🔗 Management of third parties and supply chains
How to manage the risks posed by suppliers, service providers and software dependence by international practice (ISO 27036, NIST SP 800-161, NIS2, DORA, CRA, SLSA). Examples are fictional, designed for training.
Why It Is Important
Extended attack surface - each third introduces risk
Risks to third parties
Risk to the organisation from external suppliers, service providers and software components with access to your data, systems or processes. You remain responsible for the consequences, even if the third party is guilty.
Related standards
ISO/IEC 27036 (security of supplier relations), NIST SP 800-161 Rev.1 (C-SCRM), NIST CSF 2.0 function GOVERN (GV.SC), NIS2 21(2) (d), DORA (financial ICT third party), CRA (product safety).
Fourth party risk
Your suppliers (fourth and furthest sides) and the risk of concentration (too much dependence on one cloud or service) often remain invisible, but can stop operation just like a direct incident.
Third Party Life Cycle
TPRM life cycle with continuous revaluation
Pre-contractual due diligence
Prior to cooperation, the security status of the supplier shall be assessed: Shared Assessments SIG, independent opinions (SOC 2 Type II, ISO 27001 certificate), intrusion test summaries and financial stability.
Contract safeguard clauses
Data processing contract (DPA, Article 28 GDPR), SLA with security objectives, right to audit, deadlines for notification of incidents, approval of sub-processors and data return/removal shall be terminated.
Continuous monitoring
One questionnaire is not enough: the security situation is changing. Follow safety ratings, vulnerability to warnings and certificate validity, and re-evaluate the supplier on a regular basis - the more critical, the more frequent.
Tiering and due diligence depth
Criticality classification determines test depth
Why Tiering
All suppliers are not equally risky. Classification allows to devote limited resources to the most critical - deep examination where the consequences are greatest, easy where the risk is minimal.
Standardised questionnaires
Shared Assessments SIG (Standardized Information Gathering) - industry standard questionnaire for assessment of safety status. SIG Lite for lower risk, SIG Core for deeper testing. CAIQ (Cloud) for cloud services.
Independent opinions
SOC 2 Type II (AICPA) - effectiveness of control over the time period. ISO/IEC 27001 certificate - ISMS compliance. ISAE 3402 for international services. They reduce the need for own audit.
Software supply chain
Software supply chain - attacks and defences
SBOM - List of constituents
Software Bill of Materials - machine-readable list of all software components and dependencies (formats SPDX, CycloneDX). Lets quickly determine whether you are affected by a new vulnerability (e.g. Log4Shell).
SLSA and signing
SLSA (OpenSSF) - building integrity levels with provenance (evidence of origin). Signing artifacts with Sigstore/cosign makes it possible to verify that the package comes from a reliable construction and is not counterfeit.
Dependent hygiene
Fixed versions and lockfile (repeated structures), SCA scanning (OWASP Dependency-Check, pip-audit, Trivy), monitoring of transitive addiction and OpenSSF Scorecard project for health evaluation before implementation.
Standards and regulation
Landscape of supply chain security standards
NIS2 - Legal requirement
Article 21 (2) (d) of the NIS2 Directive (EU 2022/2555) provides for supply chain security as a mandatory risk management measure, including security aspects in relation to direct suppliers and service providers.
ISO 27036 and NIST 800-161
ISO/IEC 27036 provides a governance framework for the security of supplier relationships. NIST SP 800-161 Rev.1 (C-SCRM) - detailed practices for managing cybersecurity supply chain risks at system and organisation level.
DORA and CRA
DORA (Regulation (EU) 2022/2554, applicable from 17 January 2025) regulates the supervision of financial sector ICT third party risk and critical service providers. Cyber Resilience Act (Regulation (EU) 2024/2847) imposes safety requirements on manufacturers of products with digital features across the EU market: reporting on actively used vulnerabilities from 11 September 2026, full requirements from 11 December 2027.
Practical controls
Three-layer controls + invisible risks
The Treaty is the first line of protection
The security requirements must be incorporated into the contract before signing - it is difficult to add them later. Data processing contract, SLA with measurable security objectives, audit authority and clear incident notification deadlines.
Technical insulation
Give the supplier only the necessary (lat privilege), isolate his access (segmentation, Zero Trust), request MFA and log operations. It limits injury when the supplier is compromised.
Planned exit from the beginning
The concentration and fourth party risk require a plan to replace the supplier and a continuity check. The supplier's incident is your incident - including suppliers in the incident response plan and training.
Abbreviations
Abbreviations used in the Roadmap: the original name and what it means.
- TPRM
- Third-Party Risk Management - third party risk management.
- C-SCRM
- Cyber Supply Chain Risk Management - cybersecurity supply chain risk management (NIST SP 800-161).
- SBOM
- Software Bill of Materials - list of software components and addictions.
- SPDX / CycloneDX
- Two SBOM formats.
- SLSA
- Supply-chain Levels for Software Artifacts - building integrity levels.
- SCA
- Software Composition Analysis - verification of dependence against known injuries.
- SSDF
- Secure Software Development Framework - NIST Safe Development Practices (SP 800-218).
- SIG
- Standardized Information Gathering - Shared Assessments supplier safety questionnaire.
- CAIQ
- Consensus Assessments Initiative Questionnaire - Cloud Service Security Questionnaire (CSA).
- SOC 2
- System and Organization Controls 2 - an independent auditor's opinion on the controls of the service provider.
- ISAE 3402
- International standard for the opinion of controls of service organisations.
- AICPA
- American Institute of Certified Public Accountants - the US Institute of Auditors, which issues SOC standards.
- DPA
- Data Processing Agreement - data processing contract (Article 28 GDPR).
- SLA
- Service Level Agreement - service level agreement - availability, response time.
- MSP
- Managed Service Provider - the company that manages the client's IT.
- DORA
- Digital Operational Resilience Act - the EU Financial Sector Digital Sustainability Regulation.
- CRA
- Cyber Resilience Act - EU regulation on the safety of digital products.
- IKT / ICT
- Information and communication technologies
- BCP / DR
- Business Continuity Plan / Disaster Recovery - business continuity plan / recovery from an accident.
- EO 14028
- Executive Order 14028 - U.S. Presidential Order on Cyber Security (2021), requires SBOM.
- OpenSSF
- Open Source Security Foundation - the organisation maintaining SLSA and Scorecard.
- CI/CD
- Continuous Integration / Continuous Delivery - the construction, testing and delivery of an automatic code.