CTPRP Certified Third-Party Risk Professional (CTPRP) Questions and Answers

According to the Shared Assessments Certified Third Party Risk Professional (CTPRP) Study Guide, data loss prevention (DLP) is a strategy for preventing the unauthorized disclosure, transfer, or misuse of sensitive data, such as personally identifiable information (PII), personal health information (PHI), or intellectual property (IP)1. Endpoint security is a component of DLP that focuses on protecting the devices (such as laptops, tablets, or smartphones) that access and store sensitive data from internal or external threats2. Therefore, data loss prevention in endpoint security is the strategy for preventing exfiltration of confidential information by users who access company systems, as this could result in data breaches, regulatory fines, reputational damage, or competitive disadvantage3.

The other options are not the best descriptions of data loss prevention in endpoint security, as they either relate to different aspects of data protection or security, or do not address the specific goal of preventing data exfiltration. Data backups are a strategy for ensuring data recovery in the event of a disaster, but they do not prevent data loss or leakage from unauthorized access or transfer. High-availability is a strategy for ensuring data availability and continuity, but it does not prevent data loss or leakage from malicious or accidental actions. Malware prevention is a strategy for ensuring data integrity and confidentiality, but it does not prevent data loss or leakage from legitimate users who may misuse or overshare data.

References:

• 1: Shared Assessments Certified Third Party Risk Professional (CTPRP) Study Guide, page 25
• 2: What is Endpoint Security? | McAfee
• 3: What is data loss prevention (DLP)? | Microsoft Security
• [4]: Data Backup vs. Data Recovery: What’s the Difference? | Carbonite
• [5]: What is High Availability? | IBM
• [6]: What is Malware? | Norton

Shadow IT is the use and management of any IT technologies, solutions, services, projects, and infrastructure without formal approval and support of internal IT departments. Shadow IT can pose significant security risks to the organization, such as data breaches, compliance violations, malware infections, or network disruptions. Therefore, assessing and mitigating the risk of shadow IT is an essential part of organizational security.

One of the most important factors when assessing the risk of shadow IT is whether the organization maintains adequate policies and procedures that communicate required controls for security functions. Policies and procedures are the documents that define the organization’s security objectives, standards, roles, responsibilities, and processes. They provide guidance and direction for the organization’s security activities, such as risk assessment, vendor management, incident response, data protection, access control, etc. They also establish the expectations and requirements for the organization’s employees, vendors, and other stakeholders regarding the use and management of IT resources.

By maintaining adequate policies and procedures that communicate required controls for security functions, the organization can:

• Educate and inform its employees about the security risks and implications of shadow IT, and the benefits and advantages of using authorized and supported IT resources.
• Establish and enforce clear and consistent rules and boundaries for the use and management of IT resources, and the consequences and penalties for violating them.
• Monitor and audit the compliance and performance of its employees, vendors, and other stakeholders regarding the use and management of IT resources, and identify and address any deviations or issues.
• Review and update its policies and procedures regularly, and communicate any changes or updates to its employees, vendors, and other stakeholders.

By doing so, the organization can reduce the likelihood and impact of shadow IT, and increase the visibility and accountability of its IT environment. The organization can also foster a culture of security awareness and responsibility among its employees, vendors, and other stakeholders, and encourage them to report and resolve any shadow IT incidents or problems.

The other factors, such as the organization’s security training and certification, staffing levels, and resources and investment, are also relevant for assessing the risk of shadow IT, but they are not as important as the organization’s policies and procedures. Security training and certification can help the organization’s security personnel to acquire and maintain the necessary skills and knowledge to deal with shadow IT, but they do not address the root causes or motivations of shadow IT. Staffing levels can affect the organization’s ability to detect and respond to shadow IT, but they do not prevent or deter shadow IT from occurring. Resources and investment can enable the organization to provide adequate and appropriate IT resources to its employees, vendors, and other stakeholders, but they do not guarantee the satisfaction or compliance of those parties. References:

• : Shadow IT Explained: Risks & Opportunities - BMC Software
• : What is Shadow IT? | IBM
• : Shadow IT: What Are the Risks and How Can You Mitigate Them? - Ekran System
• : Policies and Procedures - Shared Assessments

According to the Shared Assessments Certified Third Party Risk Professional (CTPRP) Study Guide, risk based decisioning is the process of applying risk criteria to prioritize and address the gaps identified during a third-party risk assessment1. The assessor should analyze the gaps based on the impact, likelihood, and urgency of the risk, and document the findings and recommendations in a report. The assessor should also review the existing or proposed compensating controls that could mitigate the risk, and submit the report to the business owner for approval of the risk treatment plan. The risk treatment plan could include accepting, transferring, avoiding, or reducing the risk, depending on the risk appetite and tolerance of the organization1.

The other statements do not reflect the best use of risk based decisioning, as they either ignore the risk analysis and documentation process, or apply a uniform or arbitrary approach to prioritizing and addressing the gaps. The assessor should not decide or conclude on the risk treatment plan without consulting the business owner, as the business owner is ultimately responsible for the third-party relationship and the risk management decisions1. The assessor should also not communicate that the gaps would not be included in the report if they were corrected immediately, as this could compromise the integrity and transparency of the assessment process and the report2.

