3 Critical Stages of Third-Party Vendor Management

By Vanessa Stanfield, Insurance Solutions powered by Affinion

Did you know your credit union could be responsible for the performance of your vendors? No credit union wants to encounter regulatory trouble or face reputational risk; especially as a result of vendor activities. It’s because of that fact that vendor management due diligence is a topic of increasing importance.

But what is the right way to go about choosing  third party vendor? The National Credit Union Administration (NCUA) has provided clear direction regarding vendor due diligence. Additionally, the NCUA has deemed the following areas as critical in third-party vendor management: Risk Assessment & Planning, Due Diligence, and Risk Measurement, Monitoring and Control.

Risk Assessment & Planning

Risk Assessment

Prior to engaging a third-party relationship, assess the current risks and document how the vendor will relate to your credit union’s strategic plan. When conducting a comprehensive risk assessment, the key areas of focus are: credit, interest rate, liquidity, transaction, compliance, strategy, and reputational risk. In this discovery phase, your credit union can identify the current risks and establish expectations of the new relationship.

Due Diligence

There are four fundamental due diligence elements to consider when choosing a vendor: organizational, business model, financial health, and program risks. In these areas, your credit union can assess what degree of due diligence is required.

But remember- not all vendors are created equal. More complex vendor relationships with more risk will typically require increased due diligence; less complexity and risk means less rigorous due diligence. For a comprehensive report and the five key due diligence questions you need to ask your vendors, read the full whitepaper here.

Risk Measurement, Monitoring and Control

Credit unions must be able to continually measure performance and risk throughout the relationship with the vendor. To do this, your credit union should clearly outline the vendor’s responsibilities and policies before taking on the vendor. In the end, this will allow for proper vendor performance management so that you can ensure expectations are being met.

Credit unions should not think of vendors as a third party, but as an extension of their organization. Because of this, it is important to consider the three critical areas above when deciding on a vendor. As the NCUA has conveyed, the utilization of vendors does not in any way diminish the credit union’s level of responsibility and for that reason, credit unions should carefully select their vendors.

What Should We Ask Our Vendors?

To be confident that the vendor’s management programs are the right fit, credit unions must discuss the vendor in great detail and ask the hard questions. Failure to conduct thorough due diligence and effectively monitor these vendors place the credit union at risk. Again, not all vendor relationships call for the same level of due diligence and ongoing monitoring, but in order to determine what level is necessary there are key questions that your credit union must contemplate.

For an in-depth look at the five key due diligence questions that credit unions must ask when selecting a third-party vendor, read the full whitepaper here.

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InsuranceSolution_4CAffinion is the NAFCU Services Preferred Partner for AD&D Insurance

Cybersecurity Ratings: The Third Party Cyber Risk Management Solution

BitSight Cyber Lock

So, you have identified your top partners.  You have thoroughly evaluated their cybersecurity services in order to keep your members’ financial data safe and secure. But before you sit back and relax, you have to ask yourself “what about tomorrow?”

The Pitfalls of Traditional Evaluation Methods for Cybersecurity

Traditional methods of evaluating your partners may include detailed questionnaires and conversations, audits, and maybe you have even conducted some vulnerability scans. These are all sound methods for establishing whether your partners are on the right track, but they are only a start.

  • One-time snapshot. The problem with this type of evaluation method is it only gives you a snapshot of the organization at one small point in time. It would be the equivalent of checking the locks on your doors once and then not doing it again in the future.
  • Expensive. Numerous questionnaires and audits can become very costly very quickly. If you are a small credit union, it may not seem practical to spend the cash or the manpower on these efforts.
  • Regulation struggle. In addition to an ethical obligation to your members, regulators are creating new legal obligations aimed at third party risk management plans. The sooner you can get in front of this issue, the easier it will be.

Vendors, especially high priority ones that have direct access to your network or your most sensitive data, really need to be monitored for their security practices all the time. This may seem daunting or even impossible, but it doesn’t have to be. The key to locking up holes in your partners’ security is through security rating and monitoring solutions.

How Cybersecurity Ratings Work

Cybersecurity ratings work essentially like a credit rating company issuing a FICO score, but instead it issues a security rating. For example, companies can be rated on a scale from 250 to 900. A high number indicates a strong security performance and a lower security risk.

A security rating platform gathers and analyzes publicly available information and noted incidents to create its security rating. It considers things like spam propagation, malware propagation, botnet infections, and then calculates a rating. You will also be able to see where the infections and incidents relating to a company’s security are occurring.

Utilizing Ratings as a Resource

BitSightRatings2Cybersecurity ratings can be a very useful tool in prioritizing which vendors require the most attention from your credit union. A company with a consistently high score probably doesn’t need a tremendous amount of your effort, so you can allocate your time and budget to the vendors that are creating greater risks for you and your members.

In addition, this rating can be a valuable resource when having a more sophisticated conversation with your vendors about cybersecurity. If you are grappling with what questions to ask or what risk vectors you should be focused on, the security rating information can give you a road map to do that.

web logo.bitsightNAFCU Services and BitSight Technologies have partnered to provide an independent security monitoring service that provides continuous data on outside vendors’ security practices. If you would like to learn more about BitSight’s solutions for credit unions, or formulating a third party risk management plan, you can check out our webinar here.

Cybersecurity Awareness Month: Confronting the Scariest Threats to Your Credit Union

CyberSecurity_KCG

October is National Cybersecurity Awareness Month which means it’s an excellent time to make sure there aren’t any unseen forces within your credit union that have nefarious plans for your members’ money.

