Keep your Intellectual Property Always Protected
The key reason in TPRM for data remanence is failing to effectively off-board Third Parties. Be it protecting your Intellectual Property (IP), customer data, technology integration and paying invoices, companies can suffer the risk of data exposure, or accidental/overspending when off-boarding is not treated in the same way as onboarding. Data retention due to regulations makes it important to revisit clauses in the contract to ensure data security after off-boarding.
All Third Parties in the inventory should pass through an Off-boarding process before their services are terminated just like how every Third Party should be onboarded. A clear indication of which departments should be involved, what prerequisites need to be met and a well-defined process with monitoring plays a vital role in effectively off-boarding Third Parties. This way you can be certain to reduce or perhaps eliminate the risk of
- Unauthorized data exposure,
- Unauthorized data retention,
- Unapproved retention of technology integrations and
- Failure to add necessary clauses in the contract to safeguard the interests of your organization.
The evidence-based off-boarding process from all stakeholders should be obtained to ensure Third Parties meet the off-boarding requirements. An organization should carefully consider the interdependencies and approval process in place by following the RACI. Continuous monitoring also plays a vital role during termination and off-boarding. Designing a TPRM program that ties all ends and has a dependency on the prior or next step allows an organization to have more control over how the lifecycle is maintained and challenges kept to a bare minimum. Often after termination of the engagement, there aren’t enough data governance controls and clauses, and this can lead to a considerable amount of time and cost to retrieve data.
Common Challenges Faced by the Businesses
- Complex, tedious and de-centralized off-boarding process
- Lack of visibility on data or access retained with Third Party post off-boarding which may not be secured with adequate security controls
- Insufficient language in the contract around data confidentiality, privacy, data deletion and regulatory requirements may violate regulations and may negatively impact the image of the organization and client trust
- Technology Integrations that remain intact after off-boarding which can lead to unauthorized access and data exfiltration resulting in an incident or beach, especially with regulated data, have one coming your way (regulatory fines!)
- Technology risk leading to business risk affecting brand reputation, client trust, stock prices and investigations
- High cost of off-boarding Third Parties with a keen eye on downtime and knowledge transfer
- Legal, Financial and Reputational risk due to any incidents that could result in unauthorized data exposure or exfiltration. Some of the prominent incidents to name a few
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- In 2023, a hacker targeted a Third Party who was engaged for a limited time and was not delivering service any more. 52,000 records were leaked
- In 2021, a former employee’s access to an off-boarded Third Party was not de-provisioned which resulted in an information leak of archived PHI data
- In 2019, a major hotel chain suffered a breach when a hacker accessed the network of a formerly used Third Party
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What we do in the TPRM Termination & Off-boarding Phase
Customized Off-boarding process and a checklist that key stakeholders can follow will ensure a well-defined and seamless process to securely off-board Third Parties
Intertwine process that will enable the team to integrate onboarding and off-boarding that is tied to the overall lifecycle
Customized approach and an effective process to practice continuous monitoring during off-boarding by factoring in the interdependencies
Standard templates and forms to ease the operations and maintain consistency in communications
Training/workshop for the stakeholders to socialize the process with supporting documentation
Build a process to centralize the process and repository
Benefits associating with Defentrix under TPRM Termination & Offboarding
Repeatable and mature process to demonstrate effective off-boarding practices
As part of both internal and external audits, it’s imperative to demonstrate an effective and efficient process on how your organization successfully manages off-boarding
Showcase the reduction of risk exposure to leadership
Pro-actively initiating the off-boarding process by engaging the right teams, saves valuable time and will cost the business less which can be showcased as a huge win
Safeguard the organization from risks of data retention, deletion and retrieval
Sufficient coverage in the contract by adding relevant clauses around retrieval and (or) retention of the confidential data in the desired format with each of the data attributes should be included and it needs to be exercised
Achieve regulatory compliance (healthcare, banking, privacy, insurance etc.)
Owing to the many state, federal, privacy, security and financial regulations, data needs to be retained for a fixed number of years and should be available for retrieval on demand. While it is being retained, the Third Party should demonstrate sufficient evidence of security controls to protect the Confidentiality, Integrity and Availability of the confidential information.
Compliance with internal and external audit
A strong risk-aware culture within and across the organization will help the stakeholders to exercise the process, and align with the procedure and best practices documented as part of the Third Party Risk Management (TPRM) process. This will greatly benefit during the internal and external audit and result in less to no non-conformities or observations.
Avoid Legal, Reputational and Financial Risk
Having a well-defined process which is periodically audited, allows the teams to adhere to and not deviate from the process which will considerably reduce the risk of any negligence or incomplete off-boarding of Third Parties
Worried about your Information Security and TPRM?
Contact us today for complete consulting and implementation of Information Security
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