Building a Vendor IT Risk Management Program: Evaluating Vendor RiskBy Mike Rothman
As we discussed in the first post in this series, whether it’s thanks to increasingly tighter business processes/operations with vendors andtrading partners, or to regulation (especially in finance) you can no longer ignore vendor risk management. So we delved into the structure and mapped out a few key aspects of a VRM program. Of course we are focused on the IT aspects of vendor management, which should be a significant component of a broader risk management approach for your environment.
But that begs the question of how you can actually evaluate the risks of a vendor. What should you be worried about, and how can you gather enough information to make an objective judgement of the risk posed by every vendor? So that’s what we’ll explore in this post.
Risk in the Eye of the Beholder
The first aspect of evaluating vendor risk is actually defining what that risk means to your organization. Yes, that seems self-evident, but you’d be surprised how many organizations don’t document or get agreement on what presents vendor risk, and then wonder why their risk management programs never get anywhere. Sigh.
All the same, as mentioned above, vendor (IT) risk is a component of a larger enterprise risk management program. So first establish the risks of working with vendors. Those risks can be broken up into a variety of buckets, including:
Financial: This is about the viability of your vendors. Obviously this isn’t something you can control from an IT perspective, but if a key vendor goes belly up, that’s a bad day for your organization. So this needs to be factored in at the enterprise level, as well as considered from an IT perspective – especially as cloud services and SaaS proliferate. If your Database as a Service vendor (or any key service provider) goes away, for whatever reason, that presents risk to your organization.
Operational: You contract with vendors to do something for your organization. What is the risk if they cannot meet those commitments? Or if they violate service level agreements? Again it is enterprise-level risk of the organization, but it also peeks down into the IT world. Do you pack up shop and go somewhere else if your vendor’s service is down for a day? Are your applications and/or infrastructure portable enough to even do that?
Security: As security professionals this is our happy place. Or unhappy place, depending on how you feel about the challenges of securing much of anything nowadays. This gets to the risk of a vendor being hacked and losing your key data, impacting availability of your services, and/or allowing an adversary to jump access your networks and systems.
Within those buckets, there are probably a hundred different aspects that present risk to your organization. After defining those buckets of risk, you need to dig into the next level and figure out not just what presents risk, but also how to evaluate and quantify that risk. What data do you need to evaluate the financial viability of a vendor? How can you assess the operational competency of vendors? And finally, what can you do to stay on top of the security risk presented by vendors? We aren’t going to tackle financial or operational risk categories, but we’ll dig into the IT security aspects below.
The first hoop most vendors have to jump through is self-assessment. As a vendor to a number of larger organizations, we are very familiar with the huge Excel spreadsheet or web app built to assess our security controls. Most of the questions revolve around your organization’s policies, controls, response, and remediation capabilities.
The path of least resistance for this self-assessment is usually a list of standard controls. Many organizations start with ISO 27002, COBIT, and PCI-DSS. Understand relevance is key here. For example, if a vendor is only providing your organization with nuts and bolts, their email doesn’t present a very significant risk. So you likely want a separate self-assessment tool for each risk category, as we’ll discuss below.
It’s pretty easy to lie on a spreadsheet or web application. And vendors do exactly that. But you don’t have the resources to check everything, so there is a measure of trust, but verify that your need to apply here. Just remember that it’s resource-intensive to evaluate every answer, so focus on what’s important, based on the risk definitions above.
Just a few years ago, if you wanted to assess the security risk of a vendor, you needed to either have an on-site visit or pay for a penetration test to really see what an attacker could do to partners. That required a lot of negotiation and coordination with the vendor, which meant it could only be used for your most critical vendors. And half the time they’d tell you to go pound sand, pointing to the extensive self-assessment you forced them to fill out.
But now, with the introduction of external threat intelligence services, and techniques you can implement yourself, you can get a sense of what kind of security mess your vendors actually are. Here are a few types of relevant data sources:
Botnets: Botnets are public by definition, because they use compromised devices to communicate with each other. So if a botnet is penetrated you can see who is connecting to it at the time, and get a pretty good idea of which organizations have compromised devices. That’s exactly how a number of services tell you that certain networks are compromised without ever looking at the networks in question.
Spam: If you have a network that is blasting out a bunch of spam, that indicatives an issue. It’s straightforward to set up a number of dummy email accounts to gather spam, and see which networks are used to blast millions of messages a day. If a vendor owns one of those networks, that’s a disheartening indication of their security prowess.
