Expert Guide Third Party Risk Management
Expert Guide Third Party Risk Management
MANAGEMENT BEST
PRACTICES
Expert Advice for an Effective & Efficient Program
EXPERT GUIDE
CONTENTS
03 Introduction
ProcessUnity specializes in helping its clients automate their Third-Party Risk Management (TPRM) programs. Through
the years, we have helped hundreds of customers implement efficient and effective processes that drive risk out of
their businesses. Our team developed this guide to showcase a number of the best practices we see in modern TPRM
programs. Our hope is that you find a few “nuggets of wisdom” that you can take back to your company, program
and team and continue to mature your TPRM processes.
Examine the importance of inherent risk calculations Help you rate your program’s maturity and
provide next steps for improvement
Demonstrate how residual risk helps determine
ongoing review cadences
Most companies have some semblance of Governance, Risk and Compliance (GRC) management in place today.
Governance is all about setting goals and objectives for the organizations and setting the tone from the executive
team and board of directors.
Compliance
Controls Financial IT Operational Management
Policies & Procedures
Risks Health & Safety Product Quality Financial Security & Privacy
When building or up-leveling a TPRM program, it’s Throughout pre- and post-contract work, there will
important to recognize that work happens both before be issues that arise. TPRM teams need capabilities to
and after signing a contract. identify, track and remediate those issues appropriately.
• The pre-contract onboarding process: usually An important note: The base process flows described
consisting of an inherent risk assessment and initial in the coming pages will vary from organization to
due diligence review – is designed to keep as much organization based on company size, the maturity of the
risk out from the start. program, industry and more. There is no “one-size-fits-all
approach,” and TPRM teams should adapt these models
• Post-contract processes: ongoing monitoring and
to fit their specific business requirements.
service reviews – are put in place to make sure
nothing has changed with vendors over time and to
check that vendors are delivering their services in
accordance with expectations.
Pre-Contract Post-Contract
Line of Request
Business 1. Request Denied
Third-Party Service
Follow Up
No
No Low Critical / High / No
Yes Medium Follow Up Yes
Third-Party Advance
Inherent Request
Risk
Manager 2. Review Request?
Level 3. Send 5. Analyze 6. Create 7. Close 8. Agreement Approved
Third-Party Assessment Assessment Related Issues Assessment in Review
Service Request
Third-Parrty
Contact 4. Assessment
Response
The onboarding workflow triggers when the a. Not all vendors will have to go through the entire
organization needs to contract with a new vendor. process. The inherent risk some vendors pose may be
Here’s how the process works: determined to be low. Lower-risk vendors may not have
to respond to due diligence questionnaires.
1. A new office is opening in the EU, and there is a
need for a payroll provider who can pay the employees b. More risky vendors will need to go through a deeper
internationally. [Step 1] A payroll or HR person assessment process.
(LOB user) initiates a request to the third-party risk
4. The completed assessment is received and analyzed
management team.
[Step 5], issues are then created [Step 6], and the
2. [Step 2] The third-party manager works with the LOB assessment is closed [Step 7].
user to determine how much risk there is in working
5. Ideally everything is good, the request is approved, and
with the vendor (inherent risk assessment) and checks
contracts and agreements are executed [Step 8].
to see if a similar service or vendor is already under
contract (to avoid duplication). The details of the onboarding workflow process will vary
among companies based on each individual company’s risk
3. Based on the initial inherent risk rating, an
profile. Some companies may have additional steps that
assessment questionnaire [Step 3] is sent to the vendor
include routing specific assessment responses to subject
requesting it provide more in-depth information [Step
matter experts (SMEs) for cybersecurity or to a financial
4] for the organization to analyze and evaluate.
specialist to determine that a vendor’s financial viability is
acceptable. Different paths exist for different organizations.
Line of
Businesss
Follow Up
ty
Third-Party
Managerr 1. Send 3. Analyze 4. Create Related 5. Close
Assessment Assessment Issues Assessment
ty
Third-Party
Contactt 2. Assessment
Response
Line of
Business 2. Complete
Service Review
Third-Party
Manager 1. Send Service
Review
Third-Party
Contact
Risk Domains Help Define Inherent 1. What is the expected annual contract amount?
