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

Risk registers are tools that help organizations document, monitor, and manage their third party risks. They typically include information such as the risk description, category, source, impact, likelihood, rating, owner, status, and action plan. Risk registers enable organizations to prioritize their risks, assign responsibilities, track progress, and report on their risk posture. According to the CTPRP Study Guide, "A risk register is a tool for capturing and managing risks throughout the third-party lifecycle. It provides a comprehensive view of the organization’s third-party risk profile and facilitates risk reporting and communication."1 Similarly, the GARP Best Practices Guidance for Third-Party Risk states, "A risk register is a tool that records and tracks the risks associated with third parties. It helps to identify, assess, and prioritize risks, as well as to assign ownership, mitigation actions, and target dates."2

References:

• CTPRP Study Guide
• GARP Best Practices Guidance for Third-Party Risk

Remote wipe is a security feature that allows an administrator or a user to remotely erase all the data and settings on a device in case it is lost or stolen. This prevents unauthorized access to sensitive information and reduces the risk of data breaches. Remote wipe is typically used for company-owned devices, as it ensures that no company data remains on the device after it is lost or stolen. Remote wipe also restores the device to its factory settings, making it unusable for the thief or finder. Remote wipe can be performed through various methods, such as using a mobile device management (MDM) solution, a cloud service, or a built-in feature of the device’s operating system. References:

• 1: How to protect your company from data breaches caused by lost or stolen devices
• 2: BYOD vs Company-Owned Devices: How to Maintain Security
• 3: Lost or Stolen Business Device? Here’s What to do Next

 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

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

When reviewing application risk for application service providers, the most important factors are the functionality and type of data the application processes, the remote connectivity options, and the APl integration methods. These factors determine the level of exposure, sensitivity, and complexity of the application, and thus the potential impact and likelihood of a security breach or a compliance violation. The number of software releases is less important, as it does not directly affect the application’s security or functionality. However, it may indicate the maturity and quality of the software development process, which is another aspect of application risk assessment. References:

• Application Security Risk: Assessment and Modeling, ISACA Journal, Volume 2, 2016

A change in company point of contact does not necessarily trigger an organization to prompt a third party contract provisions review, unless the contract specifically requires such a notification or approval. A change in company point of contact may affect the communication and relationship between the parties, but it does not affect the legal terms and obligations of the contract. However, other types of external events, such as business continuity events, data breaches/privacy incidents, and changes in regulations, may have a significant impact on the performance, compliance, and risk of the contract, and therefore may require a review of the contract provisions to ensure that they are still valid, enforceable, and aligned with the parties’ expectations and objectives. For example, a business continuity event may disrupt the delivery of goods or services, a data breach/privacy incident may expose confidential or personal information, and a change in regulations may impose new obligations or liabilities on the parties. These events may trigger clauses such as force majeure, termination, indemnification, or dispute resolution, and may require the parties to renegotiate or amend the contract accordingly. References:

• Third-Party Contract Reviews: Determining Your Best Options
• Third party contracts: best practices for third party paper
• What to Look For When Reviewing Third-Party Contracts
• CTPRP Job Guide

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

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

Changes to administrator access are typically not subject to the traditional change control process, as they often pertain to user access management rather than modifications to the production environment's infrastructure or applications. Administrator access changes involve granting, altering, or revoking administrative privileges to systems, which is managed through access control policies and procedures rather than through change control. Change control processes are primarily concerned with changes to the network, systems, and applications that could affect the production environment's stability, security, and functionality. In contrast, managing administrative access is part of identity and access management (IAM), which focuses on ensuring that only authorized individuals have access to specific levels of information and system functionality.

References:

• Access control and identity management best practices, such as those outlined in NIST SP 800-53 (Security and Privacy Controls for Federal Information Systems and Organizations), emphasize the separation of duties and least privilege principles, which guide the management of administrator access changes.
• Resources like "Access Control Systems and Methodology" from ISC²'s CISSP Common Body of Knowledge provide guidelines on effectively managing access to prevent unauthorized access and maintain system security.

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

One of the key objectives of a TPRM program is to identify and mitigate the risks posed by third parties throughout the relationship life cycle. Therefore, measuring the operational performance of implementing a TPRM program requires tracking the effectiveness and efficiency of the risk management processes and activities. Among the four examples given, calculating the average time to remediate identified corrective actions is the most likely to provide meaningful metrics for this purpose. This metric indicates how quickly and consistently the organization and its third parties can resolve the issues and gaps that are discovered during the risk assessment and monitoring phases. It also reflects the level of collaboration and communication between the parties, as well as the alignment of expectations and standards. A lower average time to remediate implies a higher operational performance of the TPRM program, as it demonstrates a proactive and responsive approach to risk management12.

