Outsourcing a function does not outsource accountability for it. When a payroll provider leaks employee records or a cloud service goes down, customers and regulators still look at the organization that chose the vendor. Third-party risk management is the discipline of knowing who you depend on, how much, and what happens if they fail.
Security is only one kind of vendor risk
Tiering: not every vendor deserves the same scrutiny
Sending a 200-question security questionnaire to your office snack supplier wastes everyone's time, and it dilutes attention from the vendors that matter. Tiering assigns effort by criticality and data access. A simple three-tier model looks like this:
Example tiering model
The free vendor tiering model and vendor security questionnaire are ready to adapt.
The lifecycle
- Inventory: find every vendor, including those bought on company cards and free tools connected to corporate identity.
- Tier: classify by data access and business criticality.
- Assess: collect questionnaires and assurance reports proportionate to tier, and record findings in the risk register.
- Contract: agree security, breach notification, audit, and data processing terms before signing.
- Monitor: re-assess on schedule and watch for breaches, report expiries, and changes in service.
- Offboard: revoke access, retrieve or confirm deletion of data, and update the inventory.
Fourth parties and the shared-responsibility gap
Your vendors have vendors. A SaaS provider's own hosting and support subcontractors are your fourth parties, and a failure there reaches you just as surely. Review subprocessor lists for critical vendors. When reading a vendor's SOC 2 report, check the complementary user entity controls section too: it lists the controls you must operate for the vendor's controls to be effective, and missing them creates a gap no questionnaire will reveal.
What frameworks expect
ISO/IEC 27001:2022 Annex A covers suppliers in controls 5.19 to 5.23, spanning supplier relationships, agreements, the ICT supply chain, monitoring and change, and cloud services. The SOC 2 Common Criteria address vendor and business partner risk under CC9.2. GDPR requires written terms with processors. For building the full program, see the vendor risk program guide.