|
+Third-Party Exit Obligations Management |
Third-Party Exit Obligations ManagementDescriptionMechanisms exist to identify and address applicable legal, regulatory, contractual, licensing, records retention and other compliance obligations associated with the cessation and transition of third-party services.Possible Solutions & ConsiderationsMicro-Small Business (<10 staff) / BLS Firm Size Classes 1-2∙ Check contract and license terms before switching vendors∙ Retain required records before account closure Small Business (10-49 staff) / BLS Firm Size Classes 3-4∙ Legal/compliance review of vendor exits∙ Records retention checklist for vendor-held data Medium Business (50-249 staff) / BLS Firm Size Classes 5-6∙ Compliance obligations register consulted during exit planning∙ Legal review of licensing and data ownership ∙ Regulatory notification assessment Large Business (250-999 staff) / BLS Firm Size Classes 7-8∙ C-SCRM exit procedure with legal, compliance and privacy review∙ Regulatory notification tracking ∙ Legal hold coordination Enterprise (> 1,000 staff) / BLS Firm Size Class 9∙ Enterprise exit governance with legal, compliance, privacy and records management sign-off∙ Regulatory obligation mapping for critical provider changes (e.g., DORA, sector regulators) ∙ GRC tracking of exit-related obligations SCR-CMMLevel 0 Not PerformedPractices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.Level 1 Performed InformallyThird-Party Management (TPM) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:▪ Policies, standards & procedures associated with TPM domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Third-party management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices. Level 2 Planned TrackedThird-Party Management (TPM) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:▪ Policies and standards associated with TPM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with TPM domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with TPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Third-party management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. Level 3 Well DefinedThird-Party Management (TPM) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:▪ Policies and standards associated with TPM domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with TPM domain capabilities are well-documented and kept current by process owners. ▪ A procurement team, or similar function, is appropriately staffed and supported to implement and maintain TPM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of third-party management operations (e.g., TPRM risk management solution and vendor management solution). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with TPM domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). Level 4 Quantitatively ControlledUtilize SCR-CMM Level 3 criteria definitions:▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define. Level 5 Continuously ImprovingUtilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define. 1. Übersicht
1.1 Referenzen1.2 Identifizierte Anforderungen1.3 Zugehörige Regulierungen2. Identifizierte Anforderungen
3. Zugehörige Regulierungen
Verknüpfte Vorgänge
|