The other three examples are less likely to provide meaningful metrics for measuring the operational performance of implementing a TPRM program, as they do not directly measure the outcomes or impacts of the risk management activities. Logging the number of exceptions to existing due diligence standards may indicate the level of compliance and consistency of the TPRM program, but it does not show how the exceptions are handled or justified. Measuring the time spent by resources for task and corrective action plan completion may indicate the level of effort and resource allocation of the TPRM program, but it does not show how the tasks and plans contribute to the risk reduction or mitigation. Tracking the number of outstanding findings may indicate the level of exposure and vulnerability of the TPRM program, but it does not show how the findings are prioritized or addressed. References:

• 1: 15 KPIs & Metrics to Measure the Success of Your TPRM Program | UpGuard Blog
• 2: Third-Party Risk Management Reporting: What You Need to Know - Venminder

Infrastructure as a service (IaaS) is a cloud deployment model that provides users with access to virtualized hardware resources, such as servers, storage, and network devices. Users can install and run their own operating systems and applications on the cloud infrastructure, and have full control over the configuration and management of the hardware equipment. IaaS is suitable for organizations that need high scalability, flexibility, and customization of their cloud environment. IaaS is different from other cloud deployment models, such as function as a service (FaaS), platform as a service (PaaS), and software as a service (SaaS), which provide users with higher-level services and abstract away the underlying hardware details. References:

• Cloud Infrastructure: 4 Key Components and Deployment Models
• Cloud Deployment Models - GeeksforGeeks
• On-Premises Cloud Deployment Model: Organization-Owned Hardware Explained

Physical access procedures and activity logs are important components of third-party risk management, as they help to ensure the security and integrity of the physical assets and data of the organization and its third parties. However, requiring physical access logs to be retained indefinitely for audit purposes is not a best practice, as it may pose legal, regulatory, and operational challenges. According to the Supplemental Examination Procedures for Risk Management of Third-Party Relationships, physical access logs should be retained for a reasonable period of time, consistent with the organization’s policies and procedures, and in compliance with applicable laws and regulations1. Retaining physical access logs indefinitely may increase the risk of unauthorized access, data breaches, privacy violations, and litigation2. Therefore, the statement B is the correct answer, as it is the only one that does not reflect a best practice for physical access procedures and activity logs.

References:

• 1: How to Write Third-Party Risk Management (TPRM) Policies and Procedures - SecurityScorecard Blog
• 2: Five Best Practices to Manage and Control Third-Party Risk - Broadcom Inc.
• 3: A checklist for third-party risk management platforms - Crowe LLP
• 4: Supplemental Examination Procedures for Risk Management of Third-Party Relationships
• 5: Third Party Risk Management: Why It’s Important And What Features To Look For - Expert Insights

 Security vulnerabilities and security defects are not synonymous, but rather different concepts that relate to the security of software products or services. A security vulnerability is a weakness or flaw in the software that can be exploited by an attacker to compromise the confidentiality, integrity, or availability of the system or data12. A security defect is a mistake or error in the software code that causes the software to behave in an unexpected or incorrect way34. A security defect may or may not lead to a security vulnerability, depending on the context and impact of the defect. For example, a security defect that causes a buffer overflow may result in a security vulnerability that allows an attacker to execute arbitrary code on the system. However, a security defect that causes a spelling error in the user interface may not pose a security risk at all.

Security vulnerabilities and security defects have different causes, consequences, and solutions. Security vulnerabilities are often caused by design flaws, logic errors, or insufficient security controls in the software12. Security defects are often caused by poor coding practices, lack of testing, or human mistakes in the software development process34. Security vulnerabilities can have severe consequences for the software users, providers, and stakeholders, such as data breaches, identity theft, fraud, or sabotage12. Security defects can have various consequences for the software functionality, performance, or usability, such as crashes, glitches, or bugs34. Security vulnerabilities require proactive and reactive measures to prevent, detect, and mitigate the potential attacks, such as security testing, patching, monitoring, and incident response12. Security defects require corrective and preventive measures to identify, resolve, and avoid the errors, such as code review, debugging, refactoring, and quality assurance34.

