CTPRP Certified Third-Party Risk Professional (CTPRP) Questions and Answers

Data privacy policies are documents that outline how an organization collects, uses, stores, shares, and protects personal information from its customers, employees, partners, and other stakeholders1. Data privacy policies should address the following key elements2:

• The purpose and scope of data collection and processing
• The legal basis and consent mechanism for data processing
• The types and categories of personal data collected and processed
• The data retention and deletion policies and practices
• The data security and encryption measures and standards
• The data sharing and disclosure practices and procedures, including the use of third parties and cross-border transfers
• The data access, correction, and deletion rights and requests of individuals
• The data breach and incident response and notification procedures and responsibilities
• The data protection officer and contact details
• The data privacy policy review and update process and frequency

Procedures for configuration settings in identity access management are typically not addressed within data privacy policies, as they are more related to the technical and operational aspects of data security and access control. Identity access management (IAM) is a framework of policies, processes, and technologies that enable an organization to manage and verify the identities and access rights of its users and devices3. IAM configuration settings determine how users and devices are authenticated, authorized, and audited when accessing data and resources. IAM configuration settings should be aligned with the data privacy policies and principles, but they are not part of the data privacy policies themselves. IAM configuration settings should be documented and maintained separately from data privacy policies, and should be reviewed and updated regularly to ensure compliance and security. References: 1: What is a Data Privacy Policy? | OneTrust 2: Privacy Policy Checklist: What to Include in Your Privacy Policy 3: What is identity and access management? | IBM : [Identity and Access Management Configuration Settings] : [Why data privacy and third-party risk teams need to work … - OneTrust] : [Privacy Risk Management - ISACA] : [What Every Chief Privacy Officer Should Know About Third-Party Risk …]

In the context of Third-Party Risk Management (TPRM), problems or issues do not inherently lead to systemic failures but are indicative of underlying faults within processes or systems that could potentially result in incidents. Problem or issue management is a critical component of TPRM, focusing on identifying, classifying, and managing the root causes of incidents to prevent their recurrence and mitigate their impact. Effective problem management involves not just managing workarounds or known errors, but also implementing permanent fixes to eliminate the root causes of problems. By addressing the underlying issues, organizations can enhance their operational resilience and reduce the likelihood and impact of future incidents. This approach aligns with best practices in TPRM, emphasizing proactive risk identification, assessment, and mitigation to safeguard against potential disruptions in the supply chain and third-party ecosystems.

References:

• Best practices in TPRM suggest a structured approach to problem and issue management, including identification, assessment, prioritization, and resolution of root causes, as outlined in frameworks such as ISO 31000 (Risk Management) and NIST SP 800-53 (Security and Privacy Controls for Federal Information Systems and Organizations).
• Learning resources such as the "Third Party Risk Management Program Playbook" from Shared Assessments and the "Third-Party Risk Management Guide" from ISACA provide comprehensive guidelines on implementing effective problem and issue management processes within a TPRM program.

The primary objective of a third party risk assessment is to validate that the vendor/service provider has adequate controls in place based on the organization’s risk posture. A third party risk assessment (also known as supplier risk assessment) quantifies the risks associated with third-party vendors and suppliers that provide products or services to your organization1. This assessment is useful for analyzing both new and ongoing supplier relationships. The growing risk of supply chain attacks makes it critical to conduct thorough and regular risk assessments of your third parties. A third party risk assessment helps you identify, measure, and mitigate the potential risks that your third parties pose to your organization, such as data breaches, cyberattacks, compliance violations, operational disruptions, reputational damage, or financial losses. A third party risk assessment also helps you align your third party risk management (TPRM) program with your organization’s risk appetite, policies, standards, and procedures. A third party risk assessment typically involves the following steps1:

• Scoping: Define the scope of the assessment based on the type, nature, and criticality of the third party relationship. Determine the relevant risk domains, such as security, privacy, compliance, business continuity, etc.
• Data collection: Gather information from the third party using various methods, such as questionnaires, surveys, interviews, audits, tests, or evidence reviews.
• Analysis: Analyze the data collected and compare it with your organization’s risk criteria, benchmarks, and best practices. Identify any gaps, weaknesses, or issues in the third party’s controls, processes, or performance.
• Reporting: Document the findings and recommendations of the assessment in a clear and concise report. Communicate the results to the relevant stakeholders, such as senior management, business owners, or regulators.
• Remediation: Follow up with the third party to ensure that they implement the necessary actions to address the identified risks. Monitor and track the progress and effectiveness of the remediation plan.
• Review: Review and update the assessment periodically or whenever there are significant changes in the third party relationship, the risk environment, or the regulatory requirements.

The other statements are not the primary objective of a third party risk assessment, although they may be related or secondary objectives. Assessing the appropriateness of non-disclosure agreements regarding the organization’s systems/data is a legal objective that may be part of the contract negotiation or review process. Determining the scope of the business relationship is a strategic objective that may be part of the vendor selection or due diligence process. Evaluating the risk posture of all vendors/service providers in the vendor inventory is a holistic objective that may be part of the vendor risk management or governance process. References:

• 1: Third-Party Risk Assessment: A Practical Guide - BlueVoyant
• : What Is Third-Party Risk Management (TPRM)? 2024 Guide | UpGuard
• : What is Third-Party Risk Management? | Blog | OneTrust

This answer is the best approach because it aligns with the principles of third-party risk management, which include ensuring compliance with company policies, contractual obligations, and regulatory requirements. By asking the vendor to replace the subcontractor, the company is exercising its right to terminate or modify the relationship if the vendor fails to meet the agreed-upon standards or poses unacceptable risks. This also minimizes the potential impact of the vendor’s non-compliance on the company’s reputation, operations, and data security. The other options are less effective because they either ignore the issue, compromise the company’s policy, or rely on the vendor’s self-assessment without verification. References:

