Every organization that shares protected information with partners needs to ensure that those entities will protect the data adequately while in their care. A data owner’s responsibility begins with assessing prospective partners’ security and compliance practices, and continues throughout the life of the relationship.
Organizations faced with this responsibility often ask the same questions:
1. How do you assess an partner’s security and compliance practices?
2. Should all service providers undergo similar assessments?
3. How can we control the cost of assessments?
Let’s take these one at a time.
1. How do you assess?
Organizations need to ensure that the vendor or partner will meet the requirements of the applicable contract or regulation. At a minimum, this means asking a set of questions about who has access; how information is stored, transmitted, and processed; and how information is encrypted (particularly while stored, while on removable devices, and while transmitted on public networks). The more prescriptive the particular regulation, the specific the questions need to be. The answers to the questions can be collected in person, in response to a questionnaire, or in third-party assessment. The method for assessment should be based on the risk a particular partner represents and your budget.
2. Should all partners be assessed equally?
No. Organizations should determine the inherent risk associated with a partner and base the depth and thoroughness of the assessment on this measure. For example, if the organization is entrusted with large amounts of critical data and a compromise would be extremely damaging to the business, then it makes sense to visit the vendor and conduct a detailed review. On the other hand, if the vendor has only controlled and restricted access to the information or would not pose a major risk if it failed, then a questionnaire might suffice.
3. How can assessment costs be controlled?
The first way to control costs is to ensure that detailed assessments are conducted only on critical vendors. Another method is to use the results of third-party assessments (assuming you can verify the trustworthiness of the assessor). The PCI Security Council established Qualified Security Assessors and the assessment process for this very reason. Other industries, including finance and healthcare, have organizations that provide assessment frameworks and methods that are commonly used. There are also international security standards, like ISO 27001 and 27002, and accounting standards (e.g., SAE 16) that provide frameworks for assessing operational, security, and compliance practices.
Regardless of the method used to assess or the organization assessing the partner, the important point to remember is that you must satisfy yourself that the partner will meet your compliance requirements. In the event of a compromise or an audit, you will need to state why you believe your method effectively met your compliance requirements.
Richard Mackey is vice president of consulting at SystemExperts Corp.