Therefore, the statement that security vulnerabilities and security defects are synonymous is FALSE. They are distinct but related aspects of software security that require different approaches and techniques to address them. References: 1: What is a Software Vulnerability? | Veracode 2: Software Security: differences between vulnerabilities and Defects 3: What is a Software Defect? - Definition from Techopedia 4: Are vulnerabilities discovered and resolved like other defects? - Springer

  Performance risk, defined as the risk that a third party may not be able to meet its obligations due to inadequate systems or processes, accurately describes the situation. This type of risk involves concerns about the third party's ability to deliver services or products at the required performance level, potentially due to limitations in their technology infrastructure, operational procedures, or management practices. Identifying and managing performance risk is essential in Third-Party Risk Management (TPRM) to ensure that third-party vendors can reliably meet contractual and service-level agreements, thereby minimizing the impact on the organization's operations and service delivery.

References:

• TPRM guidelines, such as those from the Office of the Comptroller of the Currency (OCC) and the Federal Financial Institutions Examination Council (FFIEC), highlight the importance of assessing and managing performance risks associated with third-party relationships.
• The "Third-Party Risk Management Guide" by ISACA discusses various types of risks, including performance risk, associated with engaging third-party service providers, emphasizing the need for thorough due diligence and ongoing monitoring.

Remote monitoring of HVAC, Smoke, Fire, Water, or Power systems best reflects components of an environmental controls testing program. These systems are critical to ensuring the physical security and operational integrity of data centers and IT facilities. Environmental controls testing programs are designed to verify that these systems are functioning correctly and can effectively respond to environmental threats. This includes monitoring temperature and humidity (HVAC), detecting smoke or fire, preventing water damage, and ensuring uninterrupted power supply. Regular testing and monitoring of these systems help prevent equipment damage, data loss, and downtime due to environmental factors.

References:

• Environmental control standards such as ISO/IEC 27001 (Information Security Management) include requirements for the testing and monitoring of physical and environmental security controls.
• The "Data Center Operations Manual" by the Uptime Institute provides detailed guidelines on the testing and maintenance of environmental control systems to ensure the resilience and reliability of data center operations.

Termination for cause is the type of contract termination that is most likely to occur after failure to remediate assessment findings. This is because termination for cause is based on a breach of contract by the third-party, such as non-compliance, poor performance, fraud, or misconduct. Failure to remediate assessment findings indicates that the third-party has not met the contractual obligations or expectations of the entity, and thus exposes the entity to increased risk and liability. Termination for cause allows the entity to end the contract immediately or after a notice period, and to seek damages or remedies from the third-party. Termination for cause is different from other types of contract termination, such as:

• Regulatory/supervisory termination, which is triggered by a change in law or regulation that affects the legality or feasibility of the contract.
• Termination for convenience, which is exercised by the entity without any fault or breach by the third-party, usually for strategic or operational reasons.
• Normal termination, which is the natural expiration of the contract term or the completion of the contract scope. References:
• Shared Assessments. (2020). Certified Third Party Risk Professional (CTPRP) Study Guide1
• Fusion Risk Management. (2021). Exit Strategy for Terminating a Third Party2
• Volkov, M. (2016). Third-Party Risk Management – Part 2: Contract Termination3

When calculating residual risk, the best practice for an assessor is to adjust the vendor risk rating based on the changes to the risk level after analyzing the findings and considering the effectiveness of mitigating controls. Residual risk refers to the level of risk that remains after controls are applied to mitigate the initial (inherent) risk. By evaluating the findings from a third-party assessment and factoring in the mitigating controls implemented by the vendor, the assessor can more accurately determine the remaining risk level. This adjusted risk rating provides a more realistic view of the vendor's risk profile, aiding in informed decision-making regarding risk management and vendor oversight.

References:

• The concept of residual risk calculation is discussed in risk management frameworks such as ISO 31000 (Risk Management - Guidelines), which guides the assessment and treatment of risks.
• The "Third-Party Risk Management Guide" by ISACA outlines the process of assessing and managing risks associated with third parties, including the calculation of residual risk.