References:

• 1: Shared Assessments Certified Third Party Risk Professional (CTPRP) Study Guide, pages 29-30, 33-34
• 2: Third-Party Risk Management: Final Interagency Guidance, page 10

A documented process to gain approvals for use of open source applications is typically not part of evaluating the vendor’s patch management controls, because it is not directly related to the patching process. Patch management controls are the policies, procedures, and tools that enable an organization to identify, acquire, install, and verify patches for software vulnerabilities. Patch management controls aim to reduce the risk of exploitation of known software flaws and ensure the functionality and compatibility of the patched systems. A documented process to gain approvals for use of open source applications is more relevant to the software development and procurement processes, as it involves assessing the legal, security, and operational implications of using open source software components in the vendor’s products or services. Open source software may have different licensing terms, quality standards, and support levels than proprietary software, and may introduce additional vulnerabilities or dependencies that need to be managed. Therefore, a documented process to gain approvals for use of open source applications is a good practice for vendors, but it is not a patch management control per se. References:

• Guide to Enterprise Patch Management Planning
• Governance of Key Aspects of System Patch Management
• Certified Third Party Risk Professional (CTPRP) Study Guide

A cloud hosting vendor assessment program is a process of evaluating the security, compliance, and performance of a cloud service provider (CSP) that hosts an organization’s data or applications. A cloud hosting vendor assessment program typically includes the following components123:

• Reviewing the entity’s image snapshot approval and management process: This component involves verifying how the CSP creates, approves, stores, and deletes image snapshots of the virtual machines or containers that run the organization’s workloads. Image snapshots can contain sensitive data or configuration settings that need to be protected from unauthorized access or modification.
• Requiring security services documentation and audit attestation reports: This component involves requesting and reviewing the CSP’s documentation and reports that demonstrate the security controls and practices that the CSP implements to protect the organization’s data and applications. These may include service level agreements (SLAs), security policies and procedures, security certifications and standards, vulnerability scanning and patching reports, incident response and disaster recovery plans, and independent audit reports such as SOC 2 or ISO 27001.
• Requiring compliance evidence that provides the definition of patching responsibilities: This component involves asking and verifying how the CSP handles the patching of the operating systems, applications, and libraries that run on the cloud infrastructure. Patching is a critical activity to prevent security breaches and ensure compliance with regulatory requirements. The organization needs to understand the roles and responsibilities of the CSP and the organization in patching the cloud environment, and the frequency and scope of patching activities.

The component that is typically NOT part of a cloud hosting vendor assessment program is conducting customer performed penetration tests. Penetration testing is a method of simulating a cyberattack on a system or network to identify and exploit vulnerabilities and weaknesses. While penetration testing can be a valuable tool to assess the security posture of a CSP, it is not usually included in a cloud hosting vendor assessment program for the following reasons :

• Penetration testing may violate the CSP’s terms of service or acceptable use policy, which may prohibit or restrict the customer from performing any unauthorized or disruptive activities on the cloud infrastructure. The customer may face legal or contractual consequences if they conduct penetration testing without the CSP’s consent or knowledge.
• Penetration testing may interfere with the CSP’s normal operations or affect the availability and performance of the cloud services for other customers. The customer may cause unintended damage or disruption to the CSP’s systems or networks, or trigger false alarms or alerts that may divert the CSP’s resources or attention.
• Penetration testing may not provide a comprehensive or accurate assessment of the CSP’s security, as the customer may have limited visibility or access to the CSP’s internal systems or networks, or may encounter security mechanisms or countermeasures that prevent or limit the penetration testing activities. The customer may also face ethical or legal issues if they access or compromise the data or systems of other customers or the CSP.

Therefore, the verified answer to the question is D. Conducting customer performed penetration tests.

References:

• Four Important Best Practices for Assessing Cloud Vendors
• Top 11 Questionnaires for IT Vendor Assessment in 2024
• Cloud Vendor Assessments | Done The Right Way
• [Penetration Testing in the Cloud: What You Need to Know]
• [Cloud Penetration Testing: Challenges and Best Practices]

According to the Shared Assessments CTPRP Study Guide, the business unit relationship owner is the primary point of contact for the third party and is responsible for ensuring that the third party meets the contractual obligations and service level agreements. The business unit relationship owner is also involved in the third party risk assessment process and the remediation plan approval. Therefore, a meeting should be scheduled with the business unit relationship owner before sharing the findings and remediation plans with the third party, as they have the authority and accountability to approve or reject the plans. The other options are not necessarily involved in the remediation plan approval, although they may have other roles in the third party risk management lifecycle. References:

• Shared Assessments CTPRP Study Guide, page 9, section 1.3.2
• The Third-Party Vendor Risk Management Lifecycle, section on Supplier Onboarding & Risk Monitoring
• Remediation vs. Mitigation, section on Remediation

TPRM vendor classification is the process of categorizing vendors based on their criticality, risk level, and service type. Vendor classification helps to prioritize and allocate resources for vendor assessment, monitoring, and remediation. Vendor classification should be updated periodically to reflect changes in the business environment, vendor performance, and regulatory requirements.

When updating TPRM vendor classification requirements with a focus on availability, the risk rating factors that provide the greatest impact to the analysis are the impact on operations and end users, the impact on revenue, and the impact on regulatory compliance. This is because:

• Availability is the degree to which a system or service is accessible and functional when required by authorized users. Availability is a key component of information security and business continuity, as it ensures that the business can operate normally and deliver value to its customers and stakeholders.
• Impact on operations and end users measures the extent to which a vendor’s service disruption or failure affects the business processes, functions, and activities that depend on the vendor’s service. A high impact on operations and end users means that the vendor’s service is essential for the business to perform its core functions and meet its objectives, and that any downtime or degradation of the service would cause significant operational delays, inefficiencies, or losses.
• Impact on revenue measures the extent to which a vendor’s service disruption or failure affects the business’s income, profitability, and market share. A high impact on revenue means that the vendor’s service is directly or indirectly linked to the business’s revenue generation, and that any downtime or degradation of the service would cause substantial financial losses, reduced customer satisfaction, or competitive disadvantage.
• Impact on regulatory compliance measures the extent to which a vendor’s service disruption or failure affects the business’s adherence to the laws, regulations, standards, and contractual obligations that govern its industry, sector, or jurisdiction. A high impact on regulatory compliance means that the vendor’s service is subject to strict regulatory requirements, and that any downtime or degradation of the service would cause serious legal penalties, fines, sanctions, or reputational damage.

Therefore, these three factors are the most important to consider when updating TPRM vendor classification requirements with a focus on availability, as they reflect the potential consequences and risks of vendor unavailability for the business.

