Information Security Policy for Supplier Relationships
Introduction
Vertic Ltd Pty and its core business exists in a wider economic environment in which effective relationships with suppliers are critical to its continued success. It is very important therefore that our relationships with suppliers are based on a clear understanding of our expectations and requirements in the area of information security. These requirements must be documented and agreed in a way that leaves no doubt about the importance we place on the maintenance of effective controls to reduce risk. The purpose of this document is to set out the organisation’s information security policy in the area of supplier relationships.
Information security policy for supplier relationships
General provisions
In general, information security requirements will vary according to the type of contractual relationship that exists with each supplier and the goods or services delivered.
However, the following (or some of the below) will generally apply.
The information security requirements and controls may be formally documented in a contractual agreement which may be part of, or an addendum to, the main commercial contract
Separate Non-Disclosure Agreements must be used where a more specific level of control over confidentiality is required
Appropriate due diligence must be exercised in the selection and approval of new suppliers before contracts are agreed
The information security provisions in place at existing suppliers (where due diligence was not undertaken as part of initial selection) must be clearly understood and improved where necessary
Remote access by suppliers must be via approved methods that comply with our information security policies
Access to Vertic Ltd Pty information must be limited where possible according to clear business need
Basic information security principles such as least privilege, segregation of duties and defence in depth must be applied
The supplier will be expected to exercise adequate control over the information security policies and procedures used within sub-contractors who play a part in the supply chain of delivery of goods or services to [Organization Name]
Vertic Ltd Pty will have the right to audit the information security practices of the supplier and, where appropriate, sub-contractors
Incident management and contingency arrangements must be put in place based on the results of a risk assessment
Awareness training will be carried out by both parties to the agreement, based on the defined processes and procedures
A Supplier Information Security Checklist may be required for completion by external suppliers
The selection of required controls must be based upon a comprehensive risk assessment considering information security requirements, the product or service to be supplied, its criticality to the organization and the capabilities of the supplier.
Cloud services
Cloud service providers (CSPs) must be clearly recognised as such so that the risks associated with the CSP’s access to and management of Vertic Ltd Pty cloud data may be managed appropriately.
When acting as a CSP, Vertic Ltd Pty will clearly set out the relevant information security measures it will implement as part of the agreement. Vertic Ltd Pty will also ensure that information security objectives are set for third parties who provide components of the cloud service to customers and that they carry out adequate risk assessment in order to achieve an acceptable level of security.
Due diligence
Before contracting with a supplier, it is incumbent upon Vertic Ltd Pty to exercise due diligence in reaching as full an understanding as possible of the information security approach and controls the company has in place. It is important that the documented Supplier Due Diligence Assessment Procedure is followed so that all the required information is collected, and an informed assessment can be made.
This is particularly important where cloud computing services are involved, as legal considerations regarding the location and storage of personal data must be considered.
Addressing security within supplier agreements
Once a potential supplier has been positively assessed with due diligence the information security requirements of Vertic Ltd Pty must be reflected within the written contractual agreement entered into. This agreement must consider the classification of any information that is to be processed by the supplier (including any required mapping between Vertic Ltd Pty classifications and those in use within the supplier), legal and regulatory requirements and any additional information security controls that are required.
For cloud service contracts, information security roles and responsibilities must be clearly defined in areas such as backups, incident management, vulnerability assessment and cryptographic controls.
A template Vertic Ltd Pty Supplier Information Security Agreement may be used as a starting point.
Appropriate legal advice must be obtained to ensure that contractual documentation is valid within the country or countries in which it is to be applied.
Evaluation of existing suppliers
For those suppliers that were not subject to an information security due diligence assessment prior to an agreement being made, an evaluation process must be undertaken in order to identify any required improvements. For details of this process see Supplier Information Security Evaluation Process.
Monitoring and review of supplier services
In order to focus resources on the areas of greatest need, suppliers will be categorised based on an assessment of their value to the organization.
Each supplier will be placed into one of the following four categories:
Commodity
Operational
Tactical
Strategic
The recommended frequency of supplier review meetings between Vertic Ltd Pty and each supplier will be determined by the supplier’s category according to the following table.
SUPPLIER CATEGORY | RECOMMENDED MEETING FREQUENCY |
Commodity | None |
Operational | On contract renewal |
Tactical | Annually |
Strategic | Monthly/Quarterly |
Table 1: Meeting frequencies by supplier category
Each supplier will have a designated contract manager within Vertic Ltd Pty who is responsible for arranging, chairing and documenting the meetings.
The performance of strategic suppliers will be monitored on a regular basis in line with the recommended meeting frequency. This will take the form of a combination of supplier-provided reports against the contract and internally produced reports.
Where possible, a frequent cross-check will be made between the supplier reports and those created internally in order to make sure the two present a consistent picture of supplier performance. Both sets of reports will be reviewed at supplier meetings and any required actions agreed.
Managing changes to supplier services
Changes within contract
Changes to services provided by suppliers will be subject to the Vertic Ltd Pty change management process. This process includes the requirement to assess any information security implications of changes so that the effectiveness of controls is maintained.
Contractual Disputes
In the event of a contractual dispute, the following initial guidelines must be followed:
The Chief Financial Officer must be informed that a dispute exists
The CFO will then decide on next steps, based on an assessment of the dispute
Where applicable, legal advice should be obtained via the CFO
All correspondence with the supplier in dispute must be in writing and with the approval of the CFO
An assessment of the risk to the organization should be carried out prior to escalating any dispute, and contingency plans put in place
At all times the degree of risk to the business must be managed and if possible minimised.
End of contract
The following process will be followed for scheduled end of contract, early end of contract or transfer of contract to another party:
The end of contract will be requested in writing within the agreed terms
Transfer to another party shall be planned as a project and appropriate change control procedures followed
An assessment of the risk to the organization should be carried out prior to ending or transferring the contract, and contingency plans put in place
Any budgetary implications shall be incorporated into the financial model
The various aspects of ending a contract must be carefully considered at initial contract negotiation time.