Businesses must be vigilant in scrutinizing the risks associated with their third-party vendors. Even if your business is not directly targeted by a supply chain attack, it could still suffer financial loss and other impacts stemming from an attack on one of your vendors.
“In a supply chain attack, criminals use your trusted vendors as gateways to gain access to your organization,” said Jim Connell, Head of Global Supplier Services and Chief Procurement Officer with JPMorgan Chase & Co. “Hackers look for vulnerabilities within your vendor’s network systems or manipulating the code in third-party software that are interconnected to your organization. Once cybercriminals breach those systems or applications, they can access your network.”
As organizations heighten oversight and expand vendor due diligence protocols, they will need to address additional cybersecurity risks with software platforms and network systems. These vendor risk management considerations range from evaluating vendor preparedness to utilizing a third-party risk management service. One example, TruSight™, was founded in part by JPMorgan Chase & Co. and is designed to assess compliance by financial services industry suppliers with rigorous compliance and regulatory requirements.1 Following a thorough evaluation and review process, TruSight scrutinizes each supplier’s security practices and shares an assessment with multiple financial institutions.
Organizations should have an existing set of internal cyber controls and review existing vendor due diligence programs to ensure that they maintain your policies and procedures. If your organization doesn’t have a third-party risk management program, now is the time to establish safeguards to help protect employee and client data.
What needs to be protected varies based on your supplier relationship and the services they provide. For example, before JPMorgan Chase exchanges data with a third-party supplier, we assess their security and control environments to ensure suppliers do not introduce any unnecessary or unacceptable risk to our network.
Liability varies based on relationship. However, if a supplier processes, stores or has access to your data, you are ultimately responsible for protecting that information. If data you own is exposed when one of your suppliers is impacted by a data breach, your organization could suffer reputational and financial impact. To address these risks in your operations, identify liability impacts and specify responsibility in your vendor contracts to protect assets and stipulate when you are alerted if a breach occurs.
Vendor risk management should look at four categories: governance, network architecture, security hygiene and incident response. Here are 10 examples of strong vendor management questions you should consider asking your suppliers to mitigate risks to your network systems:
1. Does your vendor have a documented set of rules and procedures regulating the use of information?
2. Does your vendor have established policies and procedures for making changes to its own business processes, systems, networks and applications?
3. Are there robust controls throughout your vendor’s network infrastructure to help safeguard data and control access to network systems?
4. Does your vendor use encryption during the storage and transmission of sensitive data, and do they adequately protect encryption keys?
5. Is access to systems, applications and data monitored, logged and restricted to only authorized individuals with the minimal level of access necessary to complete job functions?
6. Is there a documented assessment process to identify, evaluate and report security vulnerabilities in your vendor’s network, systems or applications?
7. Are there controls to detect, prevent and alert in the event of network intrusion, either as insider threats or cybercriminals?
8. Will your vendor ensure that it will keep information systems’ security configurations and security patches up to date, and will they provide documentation to confirm?
9. Is there a documented incident response plan specifically for cybersecurity and data breaches, and does the vendor periodically test it for effectiveness?
10. Can the vendor ensure timely and orderly recovery of business, support processes, operations and technology components within an agreed-upon time frame following an incident?
At a high level, there are varying courses of action to take if a vendor answers no to any of the above questions:
Above all, if a supplier is unwilling to provide information about their control environment or remediate weaknesses in it, it’s probably best to find an alternate provider. Suppliers should care as much about their clients’ security as their own.
Overall, trust but verify that your vendors are keeping systems secure. And if gaps are found, ensure that they are escalated and addressed quickly to protect both your business and your suppliers.
© 2022 JPMorgan Chase & Co. All rights reserved. JPMorgan Chase Bank, N.A. Member FDIC. Visit jpmorgan.com/cb-disclaimer for disclosures and disclaimers related to this content.