Develop a process to evaluate service providers who hold sensitive data, or are responsible for an enterprise’s critical IT platforms or processes, to ensure these providers are protecting those platforms and data appropriately.
[csf.tools Note: For more information on the Critical Security Controls, visit the Center for Internet Security.]
Establish and maintain an inventory of service providers. The inventory is to list all known service providers, include classification(s), and designate an enterprise contact for each service provider. Review and update the inventory annually, or when significant enterprise changes occur that could impact this Safeguard.
Establish and maintain a service provider management policy. Ensure the policy addresses the classification, inventory, assessment, monitoring, and decommissioning of service providers. Review and update the policy annually, or when significant enterprise changes occur that could impact this Safeguard.
Classify service providers. Classification consideration may include one or more characteristics, such as data sensitivity, data volume, availability requirements, applicable regulations, inherent risk, and mitigated risk. Update and review classifications annually, or when significant enterprise changes occur that could impact this Safeguard.
Ensure service provider contracts include security requirements. Example requirements may include minimum security program requirements, security incident and/or data breach notification and response, data encryption requirements, and data disposal commitments. These security requirements must be consistent with the enterprise's service provider management policy. Review service provider contracts annually to ensure contracts are not missing security requirements.
Assess service providers consistent with the enterprise's service provider management policy. Assessment scope may vary based on classification(s), and may include review of standardized assessment reports, such as Service Organization Control 2 (SOC 2) and Payment Card Industry (PCI) Attestation of Compliance (AoC), customized questionnaires, or other appropriately rigorous processes. Reassess service providers annually, at a minimum, or with new and renewed contracts.
Monitor service providers consistent with the enterprise's service provider management policy. Monitoring may include periodic reassessment of service provider compliance, monitoring service provider release notes, and dark web monitoring.
Securely decommission service providers. Example considerations include user and service account deactivation, termination of data flows, and secure disposal of enterprise data within service provider systems.