• Third Party Risk Management Framework, Module 3: Program Governance, Section 3.2: Policies and Procedures, p. 14
• Third Party Risk Management Framework, Module 4: Program Components, Section 4.3: Contracting, p. 24
• Third Party Risk Management Framework, Module 5: Program Implementation, Section 5.2: Ongoing Monitoring, p. 32
• Best-Practices Guidance for Third-Party Risk, Section: Defend Against Privileged User Risks, p. 2
• Five Best Practices to Manage and Control Third-Party Risk, Section: Best Practices for Controlling Third-Party Vendor Risks, p. 3

A network access policy is a set of rules and conditions that define how authorized users and devices can access the network resources and services of an organization. It typically includes the following elements12:

• Firewall settings: These are the rules that control the incoming and outgoing network traffic based on the source, destination, protocol, and port of the packets. Firewall settings help to protect the network from unauthorized or malicious access, and to enforce the network security policy of the organization.
• Unauthorized device detection: This is the process of identifying and preventing unauthorized devices from accessing the network. Unauthorized devices can pose a security risk to the network, as they may not comply with the security standards and policies of the organization, or they may be compromised by malware or hackers. Unauthorized device detection can be done by using various methods, such as network access control (NAC), network admission control (NAC), or 802.1X authentication.
• Remote access: This is the ability of authorized users to access the network resources and services of the organization from a remote location, such as a home office, a hotel, or a public hotspot. Remote access can be provided by using various technologies, such as virtual private networks (VPNs), remote desktop services (RDS), or remote access services (RAS). Remote access requires a secure and reliable connection, and it must comply with the network access policy of the organization.
• Website privacy consent banners: These are the messages that appear on websites to inform the visitors about the use of cookies and other tracking technologies, and to obtain their consent for such use. Website privacy consent banners are part of the website privacy policy, which is a legal document that discloses how the website collects, uses, and protects the personal data of the visitors. Website privacy consent banners are not related to the network access policy of the organization, as they do not affect how the users and devices can access the network resources and services of the organization.

Therefore, the correct answer is C. Website privacy consent banners, as they are typically not included within the scope of an organization’s network access policy. References:

• 1: Network Policy Server (NPS) | Microsoft Learn
• 2: Network Access Policy | University Policies

The best approach to address the conflict between the vendor’s legal obligations to retain data for tax purposes and the company’s policy to require data return or destruction at contract termination is A. Determine if a policy exception and approval is required, and require that data safeguarding obligations continue after termination. This approach recognizes that the vendor may have valid reasons to retain some data for a certain period of time, and that the company may have flexibility to grant exceptions to its policy under certain circumstances. However, this approach also ensures that the company maintains oversight and control over the data that the vendor retains, and that the vendor continues to comply with the data safeguarding obligations, such as encryption, access control, audit, and breach notification, until the data is returned or destroyed. This approach balances the interests and risks of both parties, and minimizes the potential for data breaches, misuse, or loss.

The other approaches are not the best ways to address the conflict, as they may create more problems or risks for either party. B. Change the risk rating of the vendor to reflect a higher risk tier. This approach does not resolve the conflict, but rather shifts the responsibility to the company to manage the increased risk of the vendor retaining the data. Changing the risk rating may also affect the contract terms, such as pricing, service level agreements, or liability clauses, and may require renegotiation or termination of the contract. C. Insist the vendor adheres to the policy and contract provisions without exception. This approach is too rigid and may not be feasible or reasonable for the vendor, especially if they have legal obligations to retain the data. This approach may also damage the relationship and trust between the parties, and may lead to disputes or litigation. D. Conduct an assessment of the vendor’s data governance and records management program. This approach is too time-consuming and costly, and may not be necessary or relevant for the conflict. Conducting an assessment may provide some assurance about the vendor’s data practices, but it does not address the underlying issue of the conflicting data retention requirements. Moreover, conducting an assessment may not be possible or appropriate during the contract negotiation process, as it may require access to the vendor’s systems, data, or personnel. References:

• : Best Practices for Data Destruction - ed
• : CHALLENGES AND RISKS INVOLVED WITH DATA RETENTION - DataOlogie
• : Third-Party Risk Management: Final Interagency Guidance
• : Ensuring Data Protection for Third Parties: Best Practices | UpGuard Blog

 Personal information is any information that can be used to identify an individual, either directly or indirectly, such as name, address, email, phone number, ID number, etc. Personal data is a term used in some jurisdictions, such as the European Union, to refer to personal information that is subject to data protection laws and regulations. However, the scope and definition of personal data may vary depending on the jurisdiction and the context. For example, the GDPR defines personal data as “any information relating to an identified or identifiable natural person” and includes online identifiers, such as IP addresses, cookies, or device IDs, as well as special categories of data, such as biometric, genetic, health, or political data. On the other hand, the US does not have a single federal law that regulates personal data, but rather a patchwork of sector-specific and state-level laws that may have different definitions and requirements. For example, the California Consumer Privacy Act (CCPA) defines personal information as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household” and excludes publicly available information from its scope. Therefore, from a privacy perspective, it is important to understand the different legal definitions and obligations that may apply to personal information or personal data depending on the jurisdiction and the context of the data processing activity. References:

• GDPR personal data – what information does this cover?
• Personal Information, Data Classification, Life Cycle and Best Practices
• 5 Types of Data Classification (With Examples)

