Lessons Learned in Streamlining the Third-party Risk Assessment Process

Transcription

1 Lessons Learned in Streamlining the Third-party Risk Assessment Process

2 Agenda Welcome & Introductions Overview of the Third Party Risk Management Lifecycle Three Unique Perspectives on: Third Party Inventories Due Diligence & Ongoing Monitoring How the HITRUST Assurance Program Helps Third Parties (Service Provider Perspective Q&A & Wrap-up

3 Introductions Aaron Shapiro PwC Director Cybersecurity & Privacy Jeff Martin Senior Manager Information Security Anthem Debbie Hutchinson Availity Senior Manager Audit and Third Party Assurance

4 Overview of the Third Party Risk Management Lifecycle A robust Third Party Risk Management (TPRM) program is based on adoption of key building blocks, and successfully linking the program strategy, policies and processes together. TPRM is focused on understanding and managing risks associated with vendors and other third parties with which the company does business and/or shares data. The PwC Third Party Risk Management Program Framework Third parties Vendors Suppliers Joint Ventures Business Channels Marketing Partners Affiliates Subsidiaries Regulated Entities Pre-contract lifecycle activities TPRM Program Components Governance Framework Policy & Procedures Inventory Stratification Issues Management Risk Considerations Reputational Operational Credit/Financial Business Continuity and Resiliency Strategic/Country Subcontractor Technology Info Security & Privacy Compliance Post contract lifecycle activities PwC. Not for further distribution without the prior written permission of PwC. PwC refers to the US member firm or one of its subsidiaries or affiliates, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see for further details.

5 PwC THREE UNIQUE PERSPECTIVES

6 Residual risk maturity ranking Standard risk definition Controls do not exist/are not in place Controls are in place but are not documented appropriately or currently are not reviewed/ tested; controls are not consistently followed Controls are in place and are documented and reviewed; manual or partial automation Controls are in place, are documented appropriately, are reviewed on a periodic basis, have continuous control monitoring and fully automated if available Segment 1 Critical Segment 2 High Risk Inherent risk rating Segment 3 Moderate Risk Nature Timing Extent Nature Timing Extent Nature Timing Extent 1 Onsite Annual 2 Onsite Annual 3 Onsite 4 Onsite Testing Testing Testing Testing Onsite Onsite Onsite Onsite Annual Testing Testing Testing Testing Onsite Remote Remote Remote 18 Annual Testing Inquiry Inquiry Inquiry Segment 4 Low Risk Nature Timing Extent Remote Remote Self- Assess Self- Assess Month Inquiry Inquiry Inquiry Inquiry Three Unique Perspectives - PwC Third party inventory, stratification, due diligence & on-going assessment model The inventory, risk rating and on-going testing model enables a focus on efforts to establish the third party inventory and oversee services with higher levels of inherent risk. Refine Establish On-board Oversee Govern Existing Third Party Inventory Inherent risk assessment Pre-contract due diligence & residual risk Nature, timing and extent & On-going due diligence Refresh & Re-rank Residual risk rating New Third Parties Metrics & Reporting Third Party Scorecards Program Dashboards PwC. Not for further distribution without the prior written permission of PwC. PwC refers to the US member firm or one of its subsidiaries or affiliates, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see for further details.

7 Three Unique Perspectives - PwC Third party inventory This framework will assist the TPRM Program in focusing in on the inventory list by analyzing multiple sources in rapid manner and identifying the third parties that need to be included as part of the program, and rated by inherent risk. Total Third Party Inventory from mul6ple data sources Begin with A/P Spend and LOB files and remove categories that don t pose risk Iden6fy unique third par6es and validate services against exis6ng invoices/data sources. Remove categories that don t pose risk Perform cleansing and enhancement of third party data In-scope third party inventory for risk segmenta6on Inherent risk assessment Inherent Risk Ra6ng Star6ng with commodity categories, we use a process to focus on those products/services that do and do not pose inherent risk and thus to be included as part of the program. We then clean and enhance the exis6ng third party data to be put into the inventory repository. Common Third Party Inventory Data A4ributes Third Party Name Third Party Parent Name/Associated Third Par6es Product/Service Third Party Type (Business Process Outsourcing, Partnership, Technology etc.) Spend Business Lines/Processes Supported by the Third Party Country/Region where Third Party is Based Contract Date (Engagement Date) Results of Third Party Risk Classifica6on Results of s (e.g., Third Party Informa6on Security Assessments) PwC. Not for further distribution without the prior written permission of PwC. PwC refers to the US member firm or one of its subsidiaries or affiliates, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see for further details.

