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Third-Party Risk Management Policy — visual preview
Policy

Third-Party Risk Management Policy

TPRM Governance & Vendor Lifecycle Management

Overview

Third-party relationships are a double-edged sword. They enable business growth and operational efficiency, but every vendor, partner, and supplier also introduces risk to your organization. A formal TPRM policy defines how your organization identifies, assesses, mitigates, and monitors risks associated with third parties throughout the entire relationship lifecycle. This policy template covers governance structures, risk tiering, contractual requirements, ongoing monitoring, and exit strategies.

Policy Scope and Governance

  • All third parties that access, process, store, or transmit organizational data
  • All third parties with connectivity to internal networks or systems
  • Vendors, suppliers, contractors, consultants, and business partners
  • Fourth parties and subcontractors used by your direct third parties
  • Governance structure: TPRM program owner, risk committee, and escalation paths
  • Policy review cadence: annually or after material program changes

Vendor Lifecycle Stages

StageActivitiesKey deliverables
PlanningIdentify need, define requirements, initial risk assessmentBusiness justification, preliminary risk rating
Due diligenceSecurity assessment, compliance review, financial stability checkCompleted questionnaire, SOC 2 report, references
ContractingNegotiate security terms, SLAs, breach notification, right to auditSigned contract with security schedule, DPA, BAA
OnboardingProvision access, integrate systems, baseline monitoringAccess records, integration documentation
Ongoing monitoringPeriodic reassessment, continuous monitoring, performance reviewsUpdated risk ratings, monitoring dashboards
OffboardingRevoke access, retrieve data, confirm deletion, final auditAccess revocation confirmation, data destruction certificate

Risk Tiering Methodology

Not all vendors are equal. Your cloud infrastructure provider and your office supply vendor present very different risk profiles, and your TPRM program should treat them accordingly. Tier vendors based on the type of data they access, the criticality of the service they provide, and whether they have direct connectivity to your systems. Critical-tier vendors need full assessments, regular reassessments, and continuous monitoring. Low-tier vendors can be managed through self-attestation and periodic checks. The goal is to spend your assessment resources where the risk is highest.

Contractual Security Requirements

Every vendor agreement should include security and privacy terms proportionate to the risk tier. At a minimum, require compliance with your security policies, incident notification within defined timelines, the right to audit or assess the vendor, data processing agreements where personal data is involved, and defined data handling and deletion obligations. For critical-tier vendors, include requirements for SOC 2 or ISO 27001 certification, annual penetration testing, and the ability to terminate for material security failures.

Incident Response and Exit Planning

  • Define how third-party incidents are reported, escalated, and managed within your own incident response framework
  • Require vendors to notify you of breaches within 24 to 72 hours depending on risk tier
  • Include the right to participate in or receive results of vendor incident investigations
  • Maintain data portability provisions so you can exit the relationship without data loss
  • Document offboarding procedures including access revocation timelines and data destruction verification
  • Conduct a post-exit review to confirm all obligations were met and lessons are captured

Frequently Asked Questions

How many vendors does a typical enterprise manage in a TPRM program?

Mid-size enterprises typically manage 200 to 500 third parties, while large enterprises can have 2,000 or more. The key is not assessing every vendor at the same depth but rather tiering them by risk and allocating resources accordingly.

What is concentration risk in TPRM?

Concentration risk occurs when too many critical services depend on a single vendor or a small number of vendors. If that vendor has an outage or breach, the blast radius across your organization is disproportionately large. Identify and manage concentration risk proactively.

How do we assess fourth-party risk?

Require your vendors to disclose their critical subcontractors and describe their own TPRM programs. Include flow-down requirements in contracts that obligate vendors to hold their subcontractors to similar security standards. Monitor fourth-party risk through vendor assessments and third-party risk rating services.

Should TPRM be centralized or distributed?

A hybrid model works best for most organizations. Centralize the TPRM program governance, tools, and risk methodology. Distribute the execution so that business units conduct initial due diligence with guidance from the central team. This balances control with agility.

What tools support TPRM programs?

GRC platforms like OneTrust, ServiceNow, and Archer provide TPRM modules. Third-party risk rating services like SecurityScorecard and BitSight offer continuous monitoring. Questionnaire exchange platforms like SIG and CAIQ standardize the assessment process.

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