According to the Shared Assessments CTPRP Study Guide, the business unit relationship owner is the primary point of contact for the third party and is responsible for ensuring that the third party meets the contractual obligations and service level agreements. The business unit relationship owner is also involved in the third party risk assessment process and the remediation plan approval. Therefore, a meeting should be scheduled with the business unit relationship owner before sharing the findings and remediation plans with the third party, as they have the authority and accountability to approve or reject the plans. The other options are not necessarily involved in the remediation plan approval, although they may have other roles in the third party risk management lifecycle. References:

• Shared Assessments CTPRP Study Guide, page 9, section 1.3.2
• The Third-Party Vendor Risk Management Lifecycle, section on Supplier Onboarding & Risk Monitoring
• Remediation vs. Mitigation, section on Remediation

 Risk culture is the term used to describe the collective way that an organization thinks about, manages, and responds to risk. It is influenced by the organization’s values, beliefs, norms, and practices, as well as the external environment and stakeholders. Risk culture affects how employees perceive, communicate, and act on risk issues, and how they balance risk and reward in their decision making. A strong risk culture is one that supports the organization’s strategic objectives, fosters accountability and transparency, and promotes learning and improvement. A weak risk culture is one that undermines the organization’s risk management framework, creates silos and conflicts, and exposes the organization to excessive or unnecessary risks. References:

• Shared Assessments CTPRP Study Guide, page 13, section 2.1.1
• GARP Best Practices Guidance for Third Party Risk, page 5, section 2.1
• Organizational culture | Definition, Benefits and Challenges

Single Sign-On (SSO) is a convenient and efficient way of authenticating users across multiple applications and platforms with a single set of credentials. However, it also poses some security risks and challenges that need to be considered and addressed. One of the main disadvantages of SSO is that it creates a single point of failure and a high-value target for attackers. If an end-user credential is compromised, the attacker can gain access to all the systems and resources that the user is authorized to access, potentially causing significant damage and data breaches. Therefore, SSO requires strong security measures to protect the user credentials, such as encryption, multifactor authentication, password policies, and monitoring. Additionally, SSO users need to be aware of the risks and follow best practices to safeguard their credentials, such as using strong and unique passwords, changing them regularly, and avoiding phishing and social engineering attacks. References:

• 1: What are the disadvantages of single sign-on authentication? - Information Security Stack Exchange
• 2: Single Sign-On Disadvantages: 6 Advantages and Disadvantages [What You Need to Know] - Mostly Blogging
• 3: SSO Security Risks: The Drawbacks of SSO (And What Can You Do About it) - Zluri

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 partners12. After contract signing and on-boarding due diligence is complete, the most important type of contract provision to manage Fourth-Nth party risk is subcontractor notice and approval. This provision requires the third party to inform the organization of any subcontracting arrangements and obtain the organization’s consent before engaging any Fourth-Nth parties345. This provision enables the organization to have visibility and control over the extended network of suppliers and service providers, and to assess the potential risks and impacts of any outsourcing decisions. Subcontractor notice and approval also helps the organization to ensure that the Fourth-Nth parties comply with the same standards and expectations as the third party, and to hold the third party accountable for the performance and security of the Fourth-Nth parties345. References:

• 1: Understanding 4th- and Nth-Party Risk: What Do You Need to Know? | Mitratech
• 2: Understanding 4th- and Nth-Party Risk: What Do You Need to Know? | Mitratech Holdings, Inc - JDSupra
• 3: First, 2nd , 3rd , 4th, 5th Parties: How to Measure the Tiers of Risk
• 4: Managing 4th Party Risk with Vendor Insurance Verification - Evident ID
• 5: How to Write Fourth-Party Vendor Requirements Into the Contract - Venminder

Controls evaluation is the process of verifying and validating the effectiveness of the controls implemented by the third party to mitigate the identified risks. It involves reviewing the evidence provided by the third party, such as policies, procedures, certifications, attestations, or test results, to determine if the controls are adequate, consistent, and compliant with the requirements and standards of the organization. Controls evaluation also involves analyzing the assessment results to identify any gaps, weaknesses, or issues in the third party’s controls, and reporting the findings and recommendations to the relevant stakeholders. Negotiating contract terms for the right to audit is not a component of controls evaluation, but rather a component of contract management. Contract management is the process of establishing, maintaining, and enforcing the contractual agreements between the organization and the third party. It involves defining the roles, responsibilities, expectations, and obligations of both parties, as well as the terms and conditions for service delivery, performance measurement, risk management, dispute resolution, and termination. Negotiating contract terms for the right to audit is a key aspect of contract management, as it allows the organization to monitor and verify the third party’s compliance with the contract and the applicable regulations and standards. It also enables the organization to conduct independent audits or assessments of the third party’s controls, processes, and performance, and to request remediation actions if necessary. References:

• 1: Shared Assessments, a leading provider of third party risk management solutions, offers a comprehensive guide for Certified Third Party Risk Professional (CTPRP) candidates, which covers the core concepts and best practices of third party risk management, including controls evaluation and contract management.
• 2: UpGuard, a platform for cybersecurity and third party risk management, provides a detailed overview of the best practices for third party risk assessment, which includes the steps and criteria for evaluating the controls of third parties.
• 3: Deloitte, a global professional services firm, offers an end-to-end managed service for third party risk management, which includes controls evaluation and contract management as key components of the service.

