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TPM-24.3: Technology Assets, Applications, Services and Data (TAASD) Disposition

TPM 8 — High Protect

Mechanisms exist to govern the return, transfer, retention and/or secure destruction of organizational Technology Assets, Applications, Services and Data (TAASD) held, managed or processed by third-parties upon cessation of third-party services.

Control Question: Does the organization govern the return, transfer, retention and/or secure destruction of organizational Technology Assets, Applications, Services and Data (TAASD) held, managed or processed by third-parties upon cessation of third-party services?

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

  1. TPM-24.3_A01 the required disposition (return, transfer, retention and/or secure destruction) is determined and documented for each category of organizational Technology Assets, Applications, Services and Data (TAASD) held, managed or processed by a third-party before its services cease.
  2. TPM-24.3_A02 organizational Technology Assets, Applications, Services and Data (TAASD) designated for return are returned by the third-party.
  3. TPM-24.3_A03 organizational Technology Assets, Applications, Services and Data (TAASD) designated for transfer are transferred to the replacement third-party or internally-managed service.
  4. TPM-24.3_A04 where organizational Technology Assets, Applications, Services and Data (TAASD) are retained by the third-party after cessation of services (e.g., to satisfy legal or regulatory obligations), the retention period, protection requirements and destruction at the end of the period are documented and agreed.
  5. TPM-24.3_A05 organizational Technology Assets, Applications, Services and Data (TAASD) designated for destruction, including copies and backups held by the third-party, are securely destroyed and a written attestation or certificate of destruction is obtained from the third-party.

Evidence Requirements

E-TPM-08 Third-Party Exit / Transition Plan

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

  • Request account closure and data deletion confirmation from vendors
  • Recover any company-owned equipment

Small

  • Data return and deletion clauses in contracts
  • Written confirmation of deletion retained

Medium

  • Disposition checklist within the exit process
  • Certificates of destruction for sensitive/regulated data
  • Asset recovery tracked in ITAM

Large

  • C-SCRM offboarding procedure covering data and asset disposition
  • TPRM platform tracking of disposition evidence
  • Sub-processor disposition confirmation

Enterprise

  • Enterprise vendor offboarding with formal disposition attestations
  • Legal hold and retention reconciliation before destruction
  • Audit of disposition evidence for critical vendors

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