Establish and maintain an inventory of service providers. The inventory is to list all known service providers, include classification(s), and designate an enterprise contact for each service provider. Review and update the inventory annually, or when significant enterprise changes occur that could impact this Safeguard.
Establish and maintain a service provider management policy. Ensure the policy addresses the classification, inventory, assessment, monitoring, and decommissioning of service providers. Review and update the policy annually, or when significant enterprise changes occur that could impact this Safeguard.
Classify service providers. Classification consideration may include one or more characteristics, such as data sensitivity, data volume, availability requirements, applicable regulations, inherent risk, and mitigated risk. Update and review classifications annually, or when significant enterprise changes occur that could impact this Safeguard.
Ensure service provider contracts include security requirements. Example requirements may include minimum security program requirements, security incident and/or data breach notification and response, data encryption requirements, and data disposal commitments. These security requirements must be consistent with the enterprise’s service provider management policy. Review service provider contracts annually to ensure contracts are not missing security requirements.
Assess service providers consistent with the enterprise’s service provider management policy. Assessment scope may vary based on classification(s), and may include review of standardized assessment reports, such as Service Organization Control 2 (SOC 2) and Payment Card Industry (PCI) Attestation of Compliance (AoC), customized questionnaires, or other appropriately rigorous processes. Reassess service providers annually, at a minimum, or with new and renewed contracts.
Monitor service providers consistent with the enterprise’s service provider management policy. Monitoring may include periodic reassessment of service provider compliance, monitoring service provider release notes, and dark web monitoring.
Securely decommission service providers. Example considerations include user and service account deactivation, termination of data flows, and secure disposal of enterprise data within service provider systems.
Establish and maintain a secure application development process. In the process, address such items as: secure application design standards, secure coding practices, developer training, vulnerability management, security of third-party code, and application security testing procedures. Review and update documentation annually, or when significant enterprise changes occur that could impact this Safeguard.
Leverage vetted modules or services for application security components, such as identity management, encryption, and auditing and logging. Using platform features in critical security functions will reduce developers’ workload and minimize the likelihood of design or implementation errors. Modern operating systems provide effective mechanisms for identification, authentication, and authorization and make those mechanisms available to applications. Use only standardized, currently accepted, and extensively reviewed encryption algorithms. Operating systems also provide mechanisms to create and maintain secure audit logs.
Apply static and dynamic analysis tools within the application life cycle to verify that secure coding practices are being followed.