End-user device policies are policies that establish the rules and requirements for the use and management of devices that access organizational data, networks, and systems. These policies typically include user obligations that define the responsibilities and expectations of the users regarding the security, privacy, and compliance of the devices they use. According to the web search results from the search_web tool, some common user obligations defined in end-user device policies are:

• A statement specifying the owner of data on the end-user device: This statement clarifies who owns the data stored on the device, whether it is the organization, the user, or a third party. This statement also defines the rights and obligations of the data owner and the data custodian, such as the access, retention, disposal, and protection of the data123.
• A statement that defines the process to remove all organizational data, settings and accounts at offboarding: This statement outlines the steps and procedures that the user must follow to securely erase or transfer all organizational data, settings, and accounts from the device when they leave the organization or change their role. This statement also specifies the roles and responsibilities of the user, the organization, and the device manager in ensuring the proper offboarding of the device143.
• A statement detailing user responsibility in ensuring the security of the end-user device: This statement describes the actions and measures that the user must take to protect the device from unauthorized access, theft, loss, damage, or compromise. This statement may include requirements such as enabling encryption, password, firewall, antivirus, updates, and backups, as well as reporting any incidents or issues related to the device1435.

However, option D, a statement that specifies the ability to synchronize mobile device data with enterprise systems, is not a user obligation defined in end-user device policies. Rather, this statement is a feature or functionality that may be enabled or disabled by the organization or the device manager, depending on the security and compliance needs of the organization. This statement may also be part of a device configuration policy or a mobile device management policy, which are different from end-user device policies. Therefore, option D is the correct answer, as it is the only one that does not reflect a user obligation defined in end-user device policies. References: The following resources support the verified answer and explanation:

• 1: End-User Device Policy | IT Services - University of Chicago
• 4: Device compliance policies in Microsoft Intune | Microsoft Learn
• 2: Basics of an End User Computing Policy - Apparity Blog
• 3: End-User Device Management Standard Operating Procedure
• 5: End-User Devices | Information Security - University of Chicago

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

The purpose of internal communications and information sharing using TPRM performance metrics is to inform and align the organization’s stakeholders on the status, progress, and outcomes of the TPRM program. This includes communicating the results of vendor assessments, the compliance level of the organization’s policies and procedures, and the periodic reporting to management and other relevant parties. However, documenting the corrective action plan between external parties is not an internal communication, but rather an external one. This is because the corrective action plan is a formal agreement between the organization and the vendor to address and resolve the issues identified in the assessment. Therefore, this statement is not an example of the purpose of internal communications and information sharing using TPRM performance metrics. References:

• 15 KPIs & Metrics to Measure the Success of Your TPRM Program
• Third-party risk management metrics: Best practices to enhance your program
• 3 Best Third-Party Risk Management Software Solutions (2024)

 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

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

 it is the most appropriate and compliant method of validating pre-employment screening attributes among the given options. Requesting evidence of the performance of pre-employment screening when permitted by law means that the organization respects the legal and regulatory boundaries of different jurisdictions and does not impose unnecessary or unlawful requirements on its third parties. It also ensures that the organization obtains relevant and reliable information about the third parties’ screening processes and outcomes, which can help assess their suitability and risk level.

The other options are incorrect because they are either inappropriate or ineffective methods of validating pre-employment screening attributes. Reviewing evidence of web search of social media sites (A) is inappropriate because it may violate the privacy and data protection rights of the third parties and their employees, as well as expose the organization to potential bias and discrimination claims. Providing and sampling complete personnel files to demonstrate unique screening results (B) is ineffective because it may not reflect the actual screening attributes of the third parties, as they may have different screening criteria, standards, and methods than the organization. Requiring evidence of drug testing © is inappropriate because it may not be relevant or necessary for the nature and scope of the third-party relationship, and it may also conflict with the laws and regulations of different jurisdictions that prohibit or limit such testing. References:

https://www.onetrust.com/blog/third-party-risk-management/

The concept of least privilege is a security principle that requires giving each user, service, and application only the permissions needed to perform their work and no more12. It is one of the most important concepts in network and system security, as it reduces the attack surface and the risk of unauthorized access, data breaches, and malware infections12. The statement B best describes this concept, as it implies that the vendor follows the principle of least privilege by granting people access to the minimum necessary to do their job. The other statements do not capture the essence of the concept, as they either describe other security practices (such as dual authorization and separation of duties) or limit the scope of the concept to a specific type of access (such as root and administrator access).

References:

• 1: 9 Ways to Prevent Third-Party Data Breaches in 2024 | UpGuard
• 2: Best Practice Guide to Implementing the Least Privilege Principle - Netwrix

Personally identifiable information (PII) is any data that can be used to identify, contact, or locate an individual, such as name, address, email, phone number, social security number, etc. PII is subject to various legal and regulatory requirements, such as the GDPR, HIPAA, PCI DSS, and others, depending on the industry and jurisdiction. PII also poses significant security and privacy risks, as it can be exploited by malicious actors for identity theft, fraud, phishing, or other cyberattacks. Therefore, organizations that collect, store, process, or transmit PII must implement appropriate safeguards to protect it from unauthorized access, disclosure, modification, or loss.

One of the key safeguards for PII protection is encryption, which is the process of transforming data into an unreadable format using a secret key. Encryption ensures that only authorized parties who have the key can access the original data. Encryption can be applied to data at rest (stored on a device or a server) or data in transit (moving across a network or the internet). Encryption can also be symmetric (using the same key for encryption and decryption) or asymmetric (using a public key for encryption and a private key for decryption).

