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Third Party Risk

Third-Party Risk Management Ownership: A Critical Analysis

29 Aug 2023
Who Owns Third-Party Risk Management? - Responsible Cyber

Third-party risk management (TPRM) is no longer a straightforward process confined to the onboarding of vendors. In today's intricate business ecosystem, with intertwined dependencies and dynamic regulatory landscapes, TPRM becomes an indispensable component that intersects multiple business units. At the heart of it all is the undeniable need for unambiguous visibility and unwavering oversight.

Different stakeholders, be it compliance and security officers, ethics experts, or even department heads, are increasingly cognizant of the nuances of vendor operations. They seek a holistic understanding that encompasses not just service quality but also data handling, privacy adherence, and overall risk exposure.

Historically, the onus of TPRM fell primarily on the legal and procurement departments. Their role was to vet vendors, ensuring contractual agreements safeguarded company interests. But the modern business landscape, marred with cybersecurity threats, data breaches, and stringent compliance mandates, demands a more comprehensive oversight mechanism.


The CFO's Perspective on TPRM

In many organizations, especially in those where financial risks tied to third-party associations are paramount, the Chief Financial Officer (CFO) plays a pivotal role in TPRM.

Example: Consider a multinational corporation that outsources its manufacturing to a third party in a country with volatile currency fluctuations. Here, the CFO would be deeply involved in assessing the financial implications of this relationship, including potential costs from currency volatility, import/export tariffs, or even local taxation changes.

Moreover, any potential disruption in the third-party vendor's operations can have direct repercussions on the organization's bottom line. Let's say a vendor responsible for a crucial component of a tech firm's flagship product faces operational issues. The delay in product launches can significantly impact revenues, putting the CFO at the frontline of managing these risks.


The CIO's Role in Modern TPRM

The Chief Information Officer (CIO), on the other hand, is becoming increasingly central to TPRM in businesses heavily reliant on IT infrastructure, software, and digital platforms.

Example: An e-commerce giant relying on third-party cloud services to host its platform would have the CIO actively involved in TPRM. Here, the CIO's primary concern would be ensuring data security, platform uptime, and seamless integration with other IT components. If the cloud service provider faces a data breach, not only does the e-commerce platform risk losing customer trust, but it also faces potential regulatory penalties, making TPRM vital.

Similarly, in a pharmaceutical company adopting digital transformation, third-party software vendors providing AI solutions for drug discovery would be under the CIO's purview. Any malfunction or misrepresentation can lead to substantial R&D losses, making diligent third-party risk evaluation paramount.

In summary, the multifarious nature of third-party relationships today means that TPRM is no longer the sole domain of legal or procurement teams. From CFOs worried about financial implications to CIOs ensuring IT robustness, TPRM has evolved into a cross-departmental responsibility. As business ecosystems continue to grow in complexity, organizations must adopt a holistic TPRM approach, involving every stakeholder who might bear the brunt of a third-party mishap.

Moreover, the compliance unit's role is becoming ever more intricate. They must ascertain which data is being shared with third parties, then gauge the privacy and security measures in place, ensuring they align with compliance norms. And while different departments manage unique facets of risk, all are united in their pursuit to protect the company's data.


The Peril of Risk Silos

Third-Party Risk Management (TPRM) is undeniably a cornerstone for businesses in today's interconnected digital era. However, the road to a robust TPRM strategy is fraught with multifarious challenges.


  1. Resource Constraints:

    For many organizations, especially those in their infancy or operating on a tight budget, dedicating substantial resources to TPRM may not seem feasible. There's often a tug-of-war between immediate operational demands and the long-term, seemingly abstract, process of third-party risk management.

    Example: A startup might prioritize product development and market presence over conducting an in-depth third-party security assessment of its cloud service provider, given their limited resources.

     

  2. Prioritization Paradox:

    With a myriad of operations demanding attention, where does TPRM stand? While the answer might seem obvious given the potential risks, businesses often struggle with prioritizing TPRM over immediate revenue-generating activities.

    Example: An e-commerce business during the holiday season might prioritize sales and marketing campaigns over evaluating the potential risks associated with a third-party payment gateway provider.

     

  3. Distinct Operational Prerequisites: 

    Each business, based on its sector, size, and operational model, has unique operational needs. These specific needs sometimes overshadow the universal requirements of TPRM, leading to a gap in holistic risk assessment.

    Example: A healthcare institution might focus heavily on third-party providers complying with patient data protection regulations but may neglect other potential risks like operational downtime or service disruptions.



Consequently, essential procedures in the TPRM process, such as vendor onboarding, periodic compliance checks, and incident management, become irregular, inconsistent activities. Instead of a systematic, continuous evaluation, businesses might conduct sporadic checks only when an incident triggers it or during contract renewals. This intermittent approach to TPRM invariably creates what are termed as 'risk silos'. In such a scenario, each department or team assesses and manages risks in isolation, unaware of the broader organizational implications or the evaluations of other teams.


  1. Redundancy in Risk Mitigation: Multiple departments might duplicate efforts, conducting similar risk assessments for the same vendor or overlooking shared risk factors. Example: Both the IT and finance departments of a company might independently assess the risk of a shared software vendor, leading to wasted resources.

  2. Gaps in Comprehensive Risk Analysis: While one department might evaluate a vendor thoroughly, another might give it a cursory glance, leading to an incomplete understanding of potential risks. Example: The procurement team might evaluate a supplier's delivery timelines and costs, while the quality assurance team assesses product quality. However, if neither checks the supplier's financial health, they might miss the risk of the supplier going bankrupt.

  3. Hindered Knowledge Transfer: Without a centralized TPRM strategy, teams can't share insights, warnings, or best practices, leading to a disjointed risk management approach.

     


Today's hyper-connected business ecosystem means risks don't exist in isolation. A single overlooked threat in a third-party relationship can cascade, causing disruptions across the enterprise. As such, understanding and addressing these challenges becomes paramount for organizations wishing to fortify themselves against the potential domino effect of third-party risks.


Tearing Down Silos for Enhanced Visibility

At its core, TPRM strives to safeguard an organization's extended network, ensuring both security and compliance in alignment with the company's goals and customer needs. While compliance requirements lay the foundation, risk, being dynamic, must be contextualized based on outsourced services or products, and aligned with the broader business objectives.

Embracing a collaborative stance is imperative for stakeholders managing TPRM programs. If TPRM is pigeonholed within specific units like compliance or procurement, the collaborative aspect is marginalized, leading to risks being addressed sporadically or superficially. Effective risk management requires interdisciplinary cooperation, including IT, security, privacy, ethics, and ESG, among others.

The contemporary cyber realm and the expanding third-party networks demand an evolved perspective on risk, especially with the influx of breach reporting regulations. Cyber risk shouldn't be an exclusive domain; it demands a holistic approach, incorporating it into the broader business framework.

In essence, pinning TPRM ownership on a single entity is counterproductive. Every stakeholder must be proactive, ensuring that TPRM isn't just a cursory check but an integral, evolving aspect of the business.

How Does Responsible Cyber's IMMUNE X-TPRM Help?

IMMUNE X-TPRM, developed by Responsible Cyber, offers a cohesive intelligent platform tailored for risk management. By enabling collaborative information sharing and automated workflows, organizations can transcend traditional bottlenecks and manual hurdles.

Get in touch with us to discover how IMMUNE X-TPRM can revolutionize your risk management approach with its advanced automation and comprehensive compliance intelligence.

Stay Updated: Join the Responsible Cyber community on LinkedIn, Twitter, and YouTube for the latest in privacy and security compliance.

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