The frequency for conducting a vendor reassessment is not necessarily defined by regulatory obligations, but rather by the risk rating and criticality of the vendor, as well as the changes in the vendor’s environment, performance, and controls. Regulatory obligations may provide some guidance or minimum requirements for vendor reassessment, but they are not the sole determinant of the reassessment frequency. According to the Shared Assessments Program Tools User Guide, "The frequency of reassessment should be based on the risk rating and criticality of the vendor, as well as any changes in the vendor’s environment, performance, or controls. Regulatory guidance may also influence the frequency of reassessment."1 Similarly, the CTPRP Study Guide states, "The frequency of reassessment should be based on the risk rating and criticality of the vendor, as well as any changes in the vendor’s environment, performance, or controls. Regulatory guidance may also influence the frequency of reassessment."2

References:

• Shared Assessments Program Tools User Guide
• CTPRP Study Guide

According to the NIST Computer Security Incident Handling Guide1, one of the first steps in responding to an incident is to identify the scope, nature, and source of the incident. This involves gathering evidence, analyzing logs, interviewing witnesses, and performing forensic analysis. The goal is to determine the extent of the compromise, the type of attack, the identity or location of the attacker, and the potential impact on the organization and its stakeholders. This step is essential for containing the incident, mitigating the damage, and preventing further escalation or recurrence. References:

• NIST Computer Security Incident Handling Guide1, Section 3.2.2 Identification
• Cisco What Is an Incident Response Plan for IT?2, Section 2. Respond
• CrowdStrike Incident Response [Beginner’s Guide]3, Section 3. Incident Response Steps

The onboarding process for new hires is a key part of the third-party risk management program, as it ensures that the right people are hired and trained to perform their roles effectively and securely. One of the best practices for onboarding new hires is to conduct applicant screening, which may include background checks, reference checks, verification of credentials, and assessment of skills and competencies. Applicant screening helps to identify and mitigate potential risks such as fraud, theft, corruption, or data breaches that may arise from hiring unqualified, dishonest, or malicious individuals. Therefore, it is important to wait for the results of applicant screening before onboarding new employees and contractors, as this can prevent costly and damaging incidents in the future.

The other statements are false regarding the onboarding process for new hires. It is necessary to have employees, contractors, and third-party users sign confidentiality or non-disclosure agreements, as this protects the company’s sensitive information and intellectual property from unauthorized disclosure or misuse. Non-compete agreements may not be required for all job roles, as they may limit the employee’s ability to work for other companies or in the same industry after leaving the current employer. They may also be subject to legal challenges depending on the jurisdiction and the scope of the agreement. Security and privacy awareness training is essential for all new employees and contractors, regardless of their existing certifications, as it educates them on the company’s policies, procedures, and standards for protecting data and systems from cyber threats. It also helps to foster a culture of security and compliance within the organization. References:

• 5 Steps to Effective Third-Party Onboarding
• Using a third-party onboarding tool to address new challenges in third-party risk
• Onboarding and terminating third parties
• CTPRP Job Guide

Notification obligations in incident response are the legal or contractual duties to inform relevant parties about a security breach or incident that affects their data or systems. These obligations may vary depending on the type, scope, and impact of the incident, as well as the jurisdiction, industry, and contractual agreements involved. The factors that are most likely to trigger notification obligations are:

• Regulatory requirements: Different laws and regulations may impose different notification obligations on organizations that experience or cause a security incident. For example, the General Data Protection Regulation (GDPR) requires data controllers to notify the supervisory authority within 72 hours of becoming aware of a personal data breach, and to notify the affected data subjects without undue delay if the breach poses a high risk to their rights and freedoms1. Similarly, the Computer-Security Incident Notification Rule requires banks and their service providers to notify their primary federal regulator as soon as possible, but no later than 36 hours, after a computer-security incident that materially disrupts, degrades, or impairs their operations, services, or customers2.
• Data classification or sensitivity: The type and sensitivity of the data involved in a security incident may also affect the notification obligations. For example, if the data contains personally identifiable information (PII), health information, financial information, or other confidential or sensitive information, the organization may have to notify the data owners, regulators, law enforcement, or other stakeholders about the incident and the potential risks to their privacy or security3. The data classification or sensitivity may also determine the content and timing of the notification, as well as the appropriate communication channels to use.
• Contractual terms: The contractual agreements between an organization and its third-party vendors or service providers may also specify the notification obligations in case of a security incident. For example, the contract may define the roles and responsibilities of each party, the notification procedures and timelines, the information to be shared, the remediation actions to be taken, and the penalties or liabilities for breach of contract. The contractual terms may also reflect the regulatory requirements or industry standards that apply to the organization or the third party.

