TPM-24.7: Third-Party Exit Contingencies
Mechanisms exist to establish contingency measures to maintain security, compliance, resilience and continuity of operations when a third-party relationship is terminated unexpectedly or the third-party is unable or unwilling to support an orderly transition.
Control Question: Does the organization establish contingency measures to maintain security, compliance, resilience and continuity of operations when a third-party relationship is terminated unexpectedly or the third-party is unable or unwilling to support an orderly transition?
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-24.7_A01 scenarios in which a third-party relationship may be terminated unexpectedly or the third-party may be unable or unwilling to support an orderly transition (e.g., insolvency, breach, sanctions, service withdrawal) are identified for applicable third-party relationships.
- TPM-24.7_A02 documented contingency measures exist to maintain security, compliance and resilience of affected Technology Assets, Applications, Services and Data (TAASD) when a third-party relationship is terminated unexpectedly.
- TPM-24.7_A03 documented contingency measures exist to maintain continuity of operations, including alternate sourcing, internally-managed fallback and/or escrow arrangements, when the third-party is unable or unwilling to support an orderly transition.
- TPM-24.7_A04 contingency measures for third-party exit are tested or exercised at a defined frequency for critical third-party relationships.
- TPM-24.7_A05 the conditions and authority for invoking third-party exit contingency measures are defined and, when invoked, the invocation is recorded.
Evidence Requirements
- 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
- Maintain independent backups of data held by critical vendors
- Identify an alternate provider for critical services
Small
- Vendor failure scenarios in the Business Continuity Plan (BCP)
- Independent data copies for critical services
Medium
- Third-party failure included in the BIA and BCP
- Alternate provider identification for critical services
- Escrow or independent data copies
Large
- Concentration risk assessment and contingency plans for critical providers
- Contingency testing for vendor loss scenarios
- Software/data escrow where appropriate
Enterprise
- Enterprise third-party concentration and contingency program aligned with regulatory expectations (e.g., DORA)
- Tested contingency plans for critical provider failure
- Multi-provider or exit-ready architectures for critical services