Earlier this year, Wired Magazine wrote about the biggest cybersecurity threats for 2015. Three of these are indeed scary prospects for the credit union industry, but the key is to make sure you are doing everything you can to prevent these scenarios:

  • Data Destruction: Malware exists that erases data and boot records, so it is vitally important to make sure you have an excellent data backup plan.
  • Bank Card Breaches: This is a threat that isn’t going away any time soon, so it is important to be moving towards tokenization technologies to prevent this. NAFCU has partnered with MasterCard to help credit unions move towards this. For more information you can check out this webinar from earlier this year here.
  • Third Party Breaches: The data breach at Target stores is an excellent example of why you need a strong Third Party Risk Management Plan. For more information on this, check our recent webinar or blog posts here or here.

The costs of cyber threats are no joke to financial institutions big or small. According to the National Small Business Association, 44 percent of small businesses have been the victims of a cyber-attack. Clearly, it is worth the investment to review how sound your security is. The following tips from the Department of Homeland Security are an excellent place to start.

Cyberattack Prevention Tips and Practices

  • Have a plan. According to staysafeonline.org, 59% of small and medium size businesses in the United States do not have a plan that outlines procedures for responding and reporting data breach losses.  A number of these plans are covered in various compliance frameworks that may already exist, but as shelf ware.  If this describes you, now is the time to formulate both short and long term plans.
  • Utilize the latest software. Make sure you have antivirus and antispywear and update it regularly.
  • Educate. Make sure that all of your employees are aware Cybersecurity_KCGof cyber threats and educate them on the steps they must take to help combat these attacks.
  • Invest in data loss protection software, use encryption technologies to protect data in transit, and use two-factor authentication where possible.
  • Passwords. Use strong passwords throughout your organization and have employees change them regularly.

Who Should You Call?

What should you do if you’re unsure if your organization is prepared to navigate this threat landscape? If you are not sure where your cyber security threats may lie or even where you should be looking, consider going to an outside vendor. NAFCU and Knowledge Consulting Group (KCG) have partnered to provide comprehensive cybersecurity solutions.

KCG provides expert services in penetration testing and cybersecurity advisory services. Their tests offer simulation of potential attack vectors and scenarios most likely to impact the overall credit union environment, from IT systems to social engineering. They provide risk management, governance, operations, and compliance services to help credit unions navigate the complexities of the evolving cybersecurity landscape.

So take an inventory of your practices, make a plan, and evaluate where your weak spots are.

Knowledge Consulting Group is a subsidiary of ManTech International. For more detailed information on penetration testing or cybersecurity advisory services, visit KCG’s preferred partner page.

Cyber Security Awareness Month: Third Party Cyber Risk Management

By: Jacob Olcott, VP of Business Development, BitSight Technologies

How not to become a “Target”
Thirdparty_cyberrisk_woman
October is cyber security awareness month, and there are few things more haunting to financial or retail institutions than the security breach that affected Target stores a few years back. The attack resulted in more than $40 million in debit and credit card numbers being stolen, and more than likely affected at least some of your members.

The scariest part of the security breach may be where it originated: its HVAC supplier. The attack highlights how important it is for financial organizations to have a well thought-out program to mitigate third party cyber risk.

Regulators are taking a closer look at third party risk management so the importance of employing best practices is not just practical, but legal as well.

Five Key Steps to Develop a Third Party Risk Management Program

Developing a risk management program doesn’t have to be difficult. There are five key points to consider for a plan, and several vendors and services that can help you to do so.

  1. Organize Internally. This means bringing together all teams that have an impact on, or are impacted by your cybersecurity or dealings with third party vendors. This would most likely include your legal, compliance, IT, and procurement teams.
  2. Identify and Prioritize Key Parties. It is important for credit unions to consider any third BitSight_identify_critical_vendorsparty that has either direct network connections to your organization or has access to sensitive data. This would include, but is not limited to, looking at your primary payment processor, largest software vendor, law firms, consulting firms, and benefits administrator. When prioritizing vendors, approach this from the position of your most sensitive data, likely your members’ financial data, and the level of access a third party has to that data.
  3. Evaluate your vendors’ security. This is traditionally done a number of ways such as using questionnaires, vulnerability scans, and audits. If you are not sure where to start, Shared Assessments is a good source that charges a fee for common questionnaires to send your partners regarding their cyber security efforts. If you are interested in developing your own questionnaire, the NIST cybersecurity framework is a good place to start. You can also do your own audits of your partners, but often companies will share their own documentation of audits they have done.
  4. Communicate. The importance of clearly communicating your expectations to your partners should not be overlooked. This should be done not only in writing in forms such as contracts, but verbally as well. It is important to develop a strong dialogue regarding your security concerns that is not just once, when you launch a partnership, but ongoing. The cybersecurity landscape changes on a daily basis so it is important for you and your partners to discuss where you are headed and how to stay ahead of the curve.
  5. Continuously Monitor Vendor Performance. This is another point not to be overlooked. Questionnaires and audits can only give you snapshots of a company’s security profile at one point in time. Actual security is much more fluid than that. NAFCU has partnered with BitSight Technologies as a preferred provider of monitoring services. BitSight essentially works like credit rating service for cybersecurity. They provide a number that indicates how strong a company’s security practices are on a continuous basis. BitSight calculates Security Ratings using a continuous process that gathers, processes, and assigns security data to arrive at the top-level security ratings.

For more dBitSightLogoetailed information on developing a third party cyber risk management plan you can check out NAFCU’s webinar with BitSight Technologies here or  download BitSight’s white paper on the topic.