The factor that is least likely to trigger notification obligations is:

• Encryption of data: Encryption of data is a security measure that protects the data from unauthorized access, modification, or disclosure. Encryption of data may reduce the impact or severity of a security incident, as it may prevent or limit the exposure of the data to malicious actors. However, encryption of data does not eliminate the notification obligations, as the organization still has to assess the nature and extent of the incident, and determine whether the encryption was effective or compromised. Moreover, encryption of data may not be sufficient to protect the data from other types of threats, such as deletion, corruption, or ransomware. Therefore, encryption of data is not a factor that influences the notification obligations in incident response.

References:

• 1: GDPR Article 33: Notification of a personal data breach to the supervisory authority
• 2: Computer-Security Incident Notification Rule
• 3: Third-Party Incident Management (TPIM): How to Balance IRPs with Third Parties
• : [Improving Third-Party Incident Response]
• : [Third-Party Incident Response Playbook]
• : [Does Encryption Protect You From a Data Breach?]

 According to the GDPR, personal data is any information relating to an identified or identifiable natural person (data subject). The GDPR does not consider the volume of data records as a relevant factor for classifying personal data, but rather the nature and context of the data. The GDPR requires data controllers and processors to apply appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing personal data, taking into account factors such as the state of the art, the costs of implementation, the nature, scope, context and purposes of processing, and the risks of varying likelihood and severity for the rights and freedoms of natural persons. Therefore, the volume of data records is not a decisive attribute for classifying personal data, but rather an indicator of the potential impact of a data breach or misuse.

The other factors listed in the question are more important attributes for classifying personal data, as they relate to the identification, protection, and rights of the data subjects. The data subject category that identifies the data owner refers to the type of natural person whose personal data is processed, such as customers, employees, patients, students, etc. This factor is important for determining the purpose and legal basis of processing, as well as the data subject’s rights and expectations1. The sensitivity level of specific data elements that could identify an individual refers to the degree of harm or discrimination that could result from the disclosure or misuse of such data, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, sex life or sexual orientation, or criminal convictions or offenses2. The GDPR imposes stricter rules and obligations for the processing of such special categories of personal data, as they pose a higher risk to the data subject’s fundamental rights and freedoms. The assignment of a confidentiality level that differentiates public or non-public information refers to the degree of access and disclosure that is permitted or required for the personal data, depending on the data subject’s consent, the legitimate interests of the data controller or processor, or the applicable laws and regulations1. The GDPR requires data controllers and processors to implement data protection by design and by default, meaning that they should only process the personal data that is necessary for the specific purpose and limit the access to those who need to know.

References:

• 4: 5 Types of Data Classification (With Examples) | Indeed.com
• 7: Special Categories of Personal Data - GDPR EU
• [8]: Data Classification for GDPR Explained [Full Breakdown] - DataGrail

External continuous monitoring solutions are tools or services that provide objective and timely data on the cybersecurity posture and performance of third-party vendors. They typically include components such as:

• Status updates on localized events based on geolocation, which can alert the organization to potential disruptions or incidents affecting the vendor’s operations or infrastructure in a specific region or country12.
• Alerts on legal and regulatory actions involving the vendor, which can indicate the vendor’s compliance status, reputation, or liability exposure13.
• Reports that identify changes in vendor financial viability, which can signal the vendor’s ability to sustain its business operations, invest in security, or honor its contractual obligations14.

However, metrics that track SLAs for performance management are not typically included in external continuous monitoring solutions, as they are more relevant for internal monitoring and reporting. SLAs are service level agreements that define the expected quality, availability, and reliability of the vendor’s services or products, as well as the penalties or remedies for non-compliance. SLAs are usually measured and reported by the vendor itself, or by a third-party auditor or assessor, based on the specific criteria and frequency agreed upon by the parties . Therefore, option C is the correct answer. References:

• Third Party Risk Management Framework, Module 5: Program Implementation, Section 5.2: Ongoing Monitoring, p. 32
• Bitsight Continuous Monitoring, Section: Uncover hidden risks
• Best-Practices Guidance for Third-Party Risk, Section: Monitor Third-Party Compliance with Regulations and Standards, p. 3
• Five Best Practices to Manage and Control Third-Party Risk, Section: Monitor Third-Party Financial Health, p. 4
• [Third Party Risk Management Framework], Module 4: Program Components, Section 4.3: Contracting, p. 24
• [A Better Way to Manage Third-Party Risk], Section: Establish clear service level agreements (SLAs) and key performance indicators (KPIs), p. 2

In the context of Third-Party Risk Management (TPRM) requirements within the Software Development Life Cycle (SDLC), a process for data destruction and disposal is not typically considered a key component. The primary focus within SDLC in TPRM is on ensuring secure software development practices, which includes maintaining artifacts to prove that SDLC gates are executed, conducting software security testing, and having processes in place for fixing security defects. While data destruction and disposal are important security considerations, they are generally associated with data lifecycle management and information security management practices rather than being integral to the SDLC process itself.