References:

• CTPRP Job Guide
• Criticality and Risk Rating Vendors 101
• The Third-Party Vendor Risk Management Lifecycle
• What Is Third-Party Risk Management (TPRM)? 2024 Guide
• Third-Party Risk Management and ISO Requirements for 2022

  Performance risk, defined as the risk that a third party may not be able to meet its obligations due to inadequate systems or processes, accurately describes the situation. This type of risk involves concerns about the third party's ability to deliver services or products at the required performance level, potentially due to limitations in their technology infrastructure, operational procedures, or management practices. Identifying and managing performance risk is essential in Third-Party Risk Management (TPRM) to ensure that third-party vendors can reliably meet contractual and service-level agreements, thereby minimizing the impact on the organization's operations and service delivery.

References:

• TPRM guidelines, such as those from the Office of the Comptroller of the Currency (OCC) and the Federal Financial Institutions Examination Council (FFIEC), highlight the importance of assessing and managing performance risks associated with third-party relationships.
• The "Third-Party Risk Management Guide" by ISACA discusses various types of risks, including performance risk, associated with engaging third-party service providers, emphasizing the need for thorough due diligence and ongoing monitoring.

 A regulation is a rule of order having the force of law, prescribed by a superior or competent authority, relating to the actions of those under the authority’s control. Regulations are issued by various government departments and agencies to carry out the intent of legislation enacted by the legislature of the applicable jurisdiction. Regulations also function to ensure uniform application of the law. A standard is a guideline established generally by private-sector bodies and that are available for use by any person or organization, private or government. The term includes what are commonly referred to as ‘industry standards’ as well as ‘consensus standards’. Standards are developed through a voluntary process of collaboration and consensus among stakeholders, such as manufacturers, consumers, regulators, and experts. Standards may reflect best practices, technical specifications, performance criteria, or quality requirements. Standards do not have the force of law unless they are adopted or referenced by a regulation. Therefore, a regulation must be adhered to by all companies subject to its requirements, but companies can voluntarily choose to follow standards that are relevant and beneficial to their operations, products, or services. References:

• The Difference Between Regulations and Standards
• Regulations vs Standards: Clearing Up the Confusion - AEM
• Standards vs. Regulations
• Certified Third Party Risk Professional (CTPRP) Study Guide

Data Loss Prevention (DLP) programs are not based on default tool configuration, but on the specific needs and risks of the organization. DLP programs should be tailored to the data types, locations, flows, and users that are relevant to the business. DLP programs should also align with the regulatory and contractual obligations, as well as the data risk appetite, of the organization. Default tool configuration may not adequately address these factors and may result in either over-blocking or under-protecting data. Therefore, statement C is false about DLP programs. References:

• 1: The Best Data Loss Prevention Software Tools - Comparitech
• 2: Build a Successful Data Loss Prevention Program in 5 Steps - Gartner
• 3: What is data loss prevention (DLP)? | Microsoft Security

Remote monitoring of HVAC, Smoke, Fire, Water, or Power systems best reflects components of an environmental controls testing program. These systems are critical to ensuring the physical security and operational integrity of data centers and IT facilities. Environmental controls testing programs are designed to verify that these systems are functioning correctly and can effectively respond to environmental threats. This includes monitoring temperature and humidity (HVAC), detecting smoke or fire, preventing water damage, and ensuring uninterrupted power supply. Regular testing and monitoring of these systems help prevent equipment damage, data loss, and downtime due to environmental factors.

References:

• Environmental control standards such as ISO/IEC 27001 (Information Security Management) include requirements for the testing and monitoring of physical and environmental security controls.
• The "Data Center Operations Manual" by the Uptime Institute provides detailed guidelines on the testing and maintenance of environmental control systems to ensure the resilience and reliability of data center operations.

Remote access is any connection made to an organization’s internal network and systems from an external source by a device or host. Remote access can enable greater worker flexibility and productivity, but it also poses significant security risks, such as unauthorized access, data leakage, malware infection, or network compromise. Therefore, it is important to evaluate a third party’s use of remote access within their information security policy, which should define the roles, responsibilities, standards, and procedures for remote access.

One of the key components of evaluating a third party’s use of remote access within their information security policy is identifying the use of multifactor authentication. Multifactor authentication is a method of verifying the identity of a remote user by requiring two or more factors, such as something the user knows (e.g., password, PIN), something the user has (e.g., token, smart card), or something the user is (e.g., fingerprint, face). Multifactor authentication enhances the security of remote access by making it harder for attackers to impersonate or compromise legitimate users. According to the NIST Guide to Enterprise Telework, Remote Access, and Bring Your Own Device (BYOD) Security1, multifactor authentication should be used for all remote access, especially for high-risk situations, such as accessing sensitive data or privileged accounts.

The other options are not components of evaluating a third party’s use of remote access within their information security policy. Maintaining blocked IP address ranges, reviewing the testing and deployment procedures to networking components, and providing guidelines to configuring ports on a router are all examples of network security controls, but they are not specific to remote access. They may be part of the overall information security policy, but they are not sufficient to assess the security of remote access. References:

• NIST Guide to Enterprise Telework, Remote Access, and Bring Your Own Device (BYOD) Security
• How to Implement an Effective Remote Access Policy
• Why Managing Third-Party Access Requires A Better Approach

 According to the CTPRP Job Guide, the TPRM program should establish minimum risk assessment standards for third party due diligence based on the company’s risk tolerance and risk appetite. This means that the TPRM program should define the scope, depth, frequency, and methodology of the risk assessment process for different categories of third parties, taking into account the potential impact and likelihood of various risks. The risk assessment standards should be consistent, transparent, and aligned with the company’s strategic objectives and regulatory obligations. The TPRM program should also monitor and update the risk assessment standards as needed to reflect changes in the business environment, risk profile, and best practices. The other options are not correct because they do not reflect a holistic and risk-based approach to third party due diligence. Setting the standards by each business unit may result in inconsistency, duplication, or gaps in the risk assessment process. Defining the standards in the contract or statement of work may limit the flexibility and adaptability of the risk assessment process to changing circumstances. Identifying the standards by procurement may overlook the input and involvement of other stakeholders and functions in the risk assessment process. References:

