The ongoing challenge of IT and data risk management
Managing IT and data risk is a challenging job. When we outsource our IT, applications and data processing to third-parties more and more every day, managing that risk becomes almost impossible. No longer are our data and systems contained within an infrastructure that we have full control over. We now give vendors our data, and allow them to conduct operations on our behalf.
The problem is, we don’t control their infrastructure, and we can never fully look under the hood to understand and vet their ability to protect our data and operations. We have to fully understand how important this issue is, and ensure we have the right governance, processes and teams to identify and mitigate any risks found in our vendors. No longer are our data and systems contained within an infrastructure that we have full control over
Today, everything is connected. Our own networks have Internet of Things (IoT) devices. We have VPN connections coming in, and we aren’t always sure who is on the other end of that connection. It is a full-time job just to get a handle on our own risk. How much harder, and how much larger should our teams and budgets be, to truly know and trust that our vendors can secure those devices and external connections?
For every device and application we have internally, it is very difficult to even keep an accurate inventory. Do all of our vendors have some special sauce that allows them to overcome the traditional challenges of securing internal and vendor-connected networks? They are doing the same thing we are – doing our best with the limited human and financial resources allocated by our organisation.
Risk stratification and control objectives
The benefits of outsourcing operations or using a vendor web application are clear. So how can we properly vet those vendors from an IT risk perspective?
The very first thing we need to put in place is Risk Stratification. Risk Stratification presents a few targeted questions in the purchasing process. These questions include – what type of data will be shared? How much of this data? Will the data be hosted by a vendor? Will this hosting be in the US or offshored? Has the vendor ever had a data breach? These questions allow you to quickly discern if a risk assessment is needed and if so, what depth and breadth. Risk stratification allows you to make decisions that not only improve your team’s efficiency, but also ensure that you are not being a roadblock to the business
Risk stratification allows you to make decisions that not only improve your team’s efficiency, but also ensure that you are not being a roadblock to the business. With risk stratification, you can justify the extra time needed to properly assess a vendor’s security.
And in the assessment of a vendor’s security, we have to consider what control objectives we will use. Control objectives are access controls, policies, encryption, etc. In healthcare, we often use the HITRUST set of control objectives. In assessing against those control objectives, we usually use a spreadsheet.
Today, there are many vendors who will sell us more automated ways to get that risk assessment completed, without passing spreadsheets back and forth. These solutions are great if you can get the additional budget approved.
Even if we are using old-fashioned spreadsheets, we can ensure that the questions asked of the vendor include a data flow and network/security architecture document. We want to see the SOC2 report if they are hosting their solution in Amazon, etc. If they are hosting it within their own datacentre, we absolutely want to see a SOC2 Type II report. If they haven’t done that due diligence, should that be a risk for you?
Today, we really need to be requiring our vendors to have multi-factor authentication on both their Internet-facing access, as well as their privileged internal access to our sensitive data. I rate those vendors who do not have this control in place as a high risk. We’ve recently seen breaches that were able to happen because the company did not require administrators or DBAs to use a 2-factor authentication into sensitive customer data sources.
In the assessment of a vendor’s security, one has to consider what control objectives to use
This situation brings up the issue of risk acceptance. Who in your organisation can accept a high risk? Are you simply doing qualitative risk assessment – high, medium and low risks? Or are you doing true quantitative risk analysis? The latter involves actually quantifying those risks in terms of likelihood and impact of a risk manifesting, and the dollar amount that could impact your organisation.
So is it a million dollars of risk? Who can accept that level of risk? Just the CEO? These are questions we need to entertain in our risk management programs, and socialised within your organisation.
This issue is so important – once we institute risk acceptance, our organisation suddenly starts caring about the vendors and applications we’re looking to engage. If they are asked to accept a risk without some sort of mitigation, they suddenly care and think about that when they are vetting future outsourced solutions. Quantitative risk analysis involves quantifying risks in terms of likelihood and impact of a risk manifesting
Risk management process
In this discussion, it is important to understand how we think of, and present, the gaps we identify in our risk management processes. A gap is not a risk. If I leave my front door unlocked, is that a control gap or a risk? It is a gap – an unlocked door. What is the risk?
The risk is the loss of property due to a burglary or the loss of life due to a violent criminal who got in because the door was unlocked. When we present risks, we can’t say the vendor doesn’t encrypt data. The risk of the lack of encryption is fines, loss of reputation, etc. due to the breach of data. A gap is not a risk.
Once we’ve conducted our risk analysis, we must then ensure that our contracts protect our organisation? If we’re in healthcare, we must determine if the vendor is, in fact, a true HIPAA Business Associate, and if so we get a Business Associate Agreement (BAA) in place. I also require my organisation to attach an IT Security Amendment to these contracts. The IT Security Amendment spells out those control objectives, and requires each vendor to sign off on those critical controls. We are responsible for protecting our organisation’s IT and data infrastructure – today that often means assessing a 3rd-party’s security controls
One final note on risk assessments – we need to tier our vendors. We tier them in different ways – in healthcare a Tier 1 vendor is a vendor who will have our patient information on the Internet. Tiering allows us to subject our vendors to re-assessment. A tier 1 vendor should be re-assessed annually, and may require an actual onsite assessment vs. a desk audit. A tier 2 vendor is re-assessed every 2 years, etc.
We are responsible for protecting our organisation’s IT and data infrastructure – today that often means assessing a 3rd-party’s security controls. We must be able to fully assess our vendors while not getting in the way of the business, which needs to ensure proper operations, financial productivity and customer satisfaction. If we truly understand our challenge of vendor risk management, we can tailor our operations to assess at the level needed, identify and report on risks, and follow-up on any risks that needed mitigated.