References:

• Best practices in secure software development, as outlined in frameworks like the Secure Software Development Framework (SSDF) by NIST, emphasize the importance of secure coding, vulnerability testing, and remediation processes rather than data disposal practices.
• The "Software Security Framework (SSF)" by the Open Web Application Security Project (OWASP) provides guidance on integrating security practices into the SDLC, focusing on areas like threat modeling, secure coding, and security testing.

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.

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

Terms for return or destruction of data should be defined and agreed upon during contract negotiation, as this is the phase where the organization and the third party establish the expectations, obligations, and responsibilities for the relationship, including the handling of data. According to the Shared Assessments CTPRP Study Guide, contract negotiation is the phase where "the organization and the third party negotiate and execute a contract that clearly defines the expectations and responsibilities of both parties, including the scope of work, service level agreements, performance measures, reporting requirements, compliance obligations, security and privacy controls, incident response procedures, dispute resolution mechanisms, termination rights, and other relevant terms and conditions."1 One of the key contractual terms that should be addressed is the return or destruction of data, which specifies how the third party will return or dispose of the organization’s data at the end of the relationship, or upon request, in a secure and timely manner. This term is important for ensuring the organization’s data protection, confidentiality, and compliance, as well as reducing the risk of data breaches, leaks, or misuse by the third party or unauthorized parties.

The other phases of the TPRM lifecycle are not the best choices for defining and agreeing upon terms for return or destruction of data, because:

• B. At third party selection and initial due diligence: This is the phase where the organization identifies, evaluates, and selects the third party that best meets its needs, objectives, and risk appetite. This phase involves conducting due diligence on the third party’s capabilities, qualifications, reputation, performance, security, and compliance, as well as assessing the inherent risk of the relationship. While this phase is important for screening and choosing the right third party, it does not involve defining and agreeing upon the specific terms and conditions of the relationship, such as the return or destruction of data, which are usually done in the contract negotiation phase.
• C. When deploying ongoing monitoring: This is the phase where the organization monitors and reviews the third party’s performance, service delivery, risk management, and compliance on a regular basis, as well as identifies and addresses any issues, gaps, or changes that may arise during the relationship. This phase involves collecting and analyzing data and information from various sources, such as reports, audits, assessments, surveys, feedback, incidents, and metrics, as well as communicating and collaborating with the third party to ensure alignment and improvement. While this phase is important for ensuring the quality and security of the relationship, it does not involve defining and agreeing upon the terms and conditions of the relationship, such as the return or destruction of data, which are usually done in the contract negotiation phase.
• D. At termination and exit: This is the phase where the organization terminates and exits the relationship with the third party, either by mutual agreement, expiration of contract, breach of contract, or other reasons. This phase involves executing the termination and exit plan, which may include notifying the third party, transferring or discontinuing the services, settling the financial obligations, returning or destroying the data, revoking the access rights, and conducting a post-termination review. While this phase is important for ensuring a smooth and secure transition and closure of the relationship, it does not involve defining and agreeing upon the terms and conditions of the relationship, such as the return or destruction of data, which are usually done in the contract negotiation phase.

References:

• 1: Shared Assessments CTPRP Study Guide, page 59, section 5.1: TPRM Lifecycle
• : Third-Party Risk Management: Vendor Contract Terms and Conditions, section: Data Ownership, Return and Destruction
• : [Third-Party Risk Management: The 3rd Party Ecosystem: How to Manage the Risk While Keeping the Benefit], section: Contract Negotiation
• : [Third-Party Risk Management: The 3rd Party Ecosystem: How to Manage the Risk While Keeping the Benefit], section: Termination and Exit