• CTPRP Job Guide, page 17
• Third-Party Risk Management and ISO Requirements for 2022, section “Benefits of Implementing Risk Management”
• Managing third-party risk through effective due diligence, section “Complying with regulators’ demands”
• Third-Party Due Diligence Checklist: 3 Essential Steps, section “Step 2: Conduct a Risk Assessment”

Infrastructure as a service (IaaS) is a cloud deployment model that provides users with access to virtualized hardware resources, such as servers, storage, and network devices. Users can install and run their own operating systems and applications on the cloud infrastructure, and have full control over the configuration and management of the hardware equipment. IaaS is suitable for organizations that need high scalability, flexibility, and customization of their cloud environment. IaaS is different from other cloud deployment models, such as function as a service (FaaS), platform as a service (PaaS), and software as a service (SaaS), which provide users with higher-level services and abstract away the underlying hardware details. References:

• Cloud Infrastructure: 4 Key Components and Deployment Models
• Cloud Deployment Models - GeeksforGeeks
• On-Premises Cloud Deployment Model: Organization-Owned Hardware Explained

Restrictive areas are those that contain sensitive or critical assets, systems, or information that require additional protection from unauthorized access or tampering. Access control is the process of granting or denying access to these areas based on predefined policies, rules, and criteria. An additional authentication factor is a method of verifying the identity or authorization of a user or device that is used in conjunction with another factor, such as a password, a token, or a biometric feature. Additional authentication factors enhance the security and reliability of access control by reducing the risk of impersonation, compromise, or theft of credentials.

The example that best represents the set of restrictive areas that require an additional authentication factor for access control is A. Datacenters; telecom rooms; server rooms; exterior building entrance. These areas contain vital infrastructure, equipment, and data that are essential for the organization’s operations, performance, and security. Unauthorized access to these areas could result in significant damage, disruption, or loss of data, services, or resources. Therefore, these areas should be protected by multiple layers of access control, including physical and logical barriers, as well as additional authentication factors, such as smart cards, biometrics, or one-time passwords.

The other examples are less likely to represent the set of restrictive areas that require an additional authentication factor for access control, because they either contain less sensitive or critical assets, systems, or information, or they are more accessible or visible to the public or other authorized users. For example:

• B. Datacenters; telecom rooms; security operations centers; loading docks: While datacenters, telecom rooms, and security operations centers are restrictive areas that require an additional authentication factor for access control, loading docks are not. Loading docks are typically open to external vendors, suppliers, or delivery personnel, and may not contain any sensitive or critical assets, systems, or information. Therefore, loading docks may not require an additional authentication factor for access control, but rather a basic verification of identity or authorization, such as a badge, a signature, or a receipt.
• C. Telecom rooms; parking garage; security operations centers; exterior building entrance: While telecom rooms, security operations centers, and exterior building entrance are restrictive areas that require an additional authentication factor for access control, parking garage is not. Parking garage is usually accessible to employees, visitors, or customers, and may not contain any sensitive or critical assets, systems, or information. Therefore, parking garage may not require an additional authentication factor for access control, but rather a simple validation of access rights, such as a ticket, a code, or a gate.
• D. Exterior building entrance; datacenters; telecom rooms; printer rooms: While exterior building entrance, datacenters, and telecom rooms are restrictive areas that require an additional authentication factor for access control, printer rooms are not. Printer rooms are generally available to all employees or authorized users, and may not contain any sensitive or critical assets, systems, or information. Therefore, printer rooms may not require an additional authentication factor for access control, but rather a standard authentication factor, such as a password, a PIN, or a fingerprint.

References:

• Shared Assessments CTPRP Study Guide, page 46, section 4.3.1: Access Control
• Access Controls Over Third-Party Applications, section: Vendor Access
• Controlling Third-Party Access Risk, section: Best Practices for Controlling Third-Party Vendor Risks, bullet point: Implementing supporting processes and controls that define and enforce access policies for third-party privileged users.

In the context of Third-Party Risk Management (TPRM) requirements within the Software Development Life Cycle (SDLC), a process for data destruction and disposal is not typically considered a key component. The primary focus within SDLC in TPRM is on ensuring secure software development practices, which includes maintaining artifacts to prove that SDLC gates are executed, conducting software security testing, and having processes in place for fixing security defects. While data destruction and disposal are important security considerations, they are generally associated with data lifecycle management and information security management practices rather than being integral to the SDLC process itself.

References:

• Best practices in secure software development, as outlined in frameworks like the Secure Software Development Framework (SSDF) by NIST, emphasize the importance of secure coding, vulnerability testing, and remediation processes rather than data disposal practices.
• The "Software Security Framework (SSF)" by the Open Web Application Security Project (OWASP) provides guidance on integrating security practices into the SDLC, focusing on areas like threat modeling, secure coding, and security testing.

An organization’s Ethics and Code of Conduct Program is a set of policies, procedures, and practices that define the expected standards of behavior and ethical values for all employees and stakeholders. A key component of such a program is a disciplinary process that outlines the consequences and actions for violating the code of conduct or any other relevant policies. A disciplinary process helps to enforce the code of conduct, deter unethical behavior, and protect the organization’s reputation and integrity. A disciplinary process should include clear criteria for determining the severity and frequency of violations, the roles and responsibilities of the parties involved, the steps and timelines for investigation and resolution, and the range of sanctions and remedies available. A disciplinary process should also be fair, consistent, transparent, and respectful of the rights and dignity of the accused and the accuser. A disciplinary process may involve formal termination or change of status of the employee, depending on the nature and impact of the violation. Therefore, option B is a correct component of an organization’s Ethics and Code of Conduct Program.