8 Three Unique Perspectives - PwC Due Diligence, Ongoing Monitoring & HITRUST Assurance Results of the inherent risk should drive the nature, timing and extent of activities used to monitor, oversee, and re-assess third party relationships. Due to the higher costs associated with more in-depth assessment activities, a risk based approach should be leveraged so that higher risk relationships receive more active risk management than lower risk relationships. Depth of Due Diligence Activities 0% None Very Low 40-50% Request and review third party report (e.g., HITRUST certification, SOC 1/2/3, ISO certification, etc.) Low 20-30% Inherent Risk Rating Require the completion and evaluation of a due diligence questionnaire Request and review third party report (e.g., HITRUST certification, SOC 1/2/3, ISO certification, etc.) Moderate 10-15% Perform on-site assessments (1-5 days) Require the completion and evaluation of a due diligence questionnaire Request and review third party report (e.g., HITRUST certification, SOC 1/2/3, ISO certification, etc.) High 3-5% PwC. Not for further distribution without the prior written permission of PwC. PwC refers to the US member firm or one of its subsidiaries or affiliates, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see for further details.

9 Anthem THREE UNIQUE PERSPECTIVES

10 Third Party Inventories - Anthem Follow the data; not the spend. Requires strong internal partnerships. Risk tiering can be more difficult in a highly regulated space. In-scope inventories can tend to balloon.

11 Due Diligence and Ongoing Monitoring- Anthem Inefficient pre-contract due diligence processes can impede timely procurement processes. Again, strong internal partnerships are necessary. Especially for larger organizations. Change is constant. Assessments are a point-in-time measurement. Additional pressures for enhancing ongoing monitoring. New regulations, new technologies, global marketplace, maturing client base.

12 How HITRUST Assurance Program Helps - Anthem Risk assurance activity can create exponential volumes of work. Leveraging the HITRUST Assurance Program helps to ensure a consistent and efficient approach. Anthem Information Security is requiring vendor Business Associates to achieve HITRUST certification on the environment that supports Anthem. Anthem Business Associates can leverage their HITRUST certification across the HITRUST Alliance partners.

13 Availity THREE UNIQUE PERSPECTIVES

14 Third Party Inventories - Availity Conduct a complete inventory of all third parties activities ranked by risk factors. Include all types of third party relationships that can include business associates, trading partners, service partners, subcontractors etc. Evaluate the relationships to have a comprehensive understanding of who are your third parties, what services/ functions they provide and what level of access they have to your organization s data/systems.

15 Due Diligence and Ongoing Monitoring- Availity Conduct due diligence assessments to identify any potential gaps that could create risks or compliance issues prior to contract. Third parties who have completed a HITRUST validated assessment may submit certification letter as part of their due diligence. Continue to monitor relationships to proactively account for any changes that can occur throughout the relationship cycle. Organizations need to move beyond the initial due diligence and annual reviews to proactively address the bigger challenge of monitoring and assessing third-party risks on an ongoing basis.

16 How HITRUST Assurance Program Helps Availity HITRUST assessment can help to evaluate your third party assurance program. Accepting the HITRUST certification can help due diligence by reducing time and efforts. Leveraging the CSF enables a single assessment to be accepted by many organizations across the industry. Focusing on third party risk management and consistent requirements of our third parties can help drive industry efficiencies.

17 Third Parties (Service Provider) Perspective Ability to effectively respond varies drastically Customer assessments come in all shapes and sizes and it can be very frustrating and difficult for third parties to respond timely Alignment to a recognized security/privacy framework (e.g., HITRUST CSF) helps organizations respond quickly, with less effort, and with positive results HITRUST certification and SOC 2s can relieve much of the headache associated with responding to customer requests

18 Q&A