TPM-24: Terminating Third-Party Relationships
Mechanisms exist to establish, maintain and execute a documented exit strategy for applicable third-party relationships prior to the cessation of third-party services to support an orderly, secure, compliant and resilient transition to another third-party or to internally-managed services.
Control Question: Does the organization establish, maintain and execute a documented exit strategy for applicable third-party relationships prior to the cessation of third-party services to support an orderly, secure, compliant and resilient transition to another third-party or to internally-managed services?
EMEA (1)
| Framework | Mapping Values |
|---|---|
| EMEA LUX CCSF 22/806 2022 | 14.e |
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
Third-Party Management (TPM) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include: ▪ Policies, standards & procedures associated with TPM domain capabilities provide limited coverage due to the depth and breadth of the existing documentation. ▪ Third-party management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
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).
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
- TPM-24_A01 the third-party relationships for which a documented exit strategy is required are identified based on criticality, dependency and risk.
- TPM-24_A02 a documented exit strategy exists for applicable third-party relationships before the cessation of third-party services.
- TPM-24_A03 each exit strategy addresses an orderly, secure, compliant and resilient transition to another third-party or to internally-managed services.
- TPM-24_A04 exit strategies are reviewed and updated at a defined frequency and upon significant change to the third-party relationship or the services provided.
- TPM-24_A05 upon cessation of third-party services, the documented exit strategy is executed.
Evidence Requirements
- E-TPM-05 Break Clauses
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Documented evidence of "break clauses" in third-party contracts.
Third-Party Management - E-TPM-08 Third-Party Exit / Transition Plan
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Documented evidence of exit strategies and transition plans for third-party relationships, including TAASD portability, disposition, knowledge transfer and exit contingencies.
Third-Party Management
Technology Recommendations
Micro/Small
- Exit considerations documented for critical vendors (data export, account closure)
- Contract review for termination terms
Small
- Documented exit plan for critical third parties
- Contract clauses covering data return and transition assistance
Medium
- Cybersecurity Supply Chain Risk Management (C-SCRM) program
- Exit strategy template applied to critical vendors
- Annual review of exit plans
Large
- C-SCRM program with formal exit strategies for critical and high-risk third parties
- Third-Party Risk Management (TPRM) platform (e.g., ProcessUnity, OneTrust, Prevalent)
- Contractual exit provisions standardized by legal
Enterprise
- Enterprise TPRM program with exit strategies aligned to DORA and regulatory outsourcing expectations
- TPRM platform with exit plan tracking
- Periodic exit plan testing for critical providers