Another key safeguard for PII protection is authentication, which is the process of verifying the identity of a user or a system that requests access to data. Authentication ensures that only legitimate and authorized parties can access the data. Authentication can be based on something the user knows (such as a password or a PIN), something the user has (such as a token or a smart card), something the user is (such as a fingerprint or a face scan), or a combination of these factors. Authentication can also be enhanced by using additional methods, such as one-time passwords, challenge-response questions, or multi-factor authentication.

When defining third party requirements for transmitting PII, the factors that provide stronger controls are the strength of encryption cipher and authentication method. These factors determine how secure and reliable the data transmission is, and how resistant it is to potential attacks or breaches. The strength of encryption cipher refers to the algorithm and the key size used to encrypt the data. The stronger the cipher, the more difficult it is to break or crack the encryption. The strength of authentication method refers to the type and the number of factors used to verify the identity of the user or the system. The stronger the authentication method, the more difficult it is to impersonate or compromise the user or the system.

The other factors, such as full disk encryption and backup, available bandwidth and redundancy, and logging and monitoring, are also important for PII protection, but they do not directly affect the data transmission process. Full disk encryption and backup are relevant for data at rest, not data in transit. They provide protection in case of device theft, loss, or damage, but they do not prevent data interception or modification during transmission. Available bandwidth and redundancy are relevant for data availability and performance, not data security and privacy. They ensure that the data transmission is fast and reliable, but they do not prevent data exposure or corruption during transmission. Logging and monitoring are relevant for data audit and compliance, not data encryption and authentication. They provide visibility and accountability for the data transmission activities, but they do not prevent data access or misuse during transmission. References:

• : What is Data Encryption? | Definition and Examples | Imperva
• : What is Authentication? | Definition and Examples | Imperva
• : Personally Identifiable Information (PII) - Imperva
• : Data Protection - Shared Assessments

The most important factor when scoping assessments of cloud-based third parties that access, process, and retain personal data is to identify the type of cloud hosting deployment or service model. This is because different cloud models have different implications for the allocation of security responsibilities between the third party and the cloud hosting provider. For example, in a Software as a Service (SaaS) model, the cloud provider is responsible for most of the security controls, while in an Infrastructure as a Service (IaaS) model, the third party is responsible for securing its own data and applications. Therefore, it is essential to understand the type of cloud model and the corresponding security roles and responsibilities before conducting an assessment. This will help to avoid gaps, overlaps, or conflicts in security controls and expectations. References:

• Guidance on Cloud Security Assessment and Authorization - ITSP.50.105, Canadian Centre for Cyber Security, May 2020, Section 2.1.1
• The Importance of Properly Scoping Cloud Environments, PCI Security Standards Council and Cloud Security Alliance, August 2021
• Third party and cloud: Regulatory challenges, KPMG, 2022, Section 2.1
• Certified Third Party Risk Professional (CTPRP) Study Guide, Shared Assessments, 2021, Section 4.2.2

Web content accessibility guidelines (WCAG) are a set of standards that aim to make web content more accessible to people with disabilities, such as visual, auditory, cognitive, or motor impairments. While WCAG is a good practice for web development and usability, it is not directly related to web application security. WCAG does not address the common security risks that web applications face, such as injection, broken authentication, misconfiguration, or vulnerable components. Therefore, adhering to WCAG is not a method of securing web applications, unlike the other options. References:

• 4: OWASP Top 10, a standard awareness document for web application security, lists the most critical security risks to web applications and provides best practices to prevent or mitigate them.
• 5: SANS Institute, a leading provider of cybersecurity training and certification, offers a security checklist for web application technologies (SWAT) that covers best practices for error handling, data protection, configuration, authentication, session management, input and output handling, and access control.
• 6: Built In, a platform for tech professionals, provides 13 web application security best practices, such as using a web application firewall, keeping track of APIs, enforcing expected application behaviors, and following the OWASP Top 10.

 Criticality is a measure of how essential a service provider is to the organization’s core business functions and objectives. It reflects the potential consequences of a service disruption or failure on the organization’s operations, reputation, compliance, and financial performance. Criticality is not the same as risk, which is the likelihood and severity of a negative event occurring. Criticality helps to prioritize the risk assessment and mitigation efforts for different service providers based on their relative importance to the organization. Criticality is not limited to a specific type of service, such as disaster recovery or personal information, nor is it determined by the mode of access or connectivity. Criticality is assigned to the service providers that have the greatest impact on the organization’s ability to deliver its products or services to its customers and stakeholders in a timely and satisfactory manner. References:

• Shared Assessments. (2020). Certified Third Party Risk Professional (CTPRP) Study Guide1
• Milliman. (2017). Defining “critical or important functions or activities” for outsourcing purposes2
• Webster, C. and Sundaram, D.S. (2009). Effect of service provider’s communication style on customer satisfaction in professional services setting: the moderating role of criticality and service nature. Journal of Services Marketing, 23(2), 103-1131

According to the Shared Assessments Certified Third Party Risk Professional (CTPRP) Study Guide, risk based decisioning is the process of applying risk criteria to prioritize and address the gaps identified during a third-party risk assessment1. The assessor should analyze the gaps based on the impact, likelihood, and urgency of the risk, and document the findings and recommendations in a report. The assessor should also review the existing or proposed compensating controls that could mitigate the risk, and submit the report to the business owner for approval of the risk treatment plan. The risk treatment plan could include accepting, transferring, avoiding, or reducing the risk, depending on the risk appetite and tolerance of the organization1.

The other statements do not reflect the best use of risk based decisioning, as they either ignore the risk analysis and documentation process, or apply a uniform or arbitrary approach to prioritizing and addressing the gaps. The assessor should not decide or conclude on the risk treatment plan without consulting the business owner, as the business owner is ultimately responsible for the third-party relationship and the risk management decisions1. The assessor should also not communicate that the gaps would not be included in the report if they were corrected immediately, as this could compromise the integrity and transparency of the assessment process and the report2.

