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Data processing partner listing and owner assignment

Critical
High
Normal
Low

The organization must maintain a list of partners who have access to confidential information. System vendors and processors of personal data are listed separately from other stakeholders because they play an active role in the processing of data.

Connected other frameworks and requirements:
28. Processor
GDPR
44. General principle for transfers
GDPR
26. Joint controllers
GDPR
15.1.1: Information security policy for supplier relationships
ISO 27001
8.1.1: Inventory of assets
ISO 27001

Defining supplier types that can access confidential data

Critical
High
Normal
Low

We define in advance the types of suppliers with whom cooperation requires access to confidential information or their processing areas, and through this e.g. demands data processing contracts. Such supplier types can be, for example, IT services, logistics, financial management and IT infrastructure components.

Connected other frameworks and requirements:
15.1.1: Information security policy for supplier relationships
ISO 27001
ID.BE-1: Role in supply chain
NIST CSF
5.19: Information security in supplier relationships
ISO 27001

Criteria for high priority partners

Critical
High
Normal
Low

The organization has defined the certifications or standards required of key partners. Commonly recognized standards related to cyber security include:

  • ISO 27001 (information security management system)
  • SOC2 (general security, also called SSAE 16)
  • ISO 27701 (data protection management system)
  • ISO 27017 (cyber security in cloud services) or ISO 27018 (data protection in cloud services)
  • other popular e.g. NIST (general), CSA (cloud software), PCI DSS (card payments and data)

Certifications required from partners can make organization's own partner management more efficient and provide good evidence of a particular level of security or privacy of the partner.

Connected other frameworks and requirements:
15.1.1: Information security policy for supplier relationships
ISO 27001
ID.BE-1: Role in supply chain
NIST CSF
ID.SC-4: Audit suppliers and third-party partners
NIST CSF
5.19: Information security in supplier relationships
ISO 27001
7.2 (MIL1): Manage Third-Party Risk
C2M2

Minimum requirements for partner companies to gain access to different levels of information

Critical
High
Normal
Low

Minimum security requirements have been set for partner companies handling our confidential information and these have been included in supplier agreements. Requirements vary depending on how critical information the partner handles.

It makes sense for requirements to consist of rules and practices that are followed in your own organization. You can divide the requirement levels into low, medium and high risk suppliers.

Connected other frameworks and requirements:
15.1.1: Information security policy for supplier relationships
ISO 27001
15.1.3: Information and communication technology supply chain
ISO 27001
ID.BE-1: Role in supply chain
NIST CSF
5.21: Managing information security in the ICT supply chain
ISO 27001

Monitoring suppliers' compliance with security requirements

Critical
High
Normal
Low

A designated responsible person actively monitors the supplier's activities and services to ensure compliance with the security terms of the contracts and the proper management of security incidents.

Monitoring includes the following:

  • monitoring the promised service level
  • reviewing supplier reports and arranging follow-up meetings
  • regular organization of independent audits
  • follow-up of problems identified in audits
  • more detailed investigation of security incidents and review of related documentation
  • review of the supplier's future plans (related to maintaining the service level)
Connected other frameworks and requirements:
32. Security of processing
GDPR
15.1.1: Information security policy for supplier relationships
ISO 27001
15.2.1: Monitoring and review of supplier services
ISO 27001
ID.GV-2: Cybersecurity role coordination
NIST CSF
ID.SC-1: Cyber supply chain
NIST CSF

Criteria for suppliers of high priority data systems

Critical
High
Normal
Low

The organization has defined the certifications or standards required of key partners. Commonly recognized standards related to cyber security include:

  • ISO 27001 (information security management system)
  • SOC2 (general security, also called SSAE 16)
  • ISO 27701 (data protection management system)
  • ISO 27017 (cyber security in cloud services) or ISO 27018 (data protection in cloud services)
  • other popular e.g. NIST (general), CSA (cloud software), PCI DSS (card payments and data)

Certifications required from partners can make organization's own partner management more efficient and provide good evidence of a particular level of security or privacy of the partner.

Connected other frameworks and requirements:
14.1.1: Information security requirements analysis and specification
ISO 27001
15.1.1: Information security policy for supplier relationships
ISO 27001
15.2.1: Monitoring and review of supplier services
ISO 27001
ID.SC-1: Cyber supply chain
NIST CSF
ID.SC-4: Audit suppliers and third-party partners
NIST CSF
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