Vendor management policies are documented procedures for handling the activities of a company’s vendors. They are important for businesses within many industries, but they are especially critical for financial institutions. Increasingly, technology and other services are being outsourced by today’s financial institutions. Every time a form of technology or another service is outsourced to a vendor, the risk of security problems and other issues is significantly heightened. In order to mitigate that risk, it is imperative that a financial institution has a sound vendor management policy in place.
Creating an Effective Vendor Management Policy
Several very credible sources have outlined the appropriate process for creating an effective vendor management policy. NCUA’s Guidance for Evaluating Third Party Relationship Risk (NCUA Letter 07-CU-13), in particular, is a valuable resource for financial institutions that need to create a policy of their own. A four step process is generally agreed to be the best way of arriving at an appropriate vendor management solution; an overview of those steps is highlighted below.
1. Analyzing Risk – Vendors must be assessed for their risk on a case-by-case basis. This risk assessment or analysis should take several different points into consideration. The importance of the function that the vendor will be charged with accomplishing must be assessed. The inherent risks that are involved in the activities that they will be performing for the financial institution should be considered. The risk assessment process should be documented, and should cover concerns like whether or not backup will be available and whether or not the vendor’s activities will be easy to oversee. Ultimately, the higher the risk, the greater the diligence that will need to be used in selecting a vendor. The results of the risk analysis will color all of the other steps in the process.
2. Selecting a Vendor – The intensity of the scrutiny that will be needed in selecting a vendor will depend on the results of the preceding risk analysis. Inquiries need to be made into a vendor’s financial abilities, as well as their abilities to meet the vendor’s requirements. Careful examinations of a prospective vendor’s industry expertise, staffing, internal controls like internal audits, contingency plans and security must be undertaken. Finally, a prospective vendor should be able to produce financial statements; if not, they should not be considered as this is indicative of high risk.
3. Preparing a Contract – A simple, written form contract should be prepared and reviewed by legal counsel. The expectations and responsibilities of both parties should be clearly communicated within it. Specific details concerning fees, time frames and implementation procedures should be addressed. In the case of a technology contract, a service level agreement – or SLA – should be prepared. Finally, long-term contracts are generally bad ideas.
4. Ongoing Supervision and Monitoring – The financial institution should assign an officer to oversee the vendor’s performance. The level of supervision required will depend on the results of the initial risk assessment. Period reviews of the vendor’s financial and insurance condition, along with their security and internal controls, should be conducted. An assessment of whether or not they’ve been meeting the terms of the agreement should be made at least once a year.
For more information about Vendor Management or other IT related policies find RedRock Information Security on the web at www.redrockis.com or call us toll free at 877-258-8065