The other options are not necessarily components of an Ethics and Code of Conduct Program, although they may be related or supportive of it. Option A, participation in the company’s annual privacy awareness program, is more likely to be a component of a Privacy Program, which is a specific area of ethics and compliance that deals with the protection and use of personal information. Option C, signing acknowledgement of Acceptable Use policy for use of company assets, is more likely to be a component of an Information Security Program, which is another specific area of ethics and compliance that deals with the safeguarding and management of data and systems. Option D, a process to conduct periodic access reviews of critical Human Resource files, is more likely to be a component of an Internal Control Program, which is a general area of ethics and compliance that deals with the design and implementation of controls to ensure the reliability and accuracy of financial and operational information. References:

• 1: Creating an Effective Code of Conduct (and Code Program) - Corporate Compliance Insights
• 2: Code of Conduct & Ethics (Examples and Best Practices) - Status.net
• 3: Why Have a Code of Conduct - Free Ethics & Compliance Toolkit
• 4: “Code of Ethics” and “Code of Conduct” - GeeksforGeeks
• 5: Six Tips on How to Implement a Strong Ethics Program - KnowledgeLeader

Software as a Service (SaaS) is a cloud deployment model that provides users with access to software applications over the internet, without requiring them to install, maintain, or update the software on their own devices. SaaS is primarily focused on the application layer, as it delivers the complete functionality of the software to the end users, while abstracting away the underlying infrastructure, platform, and middleware layers. SaaS providers are responsible for managing the servers, databases, networks, security, and scalability of the software, as well as ensuring its availability, performance, and compliance. SaaS users only pay for the software usage, usually on a subscription or pay-per-use basis, and can access the software from any device and location, as long as they have an internet connection. Some examples of SaaS applications are Gmail, Salesforce, Dropbox, and Netflix. References:

• Shared Assessments CTPRP Study Guide, page 15, section 2.2.2
• Cloud Computing Deployment Models and Architectures, section on Cloud Computing Models
• Layered Architecture of Cloud, section on Application Layer

One of the key objectives of a TPRM program is to identify and mitigate the risks posed by third parties throughout the relationship life cycle. Therefore, measuring the operational performance of implementing a TPRM program requires tracking the effectiveness and efficiency of the risk management processes and activities. Among the four examples given, calculating the average time to remediate identified corrective actions is the most likely to provide meaningful metrics for this purpose. This metric indicates how quickly and consistently the organization and its third parties can resolve the issues and gaps that are discovered during the risk assessment and monitoring phases. It also reflects the level of collaboration and communication between the parties, as well as the alignment of expectations and standards. A lower average time to remediate implies a higher operational performance of the TPRM program, as it demonstrates a proactive and responsive approach to risk management12.

The other three examples are less likely to provide meaningful metrics for measuring the operational performance of implementing a TPRM program, as they do not directly measure the outcomes or impacts of the risk management activities. Logging the number of exceptions to existing due diligence standards may indicate the level of compliance and consistency of the TPRM program, but it does not show how the exceptions are handled or justified. Measuring the time spent by resources for task and corrective action plan completion may indicate the level of effort and resource allocation of the TPRM program, but it does not show how the tasks and plans contribute to the risk reduction or mitigation. Tracking the number of outstanding findings may indicate the level of exposure and vulnerability of the TPRM program, but it does not show how the findings are prioritized or addressed. References:

• 1: 15 KPIs & Metrics to Measure the Success of Your TPRM Program | UpGuard Blog
• 2: Third-Party Risk Management Reporting: What You Need to Know - Venminder

Data classification is the process of categorizing data according to its type, sensitivity, and value to the organization if altered, stolen, or destroyed1. Data classification helps an organization understand the risk level of its data and implement appropriate controls to protect it. Data can be classified into three risk levels: low, moderate, and high23. Low risk data are data that are intended for public disclosure or have no adverse impact on the organization’s mission, safety, finances, or reputation if compromised23. Sanitized customer data used for aggregated profiling are an example of low risk data, as they do not contain any personally identifiable or sensitive information that could be exploited for criminal or other wrongful purposes. Sanitized data are data that have been modified to remove or obscure any confidential or identifying information, such as names, addresses, phone numbers, etc. Aggregated data are data that have been combined or summarized from multiple sources to provide statistical or analytical insights, such as trends, patterns, averages, etc. Sanitized and aggregated data are often used for research, marketing, or business intelligence purposes, and do not pose a significant threat to the organization or the customers if exposed. References:

• 1: What is Data Classification? | Best Practices & Data Types | Imperva
• 2: Data Classification Guideline (1604 GD.01) - Yale University
• 3: Risk Classifications | University IT
• : Data Classification Policy - Shared Assessments
• : What is Data Sanitization? | Definition and Examples | Imperva
• : What is Data Aggregation? | Definition and Examples | Imperva

Data privacy policies are documents that outline how an organization collects, uses, stores, shares, and protects personal information from its customers, employees, partners, and other stakeholders1. Data privacy policies should address the following key elements2:

• The purpose and scope of data collection and processing
• The legal basis and consent mechanism for data processing
• The types and categories of personal data collected and processed
• The data retention and deletion policies and practices
• The data security and encryption measures and standards
• The data sharing and disclosure practices and procedures, including the use of third parties and cross-border transfers
• The data access, correction, and deletion rights and requests of individuals
• The data breach and incident response and notification procedures and responsibilities
• The data protection officer and contact details
• The data privacy policy review and update process and frequency

Procedures for configuration settings in identity access management are typically not addressed within data privacy policies, as they are more related to the technical and operational aspects of data security and access control. Identity access management (IAM) is a framework of policies, processes, and technologies that enable an organization to manage and verify the identities and access rights of its users and devices3. IAM configuration settings determine how users and devices are authenticated, authorized, and audited when accessing data and resources. IAM configuration settings should be aligned with the data privacy policies and principles, but they are not part of the data privacy policies themselves. IAM configuration settings should be documented and maintained separately from data privacy policies, and should be reviewed and updated regularly to ensure compliance and security. References: 1: What is a Data Privacy Policy? | OneTrust 2: Privacy Policy Checklist: What to Include in Your Privacy Policy 3: What is identity and access management? | IBM : [Identity and Access Management Configuration Settings] : [Why data privacy and third-party risk teams need to work … - OneTrust] : [Privacy Risk Management - ISACA] : [What Every Chief Privacy Officer Should Know About Third-Party Risk …]