An organization’s Ethics and Code of Conduct Program is a set of policies, procedures, and practices that define the expected standards of behavior and ethical values for all employees and stakeholders. A key component of such a program is a disciplinary process that outlines the consequences and actions for violating the code of conduct or any other relevant policies. A disciplinary process helps to enforce the code of conduct, deter unethical behavior, and protect the organization’s reputation and integrity. A disciplinary process should include clear criteria for determining the severity and frequency of violations, the roles and responsibilities of the parties involved, the steps and timelines for investigation and resolution, and the range of sanctions and remedies available. A disciplinary process should also be fair, consistent, transparent, and respectful of the rights and dignity of the accused and the accuser. A disciplinary process may involve formal termination or change of status of the employee, depending on the nature and impact of the violation. Therefore, option B is a correct component of an organization’s Ethics and Code of Conduct Program.

The other options are not necessarily components of an Ethics and Code of Conduct Program, although they may be related or supportive of it. Option A, participation in the company’s annual privacy awareness program, is more likely to be a component of a Privacy Program, which is a specific area of ethics and compliance that deals with the protection and use of personal information. Option C, signing acknowledgement of Acceptable Use policy for use of company assets, is more likely to be a component of an Information Security Program, which is another specific area of ethics and compliance that deals with the safeguarding and management of data and systems. Option D, a process to conduct periodic access reviews of critical Human Resource files, is more likely to be a component of an Internal Control Program, which is a general area of ethics and compliance that deals with the design and implementation of controls to ensure the reliability and accuracy of financial and operational information. References:

• 1: Creating an Effective Code of Conduct (and Code Program) - Corporate Compliance Insights
• 2: Code of Conduct & Ethics (Examples and Best Practices) - Status.net
• 3: Why Have a Code of Conduct - Free Ethics & Compliance Toolkit
• 4: “Code of Ethics” and “Code of Conduct” - GeeksforGeeks
• 5: Six Tips on How to Implement a Strong Ethics Program - KnowledgeLeader

Vendor management is the process of coordinating with vendors to ensure excellent service to your customers12. It involves activities such as selecting vendors, negotiating contracts, controlling costs, reducing vendor-related risks and ensuring service delivery12. One of the key activities of vendor management is managing service level agreements (SLAs), which are contracts that define the expectations and obligations of both parties regarding the quality, quantity, and timeliness of the goods or services provided3. SLAs help to monitor and measure vendor performance, identify and resolve issues, and enforce penalties or rewards based on the agreed-upon metrics3. The other options are not correct because they do not reflect the concept of vendor management as a whole, but rather specific aspects or tools of vendor management. Scanning and collecting information from third party web sites, reviewing and analyzing external audit reports, and receiving and analyzing a vendor’s response to a questionnaire are all examples of methods or sources of information that can be used to conduct vendor due diligence, risk assessment, or performance evaluation, but they are not the only or the most important activities of vendor management. References:

• What is Vendor Management? Definition, Process, and Tools
• What is vendor management? | Definition & Process | Taulia
• Essential Guide to Vendor Management | Smartsheet, section “Service Level Agreements”

 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

Risk treatment is the process of selecting and implementing measures to modify risk, according to the organization’s risk appetite and tolerance. There are four main risk treatment options: avoid, reduce, transfer, or retain the risk123. Among these options, risk transfer typically requires a negotiation of contract terms between parties, as it involves shifting the responsibility or burden of the risk to another entity, such as an insurer, a supplier, a partner, or a customer1234. Risk transfer can be achieved through various contractual arrangements, such as insurance policies, indemnity clauses, warranties, guarantees, service level agreements, or outsourcing agreements1234. These arrangements usually involve a cost-benefit analysis, a due diligence process, and a mutual agreement on the terms and conditions of the risk transfer1234. Therefore, option D is the correct answer, as it is the only one that reflects a risk treatment approach that typically requires a negotiation of contract terms between parties. References: The following resources support the verified answer and explanation:

• 1: Risk Treatment — ENISA
• 2: Four Basic Risk Treatment Planning Approaches - DigiLEAF
• 3: 3 Steps to Treating Your Organizational Risks - American Society of …
• 4: Risk Management Framework - Treat Risks - Chartered Accountants ANZ

A mobile device policy is a set of rules and guidelines that define how an organization’s employees and contractors can use and secure their mobile devices, such as laptops, smartphones, and tablets, to access the organization’s data and network1. A mobile device policy typically covers aspects such as device configuration, authentication, encryption, backup, remote wipe, malware protection, acceptable use, and incident response23.