References:

• 1: Shared Assessments Certified Third Party Risk Professional (CTPRP) Study Guide, pages 29-30, 33-34
• 2: Third-Party Risk Management: Final Interagency Guidance, page 10

Threat modeling is a core element of the Microsoft Security Development Lifecycle (SDL) and a structured approach to identify, quantify, and address the security risks associated with an application12. Threat modeling helps to shape the application’s design, meet the security objectives, and reduce risk1. The best time to perform threat modeling analysis is before the application design and development activities begin, as this allows the application service provider to:

• Communicate about the security design of their systems1.
• Analyze the design for potential security issues using a proven methodology1.
• Suggest and manage mitigations for security issues1.
• Incorporate security requirements into the design2.
• Avoid costly rework or redesign later in the SDLC2.
• Identify the most critical and relevant threats to focus on2. References: 1: Microsoft Security Development Lifecycle Threat Modelling1 2: Threat Modeling Process | OWASP Foundation2

 An IT asset management program is a set of processes and tools that help an organization manage its IT assets throughout their lifecycle, from acquisition to disposal. An IT asset management program should include the following components1234:

• Maintaining inventories of systems, connections, and software applications: This component involves creating and updating a comprehensive and accurate list of all IT assets owned or used by the organization, including their location, ownership, configuration, and status. This helps the organization optimize the use of its IT resources, reduce costs, and ensure compliance with licensing and regulatory requirements.
• Tracking and monitoring availability of vendor updates and any timelines for end of support: This component involves keeping track of the latest updates, patches, and security fixes provided by the vendors of the IT assets, as well as the end-of-life dates and support options for the assets. This helps the organization maintain the security, performance, and functionality of its IT assets, and plan for timely replacement or migration of obsolete or unsupported assets.
• Identifying and tracking adherence to IT asset end-of-life policy: This component involves defining and implementing a policy for retiring and disposing of IT assets that are no longer needed, useful, or supported by the organization. This helps the organization reduce risks, costs, and environmental impacts associated with IT asset disposal, and ensure compliance with data protection and disposal regulations.

Defining application security standards for internally developed applications is not a component of an IT asset management program, but rather a component of an application development and security program. An application development and security program is a set of processes and tools that help an organization design, develop, test, deploy, and maintain secure and reliable applications, whether they are internally developed or acquired from external sources. An application development and security program should include the following components5 :

• Defining application security standards for internally developed applications: This component involves establishing and enforcing a set of security requirements and best practices for the applications developed by the organization, such as secure coding, testing, and deployment methodologies, security controls, and vulnerability management. This helps the organization ensure the confidentiality, integrity, and availability of its applications and data, and prevent or mitigate security breaches and incidents.
• Performing application security assessments for externally acquired applications: This component involves conducting security reviews and audits of the applications acquired from external sources, such as vendors, partners, or open source communities, before integrating them into the organization’s IT environment. This helps the organization identify and address any security risks, gaps, or weaknesses in the applications, and ensure compatibility and compliance with the organization’s security policies and standards.

References:

• ITAM: The ultimate guide to IT asset management
• IT asset management: 10 best practices for success
• Asset Management: The Five Core Components
• The Fundamentals of Asset Management
• Application Development and Security Program
• Application Security Best Practices

 ESG programs are initiatives that aim to improve the environmental, social, and governance performance of a vendor or service provider. ESG programs may be driven by various factors, such as regulatory obligations, customer expectations, stakeholder pressure, industry standards, or company commitments. Therefore, statement B is true and the correct answer is B. Statement A is false because ESG expectations may come from external entities, such as regulators, investors, customers, or civil society. Statement C is false because ESG commitments can be measured both qualitatively and quantitatively, using indicators such as carbon emissions, diversity, ethics, or compliance. Statement D is false because ESG obligations may apply to any company, regardless of its size, ownership, or sector. References:

• Third-party risk management and the ESG agenda
• ESG third-party risk
• The Role of Third-Party Risk Management in ESG Compliance

According to the Shared Assessments Certified Third Party Risk Professional (CTPRP) Study Guide, the third party risk assessor’s role is to evaluate the design and operating effectiveness of the third party’s controls based on an industry framework, such as ISO, NIST, COBIT, or COSO1. The assessor’s role is not to provide an opinion on the effectiveness of controls, but rather to report the results of the evaluation in a factual and objective manner2. The assessor’s role is also to conduct discovery with subject matter experts to understand the control environment, to conduct discovery and validate responses from the risk assessment questionnaire by testing or validating controls, and to review compliance artifacts and identify potential control gaps based on evaluation of the presence of control attributes1. These are all true statements that describe the assessor’s role when conducting a controls evaluation using an industry framework.

References:

• 1: Shared Assessments Certified Third Party Risk Professional (CTPRP) Study Guide, page 29
• 2: What is a Third-Party Risk Assessment? — RiskOptics

Workstation and endpoint security refers to the protection of devices that connect to a network from malicious actors and exploits1. These devices include laptops, desktops, tablets, smartphones, and IoT devices. Workstation and endpoint security can involve various measures, such as antivirus software, firewalls, encryption, authentication, patch management, and device management1.

