The Importance of Vendor Risk Assessments

When buying a car, do you rush right out to the dealership and purchase the first car you find online? Or, do you perform your research and kick the tires, taking it for a test drive? Most of us will conduct our “due diligence” before buying a car and this includes researching the types of cars we’d like to buy, taking several test drives and checking out the mechanics of the car.  This same due diligence should be done for each of the vendors that you plan to use within your company in the form of a vendor risk assessment, regardless of their size. In fact, current vendors within your company should be reviewed every one to two years. For example, did someone review their financials? Do you know if you can get your data back if they go bankrupt? Do you know if they’re governed by laws outside of your country?

In larger companies, vendor risk assessments are typically performed by risk analysts, technology auditors, and information security folks, working in conjunction with the vendor management and procurement departments. In smaller companies, there may be a one or two person team responsible for conducting the vendor risk assessment. In many startup organizations, vendor risk assessments can be an afterthought. If you don’t perform a vendor risk assessment on your vendors today, take a look at this Risk Assessment Toolkit from the State of California’s Department of Technology, Information Security Office to get you started. There are many other sample templates and resources available online, as well. This is a great video on assessing technology vendor risk and security from Monte Ratzlaff, Security Manager, at UC Davis Health System, as he presents “Vendor Risks: Evaluating the Security of New Technology”.

At this point, some of you may think, “well, I don’t need a risk assessment on ____ vendor (insert name of vendor), they’re huge!”. Right? Wrong. I’ve worked with technology audit professionals on the review of hundreds (if not thousands) of technology vendors and yes, some of those “huge” vendors can have red flags for you and your company. Whether it’s the fact that they’re in the middle of a merger, they’re outsourcing their development team, or they don’t have enough insurance to cover you in the event of a breach, the scenarios can vary, depending upon what your company considers a risk and how that risk is categorized. If you need a tool to understand risks associated with the project you’re considering, take a look at this post by BrightHub PM, it has a lot of great info on creating a risk matrix and how to use it.

In the end, just think of a vendor risk assessment as a way to kick the tires of the prospective vendor before buying a lemon whose carburetor is going to explode once you drive it off the lot. If you’re interested in performing a proof of concept or proof of technology with the vendor once they pass the vendor risk assessment, check out a former post that I wrote on this topic and good luck!

Are You Using “Test” Data in the Cloud?

CloudSecurityKeyhole_468Yes, you read that correctly. The word test is in quotation marks, as in “is it really test data that you have in the vendor’s cloud?”. Astonishingly enough, at least 85% of financial institutions are using live data in their test environments [1]. Could this be you and are you protecting your organization against a data breach effectively?

When a cloud technology vendor makes an offhand remark like, “yeah, we can create a test environment for you and load your test data into the cloud while we work through a Non-Disclosure or Proof of Concept agreement with your legal team”, be afraid. Be very afraid.

Now, I’m not knocking the technology vendors. In fact, to them this is a natural part of the engagement. What you have to be aware of is whether your company’s test data is truly “test data” or not. For example, if you’re in the financial or healthcare sectors where a data breach could expose Personal Health Information (PHI) or Personally Identifiable Information (PII), you should understand your test data thoroughly.

Once you understand your test data, think about putting together a more robust agreement with the vendor besides a Non-Disclosure or Proof of Concept agreement. Non-Disclosure and Proof of Concept agreements typically do not contain the language to protect your company against a data breach. A Master Services Agreement or Subscription Services Agreement should be reviewed by your legal or contracts team to determine if your company will be protected while using the vendor’s cloud if there is a breach with regard to the test data.

Karen Hsu of Informatica explains that “because data stored in a cloud-based ‘sandbox’ environment for testing purposes is vulnerable, it should be masked to protect sensitive information” [2]. She recommends using an automated masking tool to assist with the protection of your data. Regardless of what tools you use, your “test” data should be understood before loading any of it into a vendor’s cloud environment.

References:

[1] Dark Reading News. (2010, March). Live Data In Test Environments Is Alive And Well — And Dangerous. Retrieved from http://www.darkreading.com/risk/live-data-in-test-environments-is-alive-and-well—-and-dangerous/d/d-id/1133220?

[2] Hsu, Karen. (2013, March). Masking Test Data in the Cloud. Retrieved from http://www.bankinfosecurity.com/interviews/masking-test-data-in-cloud-i-1822

Preventing a Cloud Data Breach

Breach-WordsMany of you reading this have not (thankfully) experienced a cloud data breach with your technology vendors. However, a cloud data breach is always on the forefront as more businesses embrace cloud technology.

What are the chances that your organization could have a cloud data breach? According to research performed by the Ponemon Institute most companies will have small data breaches rather than large data breaches [1]. Does this mean you can breathe easy? Not so fast. For those of you in the retail and public sectors, your likelihood of experiencing a data breach is higher than those of you in the transportation, communications or even financial sectors [1]. However, each sector is impacted and the average cost of managing a data breach per organization is approximately $5.9 million with the average cost spent per breached record at $201 [1]. 41% of the respondents surveyed in the Ponemon Institute’s research said that malicious or criminal attacks were responsible for their data breach and 31% said that employee negligence was the root cause [1].

With those facts in mind, how do you prevent a cloud data breach?  The Ponemon Institute’s research states that “the most profitable investments companies can make seem to be an incident response plan, a strong security posture, the involvement of business continuity management and the appointment of a CISO with enterprise-wide responsibility” [1]. In addition to this, asking potential (and current) vendors about their cloud technology is also key. This is a nice article written by Julie Lopez that focuses on the right questions businesses should ask their technology vendors.  Her article mainly focuses on health care, but makes a lot of great points that everyone should read regarding vendor management. Speed to market is critical these days and cloud technology gives organizations this benefit. However, this speed to market mentality must be tempered with a sound risk mitigation strategy in order to reduce the chances of a costly data breach.

References

[1] Ponemon Institute. (2014, May). 2014 Cost of Data Breach Study: United States. Retrieved from http://essextec.com/sites/default/files/2014%20Cost%20of%20Data%20Breach%20Study.PDF