ISO 27001 Control 5.22 Monitoring, review and change management of supplier services

What is Control 5.22?

ISO 27001 Control 5.22 is designed to help your organization monitor supplier performance, address changes proactively, and manage risks to maintain strong information security.

Control Type

  • Preventive

Information Security Properties

  • Confidentiality
  • Integrity
  • Availability

Cybersecurity Concepts

  • Identify

Operational Capabilities

  • Supplier Relationships Security
  • Information Security Assurance

Security Domains

  • Governance and Ecosystem
  • Defence

1. Intro to Control 5.22

The goal of Control 5.22 is to maintain a high level of security and service delivery, even as suppliers change their offerings or face disruptions.

  • It promotes Transparency in supplier operations.
  • It provides a framework for addressing changes in supplier services without compromising security.
  • It enables organizations to Identify Risks Early and take corrective action before they escalate.

2. Understanding Control 5.22

ISO 27001 Control 5.22 takes a proactive approach, prioritizing the need for regular monitoring, thorough reviews, and effective change management to ensure suppliers meet agreed security and service standards. 

2.1 What is Control 5.22?

Control 5.22 is a part of ISO 27001’s broader effort to secure relationships with suppliers. Specifically, it requires organizations to:

  • Monitor supplier performance to ensure compliance with agreements.
  • Review and manage changes in supplier services or business operations that could affect security.
  • Maintain a clear relationship between your organization and the supplier, ensuring transparency and accountability.

2.2 The Objectives of Control 5.22

At its core, this control has two primary goals:

  1. Maintain Agreed Levels of Security and Service Delivery
    Supplier agreements often include specific terms around information security and service performance. Control 5.22 ensures that these commitments are actively monitored and enforced.

  2. Mitigate Risks from Supplier Changes
    Suppliers change—new technologies, updated policies, subcontracting arrangements, or even changes in their business status. Each of these changes can introduce new risks. This control provides a framework for identifying, assessing, and addressing these risks promptly.

2.3 Key Components of Control 5.22

Control 5.22 is layered, addressing various aspects of supplier management. 

2.3.1 Monitoring Service Performance

Suppliers’ services must align with the agreed standards, especially regarding security. Regular monitoring ensures that any deviations are identified and resolved quickly.

  • Example: If a cloud provider’s uptime drops below the agreed service level, monitoring systems should flag this for immediate follow-up.

2.3.2 Managing Supplier Changes

Suppliers often modify their services, adopt new technologies, or engage new subcontractors. These changes can have a direct impact on your organization’s security.

  • Examples of Changes to Monitor:

    • Enhancements to services, such as new features or functionalities.
    • Updates to policies, procedures, or security controls.
    • Adoption of new tools, environments, or physical locations.
    • Changes in the supplier’s subcontracting arrangements.

  • Why This Matters: A supplier changing their development tools could inadvertently introduce vulnerabilities. Monitoring such changes helps ensure that risks are identified and addressed before they affect your systems.

2.3.3 Incident and Problem Management

Security incidents can occur at any point in the supply chain. Control 5.22 emphasizes the need for a structured process to manage such events.

  • Actionable Steps:

    • Review supplier-reported incidents regularly.
    • Analyze root causes and ensure corrective actions are taken.
    • Use insights from incidents to refine your own security measures.

  • Example: If a supplier experiences a phishing attack that compromises their systems, you need to assess the potential impact on your organization and take immediate action to mitigate risks.

2.3.4 Audits and Compliance Reviews

Control 5.22 highlights the importance of regular audits and compliance checks to ensure that suppliers are adhering to their contractual obligations.

  • Internal Audits: Conduct your own assessments of supplier performance.
  • Independent Audits: Leverage third-party reports for additional assurance.
  • Actionable Tip: Use findings from audits to drive improvements, addressing gaps proactively.

2.3.5 Continuity and Resilience Planning

Suppliers play a critical role in your operations, and their disruptions can have snowballing effects. This makes sure that suppliers are prepared for disasters or major service failures.

  • What to Look For:
    • Supplier business continuity plans.
    • Disaster recovery strategies.
    • Alternative service providers or backup arrangements.

3. Purpose of Control 5.22

The purpose of Control 5.22 is to maintain the integrity, availability, and confidentiality of your operations by ensuring that supplier services align with agreed-upon security and performance standards. 

3.1 Ensuring an Agreed Level of Information Security and Service Delivery

When you sign an agreement with a supplier, you’re trusting them to uphold your security and operational standards. Control 5.22 verifies that this trust is continuously validated through monitoring and reviews.

  • Why it Matters:
    Suppliers often manage critical infrastructure, sensitive data, or essential business processes. A lapse in their security practices can have a direct impact on your organization, from data breaches to operational downtime.

  • How Control 5.22 Helps:

    • Encourages organizations to establish clear expectations in supplier agreements.
    • Requires ongoing validation to ensure these expectations are consistently met.
    • Promotes regular dialogue and collaboration between organizations and suppliers.

Example in Action:
Imagine you rely on a cloud service provider to store customer data. Control 5.22 ensures that the provider adheres to data encryption, access control, and incident response requirements throughout the term of the contract—not just at the beginning.

3.2 Mitigating Risks Associated with Supplier Services

Suppliers operate in dynamic environments, where changes to their services, technologies, or business structures can introduce new risks. Control 5.22 provides a framework to proactively identify and address these risks.

  • Types of Risks to Monitor:

    • Service Modifications: Changes to networks, software, or infrastructure that could introduce vulnerabilities.
    • Supplier Disruptions: Financial instability, leadership changes, or other business disruptions that could affect service continuity.
    • Security Incidents: Vulnerabilities or breaches within the supplier’s operations that could cascade to your organization.

