Performing due diligence during third party risk assessments is a process of verifying and validating the information provided by the third parties, as well as identifying and assessing any potential risks or issues that may arise from the relationship. Due diligence methods may vary depending on the type, scope, and complexity of the third party engagement, but they generally involve the following steps123:
Interviewing subject matter experts or control owners: This method involves engaging with the relevant stakeholders from both the organization and the third party, such as business owners, project managers, legal counsel, compliance officers, security analysts, etc. The purpose of the interviews is to gather more information about the third party’s capabilities, processes, policies, performance, and challenges, as well as to clarify any questions or concerns that may arise from the questionnaire or other sources. The interviews can also help to establish rapport and trust between the parties, and to identify any gaps or discrepancies in the information provided.
Reviewing compliance artifacts: This method involves examining the evidence or documentation that supports the third party’s claims or assertions, such as certifications, accreditations, audit reports, policies, procedures, contracts, SLAs, etc. The purpose of the review is to verify the accuracy, completeness, and validity of the artifacts, as well as to assess the level of compliance with the applicable standards, regulations, and best practices. The review can also help to identify any areas of improvement or weakness in the third party’s controls or processes.
Validating controls: This method involves testing or inspecting the actual implementation and effectiveness of the third party’s controls or processes, such as security measures, quality assurance, data protection, incident response, etc. The purpose of the validation is to confirm that the controls are operating as intended and expected, and that they are sufficient to mitigate the risks or issues identified in the assessment. The validation can also help to identify any vulnerabilities or gaps in the third party’s controls or processes.
The other options are not as comprehensive or accurate as the methods described above, as they may not cover all the aspects or dimensions of the third party risk assessment, or they may rely on incomplete or outdated information. Inspecting physical and environmental security controls by conducting a facility tour is only one part of the validation method, and it may not be applicable or feasible for all types of third parties, such as cloud service providers or remote workers. Reviewing status of findings from the questionnaire and defining remediation plans is more of a follow-up or monitoring activity, rather than a due diligence method, as it assumes that the questionnaire has already been completed and analyzed. Reviewing and assessing only the obligations that are specifically defined in the contract is a narrow and limited approach, as it may not capture the full scope or complexity of the third party relationship, or the dynamic and evolving nature of the risks or issues involved. References:
Third Party Due Diligence – a vital but challenging process
The guide to risk based third party due diligence - VinciWorks
Third Party Risk Assessment – Checklist & Best Practices