The frequency for conducting a vendor reassessment is not necessarily defined by regulatory obligations, but rather by the risk rating and criticality of the vendor, as well as the changes in the vendor’s environment, performance, and controls. Regulatory obligations may provide some guidance or minimum requirements for vendor reassessment, but they are not the sole determinant of the reassessment frequency. According to the Shared Assessments Program Tools User Guide, "The frequency of reassessment should be based on the risk rating and criticality of the vendor, as well as any changes in the vendor’s environment, performance, or controls. Regulatory guidance may also influence the frequency of reassessment."1 Similarly, the CTPRP Study Guide states, "The frequency of reassessment should be based on the risk rating and criticality of the vendor, as well as any changes in the vendor’s environment, performance, or controls. Regulatory guidance may also influence the frequency of reassessment."2

References:

• Shared Assessments Program Tools User Guide
• CTPRP Study Guide

The risk of increased expense to conduct vendor assessments based on client contractual requirements is the least important factor in defining your risk assessment process for new global third party relationships. This is because the expense of vendor assessments is not a direct risk to your organization’s security, compliance, reputation, or performance, but rather a cost of doing business that can be budgeted and optimized. While vendor assessments are necessary and beneficial, they are not the primary driver of your risk assessment process, which should focus on the potential impact and likelihood of adverse events or incidents involving your third parties. The other factors (B, C, and D) are more important because they directly affect the level of risk exposure and the mitigation strategies for your third parties. For example, natural disasters and physical security risks can disrupt your third party’s operations and service delivery, government regulation and political stability can affect your third party’s compliance and legal obligations, and financial risk can affect your third party’s solvency and reliability. Therefore, these factors should be considered more carefully when defining your risk assessment process. References:

• 1: Third Party Risk Management: Managing Risk | Deloitte US
• 2: What Is Third-Party Risk Management (TPRM)? 2024 Guide | UpGuard
• 3: What is Third-Party Risk Management? | Blog | OneTrust

This statement is false because network connectivity or remote access may trigger a higher vendor risk classification for any third party that has access to the organization’s network, systems, or data, regardless of whether they process personal information or not. Network connectivity or remote access increases the exposure of the organization to cyberattacks, data breaches, or unauthorized access by malicious actors. Therefore, the organization should assess the security controls and practices of the third party, such as encryption, authentication, firewall, antivirus, and patch management, to ensure that they meet the organization’s standards and expectations. The organization should also monitor the network activity and performance of the third party, and establish clear policies and procedures for granting, revoking, or modifying access rights. The other statements (A, B, and C) are true regarding the primary factors in determining vendor risk classification, as they reflect the potential impact, likelihood, and severity of the risks associated with the vendor’s location, importance, and data processing. References:

• Vendor Classification, Shared Assessments
• Impact of Risk Attributes on Vendor Risk Assessment and Classification, SSRN
• Guide to Vendor Risk Assessment, Smartsheet
• How Do You Determine Vendor Criticality?, UpGuard

An enterprise information security policy (EISP) is a management-level document that details the organization’s philosophy, objectives, and expectations regarding information security. It sets the direction, scope, and tone for all security efforts and provides a framework for developing and implementing security programs and controls. According to the web search results from the search_web tool, some of the key elements of an EISP are:

• A statement of the organization’s security vision, mission, and principles that align with its business goals and values123.
• A definition of the organizational structure and accountabilities for oversight, governance, and management of information security, including roles and responsibilities of senior executives, security officers, business units, and users123 .
• A specification of the legal and regulatory compliance requirements and obligations that the organization must adhere to, such as data protection, privacy, and breach notification laws123 .
• A description of the scope and applicability of the EISP, including the types of information, systems, and assets that are covered, and the exclusions or exceptions that may apply123 .
• A declaration of the effective date and date of last review by management, as well as the frequency and criteria for reviewing and updating the EISP to ensure its relevance and adequacy123 .
• A statement of the organization’s risk appetite and tolerance, and the process for identifying, assessing, and treating information security risks123 .
• A provision of the authority and responsibility for implementing, enforcing, monitoring, and auditing the EISP and its related policies, standards, procedures, and guidelines123 .
• A determination of the access control policy and the rules for granting, revoking, and reviewing access rights and privileges to information, systems, and assets123 .
• An organization of the EISP based on an accepted control framework, such as ISO 27001, NIST SP 800-53, or COBIT, that defines the security domains, objectives, and controls that the organization must implement and maintain123 .

However, option C, a statement that security policies should be changed on an annual basis due to technology changes, is not an accurate reflection of an organization’s requirements within an EISP. While technology changes may affect the security environment and the threats and vulnerabilities that the organization faces, they are not the only factor that determines the need for changing security policies. Other factors, such as business changes, legal changes, risk changes, audit findings, incident reports, and best practices, may also trigger the need for reviewing and updating security policies. Therefore, option C is the correct answer, as it is the only one that does not reflect an organization’s requirements within an EISP. References: The following resources support the verified answer and explanation:

• 1: What Is The Purpose Of An Enterprise Information Security Policy?
• 2: Enterprise Information Security Policies and Standards
• 3: Key Elements Of An Enterprise Information Security Policy
• : Enterprise Information Security Policy (EISP) - SANS

In patch management, testing is the most crucial factor when conducting post-cybersecurity incident analysis related to systems and applications. Proper testing of patches before deployment ensures that they effectively address vulnerabilities without introducing new issues or incompatibilities that could impact system functionality or security. Testing allows organizations to verify that the patch resolves the identified security issue without adversely affecting the system or application's performance. It also helps in identifying potential conflicts with existing configurations or dependencies. Effective testing strategies include regression testing, performance testing, and security testing to ensure comprehensive validation of the patch's effectiveness and safety before widespread deployment. This approach aligns with best practices in patch management, emphasizing the importance of thorough testing to mitigate the risk of unintended consequences and ensure the continued security and stability of systems and applications.

References:

• Industry standards such as ISO/IEC 27001 (Information Security Management) highlight the importance of a systematic approach to managing patches, including the role of testing in assessing the effectiveness and impact of patches.
• Resources like "Patch Management Best Practices" from the Center for Internet Security (CIS) provide guidance on developing and implementing a patch management program that includes rigorous testing procedures to ensure patches are safely and effectively applied.