A mutual NDA is a legal agreement that binds both parties to protect the confidentiality of the information they share with each other. A mutual NDA is usually signed before engaging in a business relationship with a third party, such as a vendor, partner, or customer. A mutual NDA is not directly related to the use and security of mobile devices, and therefore is less likely to be included in an organization’s mobile device policy. A mutual NDA may be part of a broader contract or agreement with a third party, but it is not specific to mobile devices.

The other options are more likely to be included in an organization’s mobile device policy, as they address the risks and responsibilities associated with mobile devices. For example:

• Language on restricting the use of the mobile device to only business purposes can help prevent unauthorized access, data leakage, and malware infection from personal or untrusted applications or websites2.
• Language detailing the user’s responsibility to not bypass security settings or monitoring applications can help ensure compliance with the organization’s security standards and policies, and enable the detection and prevention of potential incidents2.
• Language detailing specific actions that an organization may take in the event of an information security incident can help define the roles and responsibilities of the users and the organization, and the procedures for reporting, investigating, and resolving incidents involving mobile devices23.

References:

• 1: Mobile Device Policy1, Section 1. Introduction
• 2: Risk Management Guidelines for Mobile Devices2, Section Data Security
• 3: Guidelines for Managing the Security of Mobile Devices in the Enterprise3, Section 4. Recommendations for Mobile Device Security
• [4]: What is a Mutual NDA?, Section What is a Mutual NDA?
• [5]: Non-Disclosure Agreement (NDA) Definition, Section Understanding Non-Disclosure Agreements

Restrictive areas are those that contain sensitive or critical assets, systems, or information that require additional protection from unauthorized access or tampering. Access control is the process of granting or denying access to these areas based on predefined policies, rules, and criteria. An additional authentication factor is a method of verifying the identity or authorization of a user or device that is used in conjunction with another factor, such as a password, a token, or a biometric feature. Additional authentication factors enhance the security and reliability of access control by reducing the risk of impersonation, compromise, or theft of credentials.

The example that best represents the set of restrictive areas that require an additional authentication factor for access control is A. Datacenters; telecom rooms; server rooms; exterior building entrance. These areas contain vital infrastructure, equipment, and data that are essential for the organization’s operations, performance, and security. Unauthorized access to these areas could result in significant damage, disruption, or loss of data, services, or resources. Therefore, these areas should be protected by multiple layers of access control, including physical and logical barriers, as well as additional authentication factors, such as smart cards, biometrics, or one-time passwords.

The other examples are less likely to represent the set of restrictive areas that require an additional authentication factor for access control, because they either contain less sensitive or critical assets, systems, or information, or they are more accessible or visible to the public or other authorized users. For example:

• B. Datacenters; telecom rooms; security operations centers; loading docks: While datacenters, telecom rooms, and security operations centers are restrictive areas that require an additional authentication factor for access control, loading docks are not. Loading docks are typically open to external vendors, suppliers, or delivery personnel, and may not contain any sensitive or critical assets, systems, or information. Therefore, loading docks may not require an additional authentication factor for access control, but rather a basic verification of identity or authorization, such as a badge, a signature, or a receipt.
• C. Telecom rooms; parking garage; security operations centers; exterior building entrance: While telecom rooms, security operations centers, and exterior building entrance are restrictive areas that require an additional authentication factor for access control, parking garage is not. Parking garage is usually accessible to employees, visitors, or customers, and may not contain any sensitive or critical assets, systems, or information. Therefore, parking garage may not require an additional authentication factor for access control, but rather a simple validation of access rights, such as a ticket, a code, or a gate.
• D. Exterior building entrance; datacenters; telecom rooms; printer rooms: While exterior building entrance, datacenters, and telecom rooms are restrictive areas that require an additional authentication factor for access control, printer rooms are not. Printer rooms are generally available to all employees or authorized users, and may not contain any sensitive or critical assets, systems, or information. Therefore, printer rooms may not require an additional authentication factor for access control, but rather a standard authentication factor, such as a password, a PIN, or a fingerprint.

References:

• Shared Assessments CTPRP Study Guide, page 46, section 4.3.1: Access Control
• Access Controls Over Third-Party Applications, section: Vendor Access
• Controlling Third-Party Access Risk, section: Best Practices for Controlling Third-Party Vendor Risks, bullet point: Implementing supporting processes and controls that define and enforce access policies for third-party privileged users.