Shared Assessments CTPRP - Certified Third-Party Risk Professional (CTPRP)

In the ‘Defense in Depth’ security model, the innermost layer typically focuses on protecting the most sensitive and critical assets, which are often categorized as 'Private internal'. This layer includes security controls and measures that are designed to safeguard the core, confidential aspects of an organization's infrastructure and data. It encompasses controls such as access controls, encryption, and monitoring of sensitive systems and data to prevent unauthorized access and ensure data integrity and confidentiality. The 'Private internal' layer is crucial for maintaining the security of critical information and systems that are essential to the organization's operations and could have the most significant impact if compromised. Implementing robust security measures at this layer is vital for mitigating risks associated with physical access to critical infrastructure and sensitive information.

References:

Security frameworks and standards, including NIST SP 800-53 (Security and Privacy Controls for Federal Information Systems and Organizations) and the SANS Institute's guidelines on implementing 'Defense in Depth', provide detailed recommendations on securing the innermost layers of an organization's information systems.

Publications such as "Physical Security Principles" by ASIS International offer insights into best practices for securing the private internal layer, including access control systems, surveillance, and intrusion detection mechanisms.

A risk register is a tool that records and tracks the identified risks, their probability, impact, status, and mitigation actions throughout the life cycle of a third-party relationship1. A risk register typically includes the following components2:

A unique identifier for each risk

A description of the risk and its source

A rating or grading of the risk according to a risk assessment table or hierarchy

An assessment of the impact and likelihood the risk will occur and the possible seriousness

An outline of proposed mitigation actions and assignment of risk owner

A status update on the risk and the progress of the mitigation actions

A target date for resolving the risk or closing the action A vendor inventory is a list of all the third parties that a banking organization engages with, along with relevant information such as the type, scope, and nature of the services provided, the contract terms and conditions, the performance indicators, and the risk ratings3. A vendor inventory is not a component of a risk register, but rather a separate document that supports the planning and due diligence phases of the third-party relationship life cycle. A vendor inventory may be prioritized by contract value, but also by other criteria such as the criticality of the service, the risk level of the vendor, and the strategic importance of the relationship. References:

1: Third-Party Risk Management (TPRM): Final Interagency Guidance, KPMG, June 2023

2: What Is Third-Party Risk Management (TPRM)? 2024 Guide, UpGuard, January 2024

3: Third-Party Risk Management Guidance, OCC Bulletin 2023-29, October 2023

[4]: Certified Third Party Risk Professional (CTPRP) Study Guide, Shared Assessments, 2023

[5]: Best Practices Guidance for Third-Party Risk, GARP, February 2023

Peer code reviews are an essential part of the software development lifecycle (SDLC) process, as they help to improve the quality, security, and maintainability of the code. Peer code reviews involve having other developers review the code written by a developer before it is merged into the main branch or deployed to production. Peer code reviews can help to identify and fix errors, bugs, vulnerabilities, performance issues, coding standards violations, design flaws, and other issues that may affect the functionality or usability of the software. Peer code reviews also facilitate knowledge sharing, collaboration, and feedback among the development team, which can enhance the skills and productivity of the developers123.

The other options are not as likely to be included in the SDLC process, as they are either performed at different stages or not directly related to the development of the software. Scheduling the frequency of automated vulnerability scans and defining the scope of annual penetration tests are more related to the security testing and monitoring of the software, which are usually done after the development phase or as part of the maintenance phase. Scanning for data input validation in production is also a security measure that is done after the software is deployed, and it is not a good practice to rely on production testing alone, as it may expose the software to potential attacks or data breaches. Data input validation should be done during the development and testing phases, as well as in production123. References:

What is SDLC? - Software Development Lifecycle Explained - AWS

Software Development Life Cycle (SDLC) - GeeksforGeeks

What Is the Software Development Life Cycle? SDLC Explained | Coursera

When calculating residual risk, the best practice for an assessor is to adjust the vendor risk rating based on the changes to the risk level after analyzing the findings and considering the effectiveness of mitigating controls. Residual risk refers to the level of risk that remains after controls are applied to mitigate the initial (inherent) risk. By evaluating the findings from a third-party assessment and factoring in the mitigating controls implemented by the vendor, the assessor can more accurately determine the remaining risk level. This adjusted risk rating provides a more realistic view of the vendor's risk profile, aiding in informed decision-making regarding risk management and vendor oversight.

References:

The concept of residual risk calculation is discussed in risk management frameworks such as ISO 31000 (Risk Management - Guidelines), which guides the assessment and treatment of risks.

The "Third-Party Risk Management Guide" by ISACA outlines the process of assessing and managing risks associated with third parties, including the calculation of residual risk.