Stolen credentials: There are a bunch of forums where stolen credentials are traded, and if a specific vendor shows up with tons of their accounts and passwords for sale, that means their security probably leaves a bit to be desired.
Malware distribution/infected hosts: Another indication of security failure is Internet-facing devices which are compromised and then used to either host phishing sites or distribute malware, or both. If a vendor’s Internet site is infected and distributing malware, they likely have no idea what they are doing.
Public Breaches: We’ll discuss this later, but if your vendor is a public company or deals with consumers, they have to disclose breaches to their customers. Although you’ve likely gotten kind of numb to yet another breach notification, if it mentions a key vendor, that’s a concern. We’ll discuss what to do when a vendor is breached later in this series.
Security Best Practices: There are also other tells that a vendor knows a bit about security. Do they encrypt all traffic to/from their public sites? Do they authenticate their email with technologies like SPF or DKIM? Do they use secure DNS requests? To be clear, these aren’t conclusive indicators, but they can certainly give you a clue to how serious a vendor is about security.
So how do you gather all of this information? You can certainly do it yourself. Set up a bunch of honeypots and dedicate some internal resources to mining through the data. If you have tens of thousands of vendors and are heavily regulated, you might do exactly this. Otherwise you’ll likely rely on an external information provider to perform this analysis for you.
We covered some aspects of these services in our Ecosystem Risk Management Paper, but we’ll quickly summarize here. You need to figure out if you are looking for this vendor to provide a score and ranking of your other vendors, or whether you want the raw data on which vendors have issues (whether with botnets, malware distribution, etc.) to perform your own analysis and draw your own conclusions.
To make this kind of program feasible, without requiring another 25 bodies, let’s discuss risk tiering. Larger organizations may have thousands of vendors. It’s hard to consistently perform deep risk analysis of every vendor you do business with. But you also cannot afford only a cursory look at a few key vendors which present significant risk. So you can tier different vendors into separate risk tiers.
We’re simple folks, so we find any more than 3 or 4 tiers unwieldy. One of your first actions, after defining your IT security risk, is to nail down and build consensus on how to tier vendors by risk. Then your analyses and assessments will be based on the risk tier, and not some arbitrary decision on how deeply to look at each vendor. You could use tiers such as: critical, important, and basic. You could call them “unimportant” vendors but that might damage their self-esteem. The names don’t matter – you just need a set of tiers to group them between.
Critical vendors will get the full boat. A self-assessment, a means to externally evaluate their security posture, and possibly a site visit. You’ll scrutinize their self-assessments and have alerts triggered when something changes with them. We’ll go into what options you have to deal with vendor risk our the next post, but for now suffice it to say you’ll be all over your critical vendors, to make sure they are secure and have a plan to address any deficiencies.
Important vendors may warrant a cursory look at the self-assessment and the external evaluation. The security bar might need to be lower for these folks, because they present less risk to your organization. Basic vendors send in their self-assessment, and maybe you perform a simple vulnerability scan on their external web properties, just to check some box on an auditor’s checklist. That’s about all you’ll have time for with these folks.
Could you have more risk tiers? Absolutely. But the amount of work increases exponentially with each additional tier. That’s why we favor only using a handful, knowing that from a risk management standpoint the best bang for your buck will be from focusing on your critical vendors.
Tracking over Time
Obviously security is highly dynamic, so what is secure today might not be tomorrow. Likewise, what was a mess a month ago may not be so bad right now. Yet most vendor risk assessments provide a single point-in-time view, representing what things looked like at that moment. Such an assessment has limited value, because every organization can have the proverbial bad day, and inevitably some data sources provide false positives.
You want to evaluate each partner over time, and track their progress. Have they shown less infected hosts over time? How long does it take them to remediate devices participating in botnets? Has a vendor that traditionally did security well, suddenly started blasting spam and joining a bunch of botnets? Part of defining your vendor (IT) risk management program is figuring out which of the quantitative risk metrics most closely represent real risk to your organization, and need to be tracked and managed over time.
Alerting is also a key aspect of executing on the program. If a critical vendor shows up on a botnet, do you drop everything and address it with the partner? That question provides a nice segue to our next post, which will discuss ongoing monitoring and communication for your vendor (IT) risk management program.