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TPM-21.1: Security Compromise Notification Agreements

TPM 9 — Critical Detect

Mechanisms exist to compel External Service Providers (ESPs) to provide notification of actual or potential compromises in the supply chain that can potentially affect or have adversely affected Technology Assets, Applications and/or Services (TAAS) that the organization utilizes.

Renumbered: Formerly TPM-05.1 in SCF 2025.4.

Control Question: Does the organization compel External Service Providers (ESPs) to provide notification of actual or potential compromises in the supply chain that can potentially affect or have adversely affected Technology Assets, Applications and/or Services (TAAS) that the organization utilizes?

General (23)
US (13)
Framework Mapping Values
USA Federal CISA CPG 2022 1.G
USA Federal CJIS Security Policy 6.0 SR-8
USA Federal FedRAMP R5 (low) SR-08
USA Federal FedRAMP R5 (moderate) SR-08
USA Federal FedRAMP R5 (high) SR-08
USA Federal FedRAMP R5 (LI-SaaS) SR-08
USA Federal HIPAA Security Rule NIST SP 800-66 R2 § 164.314(a)(2)(i)(C) § 164.314(b)(2)(iv)
USA Federal HIPAA Administrative Simplification 2013 § 164.314(a)(2)(i)(C) § 164.314(b)(2)(iv) § 164.410(a)(1) § 164.410(a)(2) § 164.410(b) § 164.410(c)(2)
USA Federal NERC CIP 2024 CIP-013-2 1.2.1
USA California CCPA 2025 7123(c)(15)
USA Montana CDPA 2025 30-14-2813(1)(b)
USA New York DFS 23 NYCRR500 2023 Amd 2 500.4(a)(1) 500.4(a)(2) 500.4(a)(3) 500.11(b)(3)
USA Texas DIR SCSC 2.2 2025 SR-08
EMEA (4)
Framework Mapping Values
EMEA Spain CCN-STIC 825 op.ext.3
EMEA EU DORA RTS 2024 Article 23.2(a)(iii)
EMEA LUX CCSF 20/750 2020 3.2.3-8.b
EMEA LUX CCSF 22/806 2022 77.j
APAC (5)
Framework Mapping Values
APAC Australia ISM June 2026 ISM-1576
APAC India RBI PPI 2025 18.3.e
APAC Malaysia RMiT 2025 10.48(g)
APAC New Zealand NZISM 3.9 7.2.22.C.01 7.2.23.C.01
APAC Singapore CCOP CII 2026 3.10.3(b)
Americas (1)
Framework Mapping Values
Americas Canada ITSP-10-171 2025 03.17.02

Capability Maturity Model

Level 0 — Not Performed

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Level 1 — Performed Informally

SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.

Level 2 — Planned & Tracked

Third-Party Management (TPM) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with TPM domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with TPM domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with TPM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Third-party management-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Asset management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.

Level 3 — Well Defined

Third-Party Management (TPM) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with TPM domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with TPM domain capabilities are well-documented and kept current by process owners. ▪ A procurement team, or similar function, is appropriately staffed and supported to implement and maintain TPM domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of third-party management operations (e.g., TPRM risk management solution and vendor management solution). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with TPM domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to compel External Service Providers (ESPs) to provide notification of actual or potential compromises in the supply chain that can potentially affect or have adversely affected Technology Assets, Applications and/or Services (TAAS) that the organization utilizes.

Level 4 — Quantitatively Controlled

Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.

Level 5 — Continuously Improving

Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.

Assessment Objectives

  1. TPM-21.1_A01 security requirements to be satisfied by external system service providers are defined.
  2. TPM-21.1_A02 agreements and procedures are established with entities involved in the supply chain for the system, system components or system service per organization-defined criteria.
  3. TPM-21.1_A03 External Service Providers (ESPs) are contractually obligated to provide notification of actual or potential compromises in the supply chain that can potentially affect or have adversely affected systems, applications and/or services that the organization utilizes.

Evidence Requirements

E-TPM-01 Third-Party Contracts

Documented evidence of third-party contractual obligations for cybersecurity & data privacy protections.

Third-Party Management

Technology Recommendations

Micro/Small

  • Cybersecurity Supply Chain Risk Management (C-SCRM) program
  • Data Protection Impact Assessment (DPIA)
  • Third-party contract requirements for cybersecurity controls

Small

  • Cybersecurity Supply Chain Risk Management (C-SCRM) program
  • Data Protection Impact Assessment (DPIA)
  • Third-party contract requirements for cybersecurity controls

Medium

  • Cybersecurity Supply Chain Risk Management (C-SCRM) program
  • Data Protection Impact Assessment (DPIA)
  • Third-party contract requirements for cybersecurity controls

Large

  • Cybersecurity Supply Chain Risk Management (C-SCRM) program
  • Data Protection Impact Assessment (DPIA)
  • Third-party contract requirements for cybersecurity controls

Enterprise

  • Cybersecurity Supply Chain Risk Management (C-SCRM) program
  • Data Protection Impact Assessment (DPIA)
  • Third-party contract requirements for cybersecurity controls

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