Fourth-Nth party risk refers to the potential threats and vulnerabilities associated with the subcontractors, vendors, or service providers of an organization’s direct third-party partners. This can create a complex network of dependencies and exposures that can affect the organization’s security, data protection, and business resilience. To manage this risk effectively, organizations should conduct comprehensive due diligence on their extended vendor and supplier network, and include contractual stipulations that require notification and approval for any subcontracting activities. This way, the organization can ensure that the subcontractors meet the same standards and expectations as the direct third-party partners, and that they have adequate controls and safeguards in place to protect the organization’s data and systems. Additionally, the organization should monitor and assess the performance and compliance of the subcontractors on a regular basis, and update the contract provisions as needed to reflect any changes in the risk environment. References:

Understanding 4th- and Nth-Party Risk: What Do You Need to Know?

Best Practices for Fourth and Nth Party Management

Fourth-Party Risk Management: Best Practices

Due diligence is the process of evaluating the risks and opportunities associated with a potential or existing third-party vendor. Due diligence can vary in scope and depth depending on the level of risk that the vendor poses to the organization. Lower risk vendors are those that have minimal impact on the organization’s operations, reputation, or compliance, and that do not handle sensitive or confidential data or systems. For lower risk vendors, conducting due diligence may involve accepting the service provider’s self-assessment questionnaire responses as sufficient evidence of their capabilities, performance, and compliance. A self-assessment questionnaire is a tool that allows the vendor to provide information about their organization, services, processes, controls, and policies. The organization can use the questionnaire to verify the vendor’s identity, qualifications, references, and certifications, and to assess the vendor’s alignment with the organization’s standards and expectations. Accepting the vendor’s self-assessment questionnaire responses as the primary source of due diligence can save time and resources for the organization, and can also demonstrate trust and confidence in the vendor. However, the organization should also ensure that the questionnaire is comprehensive, relevant, and updated, and that the vendor’s responses are accurate, complete, and consistent. The organization should also reserve the right to request additional information or documentation from the vendor if needed, and to conduct periodic reviews or audits of the vendor’s performance and compliance.

The other options do not best describe conducting due diligence of a lower risk vendor, because they either involve more extensive or rigorous methods of due diligence, or they are not directly related to due diligence. Preparing reports to management regarding the status of third party risk management and remediation activities is an important part of monitoring and managing the vendor relationship, but it is not a due diligence activity per se. Reviewing a service provider’s self-assessment questionnaire and external audit report(s) is a more thorough way of conducting due diligence, but it may not be necessary or feasible for lower risk vendors, especially if the external audit report(s) are not readily available or relevant. Requesting and filing a service provider’s external audit report(s) for future reference is a good practice for maintaining documentation and evidence of due diligence, but it is not a due diligence activity itself.

References:

Third Party Risk Management (TPRM) | Shared Assessments

Vendor Due Diligence Strategy Guide and Checklist | Prevalent

Vendor due diligence: a practical guide and checklist

An organization’s Ethics and Code of Conduct Program is a set of policies, procedures, and practices that define the expected standards of behavior and ethical values for all employees and stakeholders. A key component of such a program is a disciplinary process that outlines the consequences and actions for violating the code of conduct or any other relevant policies. A disciplinary process helps to enforce the code of conduct, deter unethical behavior, and protect the organization’s reputation and integrity. A disciplinary process should include clear criteria for determining the severity and frequency of violations, the roles and responsibilities of the parties involved, the steps and timelines for investigation and resolution, and the range of sanctions and remedies available. A disciplinary process should also be fair, consistent, transparent, and respectful of the rights and dignity of the accused and the accuser. A disciplinary process may involve formal termination or change of status of the employee, depending on the nature and impact of the violation. Therefore, option B is a correct component of an organization’s Ethics and Code of Conduct Program.

The other options are not necessarily components of an Ethics and Code of Conduct Program, although they may be related or supportive of it. Option A, participation in the company’s annual privacy awareness program, is more likely to be a component of a Privacy Program, which is a specific area of ethics and compliance that deals with the protection and use of personal information. Option C, signing acknowledgement of Acceptable Use policy for use of company assets, is more likely to be a component of an Information Security Program, which is another specific area of ethics and compliance that deals with the safeguarding and management of data and systems. Option D, a process to conduct periodic access reviews of critical Human Resource files, is more likely to be a component of an Internal Control Program, which is a general area of ethics and compliance that deals with the design and implementation of controls to ensure the reliability and accuracy of financial and operational information. References:

1: Creating an Effective Code of Conduct (and Code Program) - Corporate Compliance Insights

2: Code of Conduct & Ethics (Examples and Best Practices) - Status.net

3: Why Have a Code of Conduct - Free Ethics & Compliance Toolkit

4: “Code of Ethics” and “Code of Conduct” - GeeksforGeeks

5: Six Tips on How to Implement a Strong Ethics Program - KnowledgeLeader

Remote monitoring of HVAC, Smoke, Fire, Water, or Power systems best reflects components of an environmental controls testing program. These systems are critical to ensuring the physical security and operational integrity of data centers and IT facilities. Environmental controls testing programs are designed to verify that these systems are functioning correctly and can effectively respond to environmental threats. This includes monitoring temperature and humidity (HVAC), detecting smoke or fire, preventing water damage, and ensuring uninterrupted power supply. Regular testing and monitoring of these systems help prevent equipment damage, data loss, and downtime due to environmental factors.