Among the four options, the use of multi-tenant laptops poses the greatest risk potential for workstation and endpoint security. Multi-tenant laptops are laptops that are shared by multiple users or organizations, such as in a cloud-based environment2. This means that the laptop’s resources, such as memory, CPU, storage, and network, are divided among different tenants, who may have different security policies, requirements, and access levels2. This can create several challenges and risks, such as:

• Data leakage or theft: If the laptop is not properly isolated or encrypted, one tenant may be able to access or compromise another tenant’s data or applications2. This can result in data breaches, identity theft, or compliance violations.
• Malware infection or propagation: If one tenant’s laptop is infected by malware, such as ransomware, spyware, or viruses, it may spread to other tenants’ laptops through the shared network or storage2. This can disrupt the laptop’s performance, functionality, or availability, and cause damage or loss of data or applications.
• Resource contention or exhaustion: If one tenant’s laptop consumes more resources than allocated, it may affect the performance or availability of other tenants’ laptops2. This can result in slow response, poor user experience, or service degradation or interruption.
• Configuration or compatibility issues: If one tenant’s laptop has different or conflicting settings, preferences, or applications than another tenant’s laptop, it may cause errors, crashes, or compatibility problems2. This can affect the laptop’s functionality, reliability, or usability.

Therefore, the use of multi-tenant laptops should trigger more investigation due to greater risk potential, and require more stringent and consistent security controls, such as:

• Segmentation or isolation: The laptop should be logically or physically separated into different segments or zones for each tenant, and restrict the communication or interaction between them2. This can prevent unauthorized access or interference between tenants, and limit the impact of a security incident to a specific segment or zone.
• Encryption or obfuscation: The laptop should encrypt or obfuscate the data and applications of each tenant, and use strong encryption keys or algorithms2. This can protect the confidentiality and integrity of the data and applications, and prevent data leakage or theft.
• Antivirus or anti-malware: The laptop should install and update antivirus or anti-malware software, and scan the laptop regularly for any malicious or suspicious activities2. This can detect and remove any malware infection or propagation, and prevent damage or loss of data or applications.
• Resource allocation or management: The laptop should allocate or manage the resources of each tenant, and monitor the resource consumption and utilization2. This can ensure the performance or availability of the laptop, and prevent resource contention or exhaustion.
• Configuration or standardization: The laptop should configure or standardize the settings, preferences, or applications of each tenant, and ensure the compatibility or interoperability between them2. This can avoid errors, crashes, or compatibility issues, and improve the functionality, reliability, or usability of the laptop.

References: 1: What is Desktop Virtualization? | IBM1 2: Multitenant organization scenario and Microsoft Entra capabilities2

An unrecoverable data loss event after restoring a system is indicative of a failure to meet the Recovery Point Objective (RPO). The RPO represents the maximum tolerable period in which data might be lost due to an incident and is a critical component of an organization's disaster recovery and business continuity planning. If data restoration efforts are unsuccessful and lead to unrecoverable data loss, it means that the organization's data backup and recovery processes were insufficient to meet the defined RPO, leading to a loss of data beyond the acceptable threshold. This situation underscores the importance of implementing effective data backup and recovery strategies that align with the organization's RPO to minimize data loss and ensure business continuity in the event of a disruption.

References:

• Business continuity and disaster recovery standards, such as ISO 22301 (Security and Resilience - Business Continuity Management Systems - Requirements), provide guidelines on establishing and managing RPOs as part of a comprehensive business continuity plan.
• The "Disaster Recovery Planning Guide" by the Disaster Recovery Journal (DRJ) offers insights into best practices for data backup and recovery, emphasizing the importance of aligning recovery strategies with defined RPOs to minimize the impact of data loss incidents.

Application whitelisting is a security technique that allows only authorized applications to run on a device or network, preventing malware or unauthorized software from executing. While this can be a useful security measure, it is not directly related to remote access risk evaluation, which focuses on the security of the connection and the access rights of the remote users. The other options are more relevant to remote access risk evaluation, as they help to monitor, control, and audit the remote access activities and prevent unauthorized or malicious access. References:

• 1: Secure Remote Access: Risks, Auditing, and Best Practices
• 2: 5 Common Vulnerabilities Associated With Remote Access

For services with system-to-system access, ensuring sufficient time for quality assurance (QA) testing before implementing changes is crucial to reducing the risk of business disruption to the outsourcer. This requirement ensures that any modifications to the system are thoroughly vetted for potential issues that could impact the outsourcer's operations. QA testing allows for the identification and remediation of bugs, compatibility issues, and other potential problems that could lead to operational disruptions or security vulnerabilities. By allocating adequate time for QA testing, organizations can ensure that changes are fully functional and secure, thereby maintaining the integrity and availability of services provided to the outsourcer. This practice is aligned with industry standards for change management, which advocate for comprehensive testing and validation processes to ensure the reliability and stability of system changes.

References:

• Industry standards such as ITIL (Information Technology Infrastructure Library) emphasize the importance of thorough testing and validation within the change management process to minimize the risk of disruptions and ensure the smooth operation of services.
• Guides like "Managing Change in IT Outsourcing Arrangements: The TPRM Perspective" provide insights into best practices for change management in third-party relationships, including the critical role of QA testing in mitigating risks associated with system changes.

Business Continuity or Disaster Recovery (BC/DR) plans are designed to ensure the continuity of critical business functions and processes in the event of a disruption or disaster. BC/DR plans should include annual testing activities to validate the effectiveness and readiness of the plans, as well as to identify and address any gaps or weaknesses. Testing activities should cover the three main areas of BC/DR: people, processes, and technology12.

