Preparing a Third-Party Incident Response Plan

Early Considerations for Third-Party Incident Response 

The rise in third-party cyberattacks significantly increases the chances of a breach at partner organizations. Risk managers must assess how well they can protect their organization in such cases. Consider the following:

• Visibility: How are you currently managing your vendors? Do you have visibility into their risk posture across the board? Is it continuously updated? 

• Notification: Can you quickly identify potential vendor vulnerabilities and recommend remediations? 

• Analysis: If a breach occurred at an essential third party, what is the process for assessing the impact on your organization, and what controls are in place to ensure prompt notification? How long will analysis take, and what tools will be used to provide your organization with forensic evidence? 

• Communications: Once forensic data is provided, who manages and analyzes the impact? If using spreadsheets, are you efficiently sharing and communicating that information to all stakeholders? 

• Evidence: Do you maintain audit-quality records of events? Are these readily available when risk managers, senior leadership, and auditors request data? 

• Resources: Does your program scale without adding security and risk personnel? How many resources do you have to re-direct to an urgent project like this? What is the impact on the team or other projects? 

9 Best Practices for Building a Third-Party Incident Response Plan 

A solid response plan is essential to protect your organization when a critical vendor is breached. Follow these nine steps to build an effective third-party incident response plan:

1. Form a Cross-Functional Team 

Identify and assign responsibilities to key internal and external stakeholders across IT, security, privacy, risk, legal, and communications. Use tabletop exercises to simulate incidents, test the efficacy of your response plan, and ensure your team is ready with the necessary capabilities and resources.

2. Build a Centralized Vendor Database 

Managing vendors with spreadsheets is error-prone and does not scale. Manage third parties with a centralized platform for consistent surveys, responses, analysis, and reporting.

3. Establish Communications Procedures and SLAs 

Provide vendors with a simple way to update you on breaches or security incidents. Include communication protocols, such as information gathering steps and escalation paths, and enforce contract measures, such as incident response service level agreements (SLAs).

Leverage solutions that facilitate proactive incident response. Consider developing and sharing a playbook for pre- and post-breach procedures to provide better visibility to all parties. 

4. Profile and Tier All Vendors 

Each third party represents distinct levels of risk to an organization. Conducting profiling and tiering on third parties helps you to understand the potential impact of a vendor breach based on factors such as their industry, location, or criticality of their solution or service to your business. 

5. Assess Vendor Incident Response Capabilities 

Many third-party risk surveys focus primarily on a vendor's defenses, but in today’s environment, teams must assume incidents are inevitable. Organizations should also evaluate a vendor’s ability to respond to incidents, including their policies for handling, investigating, and recovering from breaches.

This assessment should include escalation and communication procedures, notification requirements, logging policies, forensic data collection, analysis capabilities (internal or external), and regular testing to ensure effectiveness.

6. Automate Vendor Surveys 

Relying on a spreadsheet-driven approach to identify gaps in incident response capabilities and/or incident alerts is inefficient and leaves organizations with poor protection. Automate the collection and analysis of third-party event information to ensure continuous, up-to-date risk visibility.

7. Employ a Risk Matrix to Weight the Risks 

A risk for one vendor may not be a risk for another. Scale or weight risks based on the vendor’s role and data interaction to keep your team focused on the most critical threats.

8. Provide Remediation Guidance and Implement Process Improvements 

Provide your third parties with clear guidance on how to improve their incident response plans and then track, score, and manage residual risk. This helps partners become more proactive and accelerates risk identification and mitigation controls.  

9. Continuously Monitor for Adverse Events 

Don’t rely solely on vendors to report incidents. Continuously monitor for new and emerging cyber threats across your vendor ecosystem. Instead of trying to stay on top of security news and community postings manually, look for threat intelligence providers that can automate and scale the monitoring process for you. 

Additional Considerations to Include in Your Incident Response Strategy:

Review Basic Security Controls  
Assess vendors' access to your infrastructure and data. Implement tools like behavioral analysis, micro-segmentation, and privileged user management.

Conduct Post-Incident Follow-Up  
Analyze incidents to identify lessons learned and prevent future mistakes. Implement corrective actions and develop practice cases for future exercises.

Benchmark Your Incident Response Plan with Industry Standards

Several industry standards and cybersecurity frameworks provide additional guidance on third-party incident response. Including:

• NIST 800-61R2: Computer Security Incident Handling Guide 

• ISO/IEC 27035-1:2023: Information Security Incident Management Part 1: Principles and Process

• ISO/IEC 27035-2:2023: Information Security Incident Management Part 2: Guidelines to Plan and Prepare for Incident Response 

• OCC 2021-55: Bank Incident Notification Final Rule, issued 11/23/2021 

• OCC2022-8: Information technology Points of Contact for Bank’s Computer Security Incident Notifications, issued 3/29/2022

For a detailed look at the NIST guidelines, download our NIST Third-Party Incident Response Checklist.

Incorporate Incident Response Requirements Into Third-Party Risk Management

Incorporating incident response requirements into a programmatic third-party risk management plan helps organizations maintain visibility into all risks and react more quickly when incidents occur. The benefits of this approach include: 

• Reduced Mean Time to Resolution (MTTR): Automating vendor incident analysis enables quicker internal risk mitigation.

• Accelerated Updates: A centralized platform lets third parties proactively submit event updates, giving your team timely information.

• Simplified Audits: A third-party risk platform can provide auditors with easy access to data, eliminating the need for manual reporting. The platform should include incident response capabilities and controls to automatically track plans, events, remediation, and impact.

• Better Reporting: Leverage a centralized solution to keep detailed records of incident responses and share timely updates with executives and the board.

By preparing in advance, establishing communication channels, and having a comprehensive incident response plan, your organization will be better equipped to handle third-party data breaches. Proactive risk management protects your company, partners, and customers from the broad impact of cybersecurity threats.

Next Steps: Streamline Incident Response Management

Many organizations struggle with delays in receiving breach information from their vendors. Manual notification processes slow down risk assessment and remediation. To speed up incident response, use automated TPRM platforms and managed services.

The Prevalent Third-Party Incident Response Service 

The Prevalent Third-Party Incident Response Service helps organizations manage vendors centrally, assess them using a contextual questionnaire, score risks flexibly, and offer prescriptive remediation guidance. Available as a managed service or self-service platform, Prevalent automates key tasks, helping you quickly identify and mitigate vendor vulnerabilities.

The Prevalent™ Third-Party Incident Response Service enables organizations to: 

• Simplify response management with a centralized vendor database.

• Automate vendor incident information collection and analysis.

• Accelerate response times through proactive event notifications.

• Expedite remediation with built-in recommendations.

• Prepare for board and executive questions about vendor incidents.

• Demonstrate third-party breach response plans to auditors.

• Continuously monitor the Internet and dark web for cyber threats and compromised data. 

Learn how you can streamline and enhance your incident response strategy. Request a demo and strategy call today.