The scenario described indicates a lack in the vendor's Asset Management Program. An effective Asset Management Program includes maintaining an accurate inventory of hardware and devices, monitoring their status, and promptly identifying and responding to any losses or discrepancies. The failure to discover the loss of laptops and a tablet that processed company data for two years suggests deficiencies in tracking and managing physical assets. This lapse can lead to risks associated with data security, regulatory compliance, and operational integrity. A robust Asset Management Program should ensure that all assets are accounted for, their usage is monitored, and any anomalies or losses are quickly identified and addressed.

References:

• IT asset management standards, such as ISO/IEC 27001 (Information Security Management), emphasize the importance of maintaining an inventory of assets and implementing appropriate controls to safeguard organizational assets.
• The "IT Asset Management Handbook" by the International Association of IT Asset Managers (IAITAM) provides guidelines on establishing a comprehensive Asset Management Program, including best practices for asset tracking, monitoring, and loss prevention.

The primary objective of a third party risk assessment is to validate that the vendor/service provider has adequate controls in place based on the organization’s risk posture. A third party risk assessment (also known as supplier risk assessment) quantifies the risks associated with third-party vendors and suppliers that provide products or services to your organization1. This assessment is useful for analyzing both new and ongoing supplier relationships. The growing risk of supply chain attacks makes it critical to conduct thorough and regular risk assessments of your third parties. A third party risk assessment helps you identify, measure, and mitigate the potential risks that your third parties pose to your organization, such as data breaches, cyberattacks, compliance violations, operational disruptions, reputational damage, or financial losses. A third party risk assessment also helps you align your third party risk management (TPRM) program with your organization’s risk appetite, policies, standards, and procedures. A third party risk assessment typically involves the following steps1:

• Scoping: Define the scope of the assessment based on the type, nature, and criticality of the third party relationship. Determine the relevant risk domains, such as security, privacy, compliance, business continuity, etc.
• Data collection: Gather information from the third party using various methods, such as questionnaires, surveys, interviews, audits, tests, or evidence reviews.
• Analysis: Analyze the data collected and compare it with your organization’s risk criteria, benchmarks, and best practices. Identify any gaps, weaknesses, or issues in the third party’s controls, processes, or performance.
• Reporting: Document the findings and recommendations of the assessment in a clear and concise report. Communicate the results to the relevant stakeholders, such as senior management, business owners, or regulators.
• Remediation: Follow up with the third party to ensure that they implement the necessary actions to address the identified risks. Monitor and track the progress and effectiveness of the remediation plan.
• Review: Review and update the assessment periodically or whenever there are significant changes in the third party relationship, the risk environment, or the regulatory requirements.

The other statements are not the primary objective of a third party risk assessment, although they may be related or secondary objectives. Assessing the appropriateness of non-disclosure agreements regarding the organization’s systems/data is a legal objective that may be part of the contract negotiation or review process. Determining the scope of the business relationship is a strategic objective that may be part of the vendor selection or due diligence process. Evaluating the risk posture of all vendors/service providers in the vendor inventory is a holistic objective that may be part of the vendor risk management or governance process. References:

• 1: Third-Party Risk Assessment: A Practical Guide - BlueVoyant
• : What Is Third-Party Risk Management (TPRM)? 2024 Guide | UpGuard
• : What is Third-Party Risk Management? | Blog | OneTrust

A Business Impact Analysis (BIA) is a process of determining the criticality of business activities and associated resource requirements to ensure operational resilience and continuity of operations during and after a business disruption1. A BIA is used to identify the potential impacts of disruptions on business processes, such as lost sales, delayed revenue, increased expenses, regulatory fines, or contractual penalties2. A BIA is not concerned with the probability or causes of disruptions, but rather with the effects and consequences of disruptions3. Therefore, a BIA typically does not include requiring vendor participation in testing, as this is a part of the business continuity and disaster recovery planning and implementation, not the impact analysis. Vendor participation in testing is important to validate the effectiveness and alignment of the vendor’s business continuity and disaster recovery plans with the organization’s objectives and expectations, but it is not a component of the BIA itself. References: 1: Using Business Impact Analysis to Inform Risk Prioritization and Response 2: Business Impact Analysis (BIA): Prepare for Anything [2024] • Asana 3: The Difference Between a Vendor’s BIA and Risk Analysis - Venminder : Best Practices Guidance for Third Party Risk

 Risk culture is the term used to describe the collective way that an organization thinks about, manages, and responds to risk. It is influenced by the organization’s values, beliefs, norms, and practices, as well as the external environment and stakeholders. Risk culture affects how employees perceive, communicate, and act on risk issues, and how they balance risk and reward in their decision making. A strong risk culture is one that supports the organization’s strategic objectives, fosters accountability and transparency, and promotes learning and improvement. A weak risk culture is one that undermines the organization’s risk management framework, creates silos and conflicts, and exposes the organization to excessive or unnecessary risks. References:

• Shared Assessments CTPRP Study Guide, page 13, section 2.1.1
• GARP Best Practices Guidance for Third Party Risk, page 5, section 2.1
• Organizational culture | Definition, Benefits and Challenges

The Cardholder Data Environment (CDE) is the part of the network that stores, processes, or transmits cardholder data or sensitive authentication data, as well as any connected or security-impacting systems123. The CDE is subject to the Payment Card Industry Data Security Standard (PCI DSS), which is a set of requirements and guidelines for ensuring the security and compliance of payment card transactions123. The PCI DSS defines various artifacts that are reviewed when assessing the CDE, such as:

• The Data Security Standards (DSS) framework: This is the document that specifies the 12 high-level requirements and the corresponding sub-requirements and testing procedures for PCI DSS compliance123. The DSS framework should be used to scope the assessment, meaning to identify and document the systems and components that are in scope for PCI DSS, as well as the applicable requirements and controls for each system and component123. Therefore, option A is a true statement regarding artifacts reviewed when assessing the CDE.
• The Report on Compliance (ROC): This is the report that provides the assessment results completed by a qualified security assessor (QSA) that includes an onsite audit of the CDE123. The ROC is a detailed and comprehensive document that validates the organization’s compliance status and identifies any gaps or deficiencies that need to be remediated123. The ROC is required for merchants and service providers that process more than 6 million transactions annually, or that have suffered a breach or been compromised in the past year123. Therefore, option B is a true statement regarding artifacts reviewed when assessing the CDE.
• The Self-Assessment Questionnaire (SAQ): This is a questionnaire that provides a validation tool for merchants and service providers that are not required to submit a ROC123. The SAQ is a self-assessment tool that allows the organization to evaluate its own compliance status and identify any gaps or deficiencies that need to be remediated123. The SAQ does not provide independent testing of controls, as it is based on the organization’s self-reported answers and evidence123. Therefore, option C is a false statement regarding artifacts reviewed when assessing the CDE.
• A System and Organization Controls (SOC) report: This is a report that provides an independent audit of the internal controls and processes of a service organization, such as a cloud provider, a data center, or a payment processor45. The SOC report is not specific to PCI DSS, but rather to other standards and frameworks, such as SOC 1 (based on SSAE 18), SOC 2 (based on Trust Services Criteria), or SOC 3 (based on SOC 2)45. A SOC report is not sufficient to demonstrate PCI DSS compliance, as it may not cover all the requirements and controls of the PCI DSS, or it may not address the same location or scope as the CDE123. Therefore, option D is a false statement regarding artifacts reviewed when assessing the CDE.

References: The following resources support the verified answer and explanation:

• 1: PCI DSS Quick Reference Guide
• 2: PCI DSS FAQs
• 3: PCI DSS Glossary
• 4: What is a SOC report?
• 5: SOC Reports: What They Are, and Why They Matter

Personally identifiable information (PII) is any data that can be used to identify, contact, or locate an individual, such as name, address, email, phone number, social security number, etc. PII is subject to various legal and regulatory requirements, such as the GDPR, HIPAA, PCI DSS, and others, depending on the industry and jurisdiction. PII also poses significant security and privacy risks, as it can be exploited by malicious actors for identity theft, fraud, phishing, or other cyberattacks. Therefore, organizations that collect, store, process, or transmit PII must implement appropriate safeguards to protect it from unauthorized access, disclosure, modification, or loss.

One of the key safeguards for PII protection is encryption, which is the process of transforming data into an unreadable format using a secret key. Encryption ensures that only authorized parties who have the key can access the original data. Encryption can be applied to data at rest (stored on a device or a server) or data in transit (moving across a network or the internet). Encryption can also be symmetric (using the same key for encryption and decryption) or asymmetric (using a public key for encryption and a private key for decryption).

Another key safeguard for PII protection is authentication, which is the process of verifying the identity of a user or a system that requests access to data. Authentication ensures that only legitimate and authorized parties can access the data. Authentication can be based on something the user knows (such as a password or a PIN), something the user has (such as a token or a smart card), something the user is (such as a fingerprint or a face scan), or a combination of these factors. Authentication can also be enhanced by using additional methods, such as one-time passwords, challenge-response questions, or multi-factor authentication.

When defining third party requirements for transmitting PII, the factors that provide stronger controls are the strength of encryption cipher and authentication method. These factors determine how secure and reliable the data transmission is, and how resistant it is to potential attacks or breaches. The strength of encryption cipher refers to the algorithm and the key size used to encrypt the data. The stronger the cipher, the more difficult it is to break or crack the encryption. The strength of authentication method refers to the type and the number of factors used to verify the identity of the user or the system. The stronger the authentication method, the more difficult it is to impersonate or compromise the user or the system.

The other factors, such as full disk encryption and backup, available bandwidth and redundancy, and logging and monitoring, are also important for PII protection, but they do not directly affect the data transmission process. Full disk encryption and backup are relevant for data at rest, not data in transit. They provide protection in case of device theft, loss, or damage, but they do not prevent data interception or modification during transmission. Available bandwidth and redundancy are relevant for data availability and performance, not data security and privacy. They ensure that the data transmission is fast and reliable, but they do not prevent data exposure or corruption during transmission. Logging and monitoring are relevant for data audit and compliance, not data encryption and authentication. They provide visibility and accountability for the data transmission activities, but they do not prevent data access or misuse during transmission. References:

• : What is Data Encryption? | Definition and Examples | Imperva
• : What is Authentication? | Definition and Examples | Imperva
• : Personally Identifiable Information (PII) - Imperva
• : Data Protection - Shared Assessments

Web content accessibility guidelines (WCAG) are a set of standards that aim to make web content more accessible to people with disabilities, such as visual, auditory, cognitive, or motor impairments. While WCAG is a good practice for web development and usability, it is not directly related to web application security. WCAG does not address the common security risks that web applications face, such as injection, broken authentication, misconfiguration, or vulnerable components. Therefore, adhering to WCAG is not a method of securing web applications, unlike the other options. References:

• 4: OWASP Top 10, a standard awareness document for web application security, lists the most critical security risks to web applications and provides best practices to prevent or mitigate them.
• 5: SANS Institute, a leading provider of cybersecurity training and certification, offers a security checklist for web application technologies (SWAT) that covers best practices for error handling, data protection, configuration, authentication, session management, input and output handling, and access control.
• 6: Built In, a platform for tech professionals, provides 13 web application security best practices, such as using a web application firewall, keeping track of APIs, enforcing expected application behaviors, and following the OWASP Top 10.

Application whitelisting is a security technique that allows only authorized applications to run on a device or network, preventing malware or unauthorized software from executing. While this can be a useful security measure, it is not directly related to remote access risk evaluation, which focuses on the security of the connection and the access rights of the remote users. The other options are more relevant to remote access risk evaluation, as they help to monitor, control, and audit the remote access activities and prevent unauthorized or malicious access. References:

• 1: Secure Remote Access: Risks, Auditing, and Best Practices
• 2: 5 Common Vulnerabilities Associated With Remote Access