Risk Questions (Risk domains: financial, business continuity)
Typically, inherent risk is determined via communication 2. Is the third-party service performed domestically
between the LOB user requesting a vendor service and (Risk domain: geographic)
the third-party manager. There is usually some sort of
3. Is the service essential to the operations of the
short questionnaire or form completed by the requestor.
company? (Risk domain: business continuity)
There are nine risk domains TPRM teams can look at to
determine the right mix of inherent risk questions for 4. How difficult would it be to replace this service?
their company: (Risk domain: business continuity)
• Identity: Is this vendor who it says it is? 5. What is the expected annual volume of records that
Is it a real company? will be accessed, processed, stored, or transmitted by
this third party? (Risk domain: information security)
• Information security: Is the vendor handling
sensitive information/data? 6. Is any part of the third-party service being provided
subject to any regulatory and/or compliance
• Geographic: Where is the vendor located?
requirements? (Risk domain: compliance)
Could its location lead to a supply chain disruption?
7. Does this third-party store, process, or transmit
• Financial: Is the vendor paying its bills?
personally identifiable information (PII) or protected
Will it continue to be in business in a year?
health information (PHI) as part of this service?
• Business Continuity: Does vendor have a plan in (Risk domain: information security)
place in case something goes wrong?
8. Is the service delivered as a cloud-based solution?
• Fourth Party: Is the vendor working with fourth (Risk domain: information security)
parties? What risk do its fourth parties present?
9. Does this third party have access to our IT
• Reputation: Is there negative news about the vendor network or technical infrastructure?
that may cause reputational and brand damage by (Risk domain: information security)
associating with them?
10. Does the third party outsource any part of the
• Compliance: Is the vendor in compliance with rules service? (Risk domains: information security, geographic)
and regulations?
• Conflict of interest: Are there any personal conflicts
of interest with vendor personnel? Does the business
have Unidenfied Beneficial Owners to consider?
Testing is a key part of the scoring system development The system was designed and successfully tested, and
process, and answers the question, “Does this make now the low, medium, high, and critical designations
sense for us?” can be used to scope the amount of due diligence for
vendors—the due diligence depth the company does
In test scenarios, a major bank, a records shredder and with each vendor.
a landscaping contractor are all scored. The company’s
bank is essential to operations and therefore deemed a
LOW MEDIUM HIGH CRITICAL
Critical vendor. The answers to the remaining questions 0-5 6-7 8 - 11 12 +
aren’t even needed.
No Further Light Due Medium Due Intensive Due
The records shredder is a little different. It’s not essential, Due Diligence Diligence Diligence Diligence
Required Required Required Required
not a big contract, and performed domestically.
However, the vendor is difficult to replace, it will touch
Figure 3.5 – Use inherent risk scores to auto-scope
a high volume of records, have personal identifiable due diligence
information to shred, and there will be regulatory issues
to consider. All of these answers lead to 8 points, which
For a low risk vendor, no due diligence is required; the
leads to a High-risk designation.
contract is signed, and business engaged.
At the other end of the spectrum is the company
As the organization engages with medium, high, and
responsible for snow plowing in the winter and facility
critical risk vendors more time will be spent on and a
landscaping during warmer months. The only points they
deeper intensity will be part of the assessments.
scored were earned because they outsource to a vendor
that plants flowers in the spring. The vendor is not a risk
to the company and designated in the Low risk tier.
QUESTIONNAIRES
There have been interesting changes to assessment Self-scoping questionnaires followed the small,
questionnaires over the past few years. medium, large approach. These questionnaires scoped
automatically based the risk tiers or changed on the fly
In the early days of TPRM, companies would have a
based on vendors’ answers to questions. These smart
single assessment for all vendors – a one-size-fits-all
questionnaires can show or hide questions or sections
approach. The questionnaires were long and used to
of questions based on inherent risk tier and answers
assess all vendors regardless of the risk they posed. It
to previous questions. Self-scoping questionnaires
was overkill for low-risk and small vendors; it was not
help minimize the number of questions that need to
enough for critical vendors.
be answered by the vendor and analyzed by the TPRM
Because the one size fits all approach did not work well, team.
companies evolved to have multiple questionnaires –
Most recently, self-scoping questionnaires have
this was more of a small, medium, large approach. Deep
been enhanced with self-scoring capabilities where
questionnaires were sent to high-risk vendors and lighter
the questionnaire is assessed in real time. These
questionnaires were reserved for lower-risk vendors.
questionnaires, through an automation process and a set
There were issues with maintaining multiple question
of preferred responses, generate issues and follow-up
sets, however.
tasks that help the third-party management team focus
on what is most important.