References:

Environmental control standards such as ISO/IEC 27001 (Information Security Management) include requirements for the testing and monitoring of physical and environmental security controls.

The "Data Center Operations Manual" by the Uptime Institute provides detailed guidelines on the testing and maintenance of environmental control systems to ensure the resilience and reliability of data center operations.

Notification obligations in incident response are the legal or contractual duties to inform relevant parties about a security breach or incident that affects their data or systems. These obligations may vary depending on the type, scope, and impact of the incident, as well as the jurisdiction, industry, and contractual agreements involved. The factors that are most likely to trigger notification obligations are:

Regulatory requirements: Different laws and regulations may impose different notification obligations on organizations that experience or cause a security incident. For example, the General Data Protection Regulation (GDPR) requires data controllers to notify the supervisory authority within 72 hours of becoming aware of a personal data breach, and to notify the affected data subjects without undue delay if the breach poses a high risk to their rights and freedoms1. Similarly, the Computer-Security Incident Notification Rule requires banks and their service providers to notify their primary federal regulator as soon as possible, but no later than 36 hours, after a computer-security incident that materially disrupts, degrades, or impairs their operations, services, or customers2.

Data classification or sensitivity: The type and sensitivity of the data involved in a security incident may also affect the notification obligations. For example, if the data contains personally identifiable information (PII), health information, financial information, or other confidential or sensitive information, the organization may have to notify the data owners, regulators, law enforcement, or other stakeholders about the incident and the potential risks to their privacy or security3. The data classification or sensitivity may also determine the content and timing of the notification, as well as the appropriate communication channels to use.

Contractual terms: The contractual agreements between an organization and its third-party vendors or service providers may also specify the notification obligations in case of a security incident. For example, the contract may define the roles and responsibilities of each party, the notification procedures and timelines, the information to be shared, the remediation actions to be taken, and the penalties or liabilities for breach of contract. The contractual terms may also reflect the regulatory requirements or industry standards that apply to the organization or the third party.

The factor that is least likely to trigger notification obligations is:

Encryption of data: Encryption of data is a security measure that protects the data from unauthorized access, modification, or disclosure. Encryption of data may reduce the impact or severity of a security incident, as it may prevent or limit the exposure of the data to malicious actors. However, encryption of data does not eliminate the notification obligations, as the organization still has to assess the nature and extent of the incident, and determine whether the encryption was effective or compromised. Moreover, encryption of data may not be sufficient to protect the data from other types of threats, such as deletion, corruption, or ransomware. Therefore, encryption of data is not a factor that influences the notification obligations in incident response.

References:

1: GDPR Article 33: Notification of a personal data breach to the supervisory authority

2: Computer-Security Incident Notification Rule

3: Third-Party Incident Management (TPIM): How to Balance IRPs with Third Parties

: [Improving Third-Party Incident Response]

: [Third-Party Incident Response Playbook]

: [Does Encryption Protect You From a Data Breach?]

 This answer is correct because a change at outsourcer due to merger and acquisition (M&A) is the least likely indicator to trigger a reassessment of an existing vendor. This is because the outsourcer is not the direct vendor of the organization, but rather a third party that the vendor uses to perform some of its services. Therefore, the impact of the change at the outsourcer on the vendor’s performance and risk level may not be significant or immediate. However, the other indicators (A, B, and C) are more likely to trigger a reassessment of an existing vendor, as they directly affect the vendor’s operations, capabilities, and compliance status. For example:

A change in vendor location or use of new fourth parties may introduce new risks such as geopolitical, regulatory, or cybersecurity risks that need to be evaluated and mitigated.

A change in scope of existing work may alter the vendor’s access to the organization’s data or systems, which may require additional security measures and controls to protect the confidentiality, integrity, and availability of the information assets.

A change in regulation that impacts service provider requirements may impose new obligations or standards on the vendor that need to be verified and monitored to ensure compliance and avoid penalties or fines. References:

How to Conduct a Successful Vendor Risk Assessment in 9 Steps, Case IQ

Why You Need to Reassess Vendor Risk on an Ongoing Basis, ThirdPartyTrust

Vendor Assessment and Evaluation Guide, Smartsheet