HIPAA to state privacy laws to PCI DSS, every one has provisions for managing partners that have access to protected data. However, many organizations new to compliance (or with immature compliance programs) have a difficult time determining how to “manage” their vendors.

The key to effective management of vendors is to understand the risk that each vendor poses, and to manage that risk over the long term. This means assessing risk, establishing controls, and monitoring the effectiveness of the controls periodically for the life of the relationship.

Regulations require organizations to monitor the state of the relationship and take responsibility for the practices of the partner. These relationships require assessment, legal agreements, and regular communication. At the heart of this practice is the idea that organizations need to view a breach at a partner as just as dangerous as a compromise in their own enterprises.

The first step in effectively managing partners is to understand what data is shared with a partner and to determine the inherent risk. The inherent risk is the worst-case scenario in which the data is compromised. This means imagining the compromise without factoring in the likelihood of it occurring. Understanding inherent risk allows an organization to understand the criticality of the vendor and determine to what degree it should invest in analyzing its security practices and protecting the data.

Once you understand the data shared, you should ask yourself whether all the data needs to be shared. Sometimes this analysis and some creative thinking can eliminate sensitive data fields and substantially reduce the risk of compromise. However, it could be that critical information needs to be shared. If so, you’ll need to ensure that the organization is going to protect the data in a compliant manner.

If the data is extremely sensitive (e.g., includes Social Security numbers, protected health information, or payment card data), you will need to find a cost-effective method for analyzing the vendor’s security and compliance controls. The options are to conduct your own assessment, contract someone to conduct an assessment, or trust someone else’s assessment.

In a future post, I’ll describe ways to assess whether the vendor is capable of meeting your requirements and the pros and cons of various assessment methods. The important point to remember is that you need to be confident that the vendor’s business model, technical controls, and legal commitments will allow you to comply the particular regulation or regulations that require you to protect the data.

Richard Mackey is vice president of consulting at SystemExperts Corp.

Comment  | 
Print  | 
More Insights
Register for Dark Reading Newsletters
White Papers
Cartoon
Current Issue
Flash Poll
Title Partner’s Role in Perimeter Security
Title Partner’s Role in Perimeter Security
Considering how prevalent third-party attacks are, we need to ask hard questions about how partners and suppliers are safeguarding systems and data.
Video
Slideshows
Twitter Feed
Dark Reading - Bug Report
Bug Report
Enterprise Vulnerabilities
From DHS/US-CERT's National Vulnerability Database
CVE-2014-4774
Published: 2015-05-25
Cross-site request forgery (CSRF) vulnerability in the login page in IBM License Metric Tool 9 before 9.1.0.2 and Endpoint Manager for Software Use Analysis 9 before 9.1.0.2 allows remote attackers to hijack the authentication of arbitrary users via vectors involving a FRAME element.

CVE-2014-4778
Published: 2015-05-25
IBM License Metric Tool 9 before 9.1.0.2 and Endpoint Manager for Software Use Analysis 9 before 9.1.0.2 do not send an X-Frame-Options HTTP header in response to requests for the login page, which allows remote attackers to conduct clickjacking attacks via vectors involving a FRAME element.

CVE-2014-6190
Published: 2015-05-25
The log viewer in IBM Workload Deployer 3.1 before 3.1.0.7 allows remote attackers to obtain sensitive information via a direct request for the URL of a log document.

CVE-2014-6192
Published: 2015-05-25
Cross-site scripting (XSS) vulnerability in IBM Curam Social Program Management 6.0 SP2 before EP26, 6.0.4 before 6.0.4.5 iFix10, 6.0.5 before 6.0.5.6, and 6.0.5.5a before 6.0.5.8 allows remote authenticated users to inject arbitrary web script or HTML via a crafted URL.

CVE-2014-8926
Published: 2015-05-25
Common Inventory Technology (CIT) before 2.7.0.2050 in IBM License Metric Tool 7.2.2, 7.5, and 9; Endpoint Manger for Software Use Analysis 9; and Tivoli Asset Discovery for Distributed 7.2.2 and 7.5 allows remote attackers to cause a denial of service (CPU consumption or application crash) via a cr...

Dark Reading Radio
Archived Dark Reading Radio
Join security and risk expert John Pironti and Dark Reading Editor-in-Chief Tim Wilson for a live online discussion of the sea-changing shift in security strategy and the many ways it is affecting IT and business.