For a more in-depth look at how assessment tools have evolved, download ProcessUnity’s guide, The Evolution of
the Third-Party Due Diligence Questionnaire.
With the inherent risk scoring system in place, it can be used to determine residual risk, and to set up the
organization’s post-contract review cadences, defining how often and how deep the company needs to go with
ongoing monitoring moving forward.
Residual Risk Determines Scope and Combining the inherent risk rating and the assessment
Frequency review rating determines a residual risk score. This will
determine how often assessments need to be performed
Take the vendor’s initial inherent risk score and combine
and how deep the assessment needs to be.
it with the score from the previous assessment.
Let’s look at what this means for critical vendors.
Inherent Risk Categories A critical vendor with:
• Critical • Medium • No Prior Review will be rated Critical for residual risk,
• High • Low required to submit to the deepest due diligence, and
the assessment will be required immediately.
Figure 4.2 – Residual risk determines scope and frequency of periodic due diligence
As vendors perform better compared with their previous assessment ratings, their residual risk score gets dropped
down, and their assessments become lighter and less frequent.
Many third-party management teams are small and have limited resources but want to improve their programs and
expand their abilities or team. There’s help: third-party risk management programs can be augmented with external
expert content and managed services.
Line of Request
Business 1. Request Denied
Third-Party Service
Follow Up
No
No Low Critical / High / No
Yes Medium Follow Up
Yes
Third-Party Advance
Inherent
Request
Risk
Manager 2. Review Request?
Level 3. Send 5. Analyze 6. Create 7. Close 8. Agreement Approved
Third-Party Assessment Assessment Related Issues Assessment in Review
Service Request
ALERT!
Questionable Financial Health
Third-Party Score!
Contact 4. Assessment
Response
Figure 5.1 – Expert content serves as a virtual assistant during the onboarding process
Follow Up
ALERT!
Third-Party Cybersecurity Rating Below
Manager 1. Send 3. Analyze 4. Create 5. Close Acceptable Threshold! Please
Assessment Assessment Related Issues Assessment Reassess.
Third-Party
Contact 2. Assessment
Response
Figure 5.2 – Expert content alerts TPRM teams to changes in vendor status in between periodic due diligence
TIME
Informal to Reactive program: The key advantage in moving from informal to reactive is a blank slate. Find peers in
the industry that are “better” than you are; ask how they are running their programs and find out what mistakes they
made so you can avoid them. Formalize your program. Document your workflows and inherent risk scoring system.
Surface results (and issues) to the executive team.
Reactive to Proactive program: Get rid of spreadsheets and email. Establish a third-party risk management system
to manage data and automate manual tasks. Define inherent risk and residual risk. The key advantage here is your
experiential knowledge regarding what is and what is not working. Push aside what is not working and focus on
what is.
Proactive to Optimized program: When your organization reaches the proactive level, seek to increase LOB
involvement (use LOB involvement to help with inherent riskscores early in the process and with performance reviews
after contracts have been signed). Begin looking beyond early phases of vendor risk management lifecycle to focus
on ROI generating opportunities and incorporate contract management and SLA tracking. The advantage here,
especially for highly-regulated organizations, is that at this stage your organization should have consistency with your
regulators and audits should be more routine and less challenging, which will lead to regulators having confidence in
your organization.
Optimized to Better Optimized: When your organization reaches the top of the mountain, it has all of the data
it needs to make better business decisions around contracts and negotiations and put KPIs, SLAs and other
performance metrics in place. Continue to transform a cost-of-doing-business into an ROI center for the organization.
Formalize your program Nix the one-size-fits all Increase LOB involvement and Focus on cost reduction and
questionnaire executive promotion vendor service quality
Document, document,
document Implement a repository for Extend beyond onboarding Advantage: Improved
Socialize program’s charter
TPRM data and due diligence negotiation power based
with executives Calculate inherent and on accurate, actionable data
Improve contract management on vendors’ ability to meet
residual risk and SLA tracking
Advantage: Blank slate KPIs, SLAs and other
Look to automation Incorporate external data performance metrics
Advantage: Leverage your into onboarding and
recent experience to determine continuous monitoring
what’s working…and what’s Advantage: Consistency builds
not working confidence with regulators
These are truly achievable goals. No matter where you are in your vendor risk maturity there is always an opportunity
for growth and improvement: you will find that your program is one that will mature over time, increasing in value as
you gain experience.
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Twitter: @processunity
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