The four options given in the question represent different types of testing activities that may be included in the BC/DR plans. However, option D is the least likely to be included, as it is not a mandatory or common practice for most organizations. While it is beneficial to involve third party service providers in the BC/DR testing, as they may play a vital role in the recovery process, it is not a requirement or a standard for most industries. Third party service providers may have their own BC/DR plans and testing schedules, which may not align with the organization’s plans and objectives. Moreover, requiring their participation in industry exercises may pose challenges in terms of coordination, confidentiality, and cost34.

Therefore, option D is the correct answer, as it is the least likely to be included in the annual testing activities for BC/DR plans. The other options are more likely to be included, as they are essential for ensuring the availability and functionality of the technology, processes, and personnel that support the critical business operations. These options are:

• A. Plans to enable technology and business operations to be resumed at a back-up site. This is a common testing activity that involves simulating a disaster scenario that affects the primary site and activating the back-up site to resume the operations. This tests the technical infrastructure, data backup and recovery, and operational procedures of the BC/DR plan12.
• B. Process to validate that specific databases can be accessed by applications at the designated location. This is a common testing activity that involves verifying that the data and applications that are critical for the business functions are accessible and functional at the recovery location. This tests the data integrity, security, and compatibility of the BC/DR plan12.
• C. Ability for business personnel to perform their functions at an alternate work space location. This is a common testing activity that involves relocating the key staff to an alternate location and having them perform their normal duties. This tests the communication, coordination, and productivity of the BC/DR plan12.

References:

• 1: How to Test a Business Continuity Disaster Recovery (BCDR) Plan
• 2: Business Continuity or Disaster Recovery Testing and Training Guidelines
• 3: Third Party Risk Management and Business Continuity Planning
• 4: Third Party Risk Management: Business Continuity and Disaster Recovery

 An Asset Management program is a set of policies, procedures, and practices that aim to optimize the value, performance, and lifecycle of the organization’s assets, such as physical, financial, human, or information assets123. An Asset Management program typically defines policy requirements for the following aspects of asset management:

• The Policy states requirements for the reuse of physical media (e.g., devices, servers, disk drives, etc.): This requirement ensures that the organization follows proper procedures for sanitizing, wiping, or destroying physical media that contain sensitive or confidential data before reusing, recycling, or disposing of them123. This requirement helps prevent data leakage, theft, or loss, and protects the organization’s reputation and compliance123.
• The Policy requires that employees and contractors return all company data and assets upon termination of their employment, contract or agreement: This requirement ensures that the organization recovers all the data and assets that were assigned, loaned, or accessed by the employees and contractors during their employment, contract, or agreement123. This requirement helps maintain the security, integrity, and availability of the organization’s data and assets, and prevents unauthorized or inappropriate use or disclosure of them123.
• The Policy defines requirements for the inventory, identification, and disposal of equipment and/or physical media: This requirement ensures that the organization maintains an accurate and up-to-date record of all the equipment and physical media that it owns, leases, or uses, and assigns unique identifiers to them123. This requirement also ensures that the organization follows proper procedures for disposing of equipment and physical media that are no longer needed, useful, or functional123. This requirement helps improve the efficiency, effectiveness, and accountability of the organization’s asset management processes, and reduces the risks of waste, fraud, or misuse of the organization’s resources123.

However, option D, a policy requirement that requires visitors (including other tenants and maintenance personnel) to sign-in and sign-out of the facility, and to be escorted at all times, is typically not defined in an Asset Management program. Rather, this requirement is more likely to be defined in a Physical Security program, which is a set of policies, procedures, and practices that aim to protect the organization’s premises, assets, and personnel from unauthorized access, damage, or harm . A Physical Security program typically defines policy requirements for the following aspects of physical security:

• The Policy requires visitors (including other tenants and maintenance personnel) to sign-in and sign-out of the facility, and to be escorted at all times: This requirement ensures that the organization controls and monitors the access of visitors to the facility, and verifies their identity, purpose, and authorization . This requirement also ensures that the organization prevents visitors from accessing restricted or sensitive areas, equipment, or information, and escorts them throughout their visit . This requirement helps enhance the security, safety, and compliance of the organization’s facility, assets, and personnel, and prevents potential threats, incidents, or breaches .
• The Policy defines requirements for the locking, alarming, and surveillance of the facility and its entrances and exits: This requirement ensures that the organization secures the perimeter and the interior of the facility, and detects and responds to any unauthorized or suspicious activity or intrusion . This requirement also ensures that the organization uses appropriate and effective physical security measures, such as locks, alarms, cameras, guards, or barriers, to deter, prevent, or delay unauthorized access . This requirement helps protect the organization’s facility, assets, and personnel from theft, vandalism, sabotage, or attack .
• The Policy specifies requirements for the emergency preparedness and response of the facility and its occupants: This requirement ensures that the organization plans and implements procedures for dealing with emergencies, such as fire, flood, earthquake, power outage, or active shooter, that may affect the facility and its occupants . This requirement also ensures that the organization provides adequate and accessible equipment, resources, and training for the emergency preparedness and response, such as fire extinguishers, first aid kits, evacuation routes, emergency contacts, or drills . This requirement helps ensure the safety, health, and continuity of the organization’s facility, assets, and personnel, and minimizes the impact and damage of emergencies .

Therefore, option D is the correct answer, as it is the only one that does not reflect a policy requirement that is typically defined in an Asset Management program. References: The following resources support the verified answer and explanation:

• 1: Asset Management Policy Guide + Free Template | Fiix
• 2: Asset Management Policy: How to Build One From Scratch - Limble CMMS
• 3: How to develop an asset management policy, strategy and governance framework: Set up a consistent approach to asset management in your municipality
• : Physical Security Policy - SANS
• : Physical Security Policy - IT Governance