  • Proactive Risk Mitigation Strategies:

    • Establishing monitoring systems to track service performance and changes.
    • Conducting regular audits to identify and address potential weaknesses.
    • Maintaining a contingency plan to ensure continuity in case of supplier failure.

Example:
If a supplier adopts a new development tool, it could inadvertently introduce vulnerabilities into their software.

3.3 Why Purpose Drives Implementation

Control 5.22 aims to secure that your organization and its partners work together to maintain a secure, reliable operational environment. By focusing on maintaining agreed security standards and mitigating risks.

4. Guidance for Implementation

ISO 27001 Control 5.21 requires to use a structured and proactive approach to monitoring, reviewing, and managing changes in supplier services.

4.1 Monitoring Service Performance

Regularly assessing supplier service levels ensures compliance with agreed terms and helps identify issues before they escalate. 

  • Key Actions:
    • Use KPIs to track critical metrics like uptime, incident response times, and data handling.
    • Automate performance monitoring with tools that provide real-time insights into service delivery.
    • Schedule regular reviews to assess supplier adherence to contractual obligations.

Example:
If a cloud provider commits to 99.9% uptime in the SLA but falls short, monitoring tools should flag this discrepancy immediately, prompting a review.

4.2 Managing Supplier Changes

Suppliers are dynamic entities. They introduce updates, adopt new tools, and change operational processes. Tracking these changes is essential to ensure they don’t inadvertently introduce vulnerabilities.

  • What to Monitor:

    • Enhancements to existing services or systems.
    • Development of new applications or features.
    • Updates to policies, procedures, or security controls.

  • Action Plan:

    • Require suppliers to notify you of any planned changes in advance.
    • Conduct risk assessments to evaluate potential impacts.
    • Adjust contracts or SLAs to reflect significant updates.

Example:
A supplier decides to adopt AI-driven monitoring tools. While this may improve efficiency, it could also raise new privacy or security concerns that require thorough evaluation.

4.3 Monitoring Service Modifications

Service modifications, such as network upgrades or changes in subcontractors, can significantly impact your security posture. 

  • Types of Modifications to Track:

    • Changes to networks, technologies, or products.
    • Introduction of new development tools or environments.
    • Relocation of service facilities or physical infrastructure.
    • Subcontracting to additional or alternative suppliers.

  • Proactive Monitoring Steps:

    • Maintain an updated inventory of all supplier services and their critical dependencies.
    • Collaborate with suppliers to understand the scope and purpose of changes.
    • Use contractual clauses to enforce advanced notification and joint evaluations.

Example:
If a supplier shifts their data center operations to a new geographic location, you need to assess the regulatory implications and potential security risks of the move.

4.4 Conducting Review Processes

Routine reviews ensure that suppliers remain compliant and provide opportunities to address emerging risks proactively.

  • How to Conduct Reviews:
    • Evaluate supplier-generated service reports for insights into performance, incidents, and updates.
    • Arrange regular progress meetings to discuss issues, updates, and future plans.
    • Perform audits of suppliers and their subcontractors to verify compliance with agreements.

4.5 Incident Management

When security incidents occur, quick and coordinated action is crucial. Control 5.22 emphasizes the importance of structured incident management processes that include both your organization and the supplier.

  • Key Actions:
    • Establish clear reporting timelines for incidents, ensuring timely communication.
    • Review incident reports to analyze root causes and verify resolution effectiveness.
    • Conduct post-incident reviews to identify lessons learned and prevent recurrence.

Example:
If a supplier experiences a DDoS attack that impacts your services, their incident response should include notifying your team promptly, mitigating the issue, and sharing actionable insights.

4.6 Reviewing Audit Trails and Records

Reviewing supplier records helps identify patterns, vulnerabilities, and opportunities for improvement. This includes examining logs of security events, operational problems, and disruptions.

  • Best Practices:
    • Regularly analyze audit trails to detect unusual activity or repeated issues.
    • Use these records to validate compliance with your organization’s security standards.
    • Follow up on discrepancies or concerns with targeted discussions and audits.

Tip:
Incorporate automated tools to analyze large volumes of supplier data for faster and more accurate insights.

4.7 Responding to and Managing Security Events

Security events and vulnerabilities require swift, decisive action. Control 5.22 outlines the importance of maintaining readiness to address these challenges effectively.

  • Steps to Take:
    • Define roles and responsibilities for managing security events within both your organization and the supplier’s team.
    • Collaborate with suppliers to implement corrective actions and improve preventive measures.
    • Regularly update your response protocols based on lessons learned from past events.

Example:
If a vulnerability is discovered in a software product provided by a supplier, your response plan should include patch deployment, testing, and communication with affected stakeholders.

4.8 Ensuring Service Continuity

Suppliers are integral to your operations, and disruptions can have cascading effects. Ensuring they have robust continuity plans is essential to maintaining resilience.

  • What to Look For:
    • Comprehensive business continuity and disaster recovery plans.
    • Clear strategies for maintaining service levels during disruptions.
    • Testing and updating continuity plans regularly to account for new risks.

Example:
A supplier that hosts your website should have backup systems in place to maintain availability during a power outage or cyberattack.

4.9 Compliance and Regular Evaluation

Suppliers must be evaluated regularly to ensure they continue meeting agreed security standards.

  • How to Ensure Compliance:
    • Assign responsibility for supplier compliance reviews to a designated team or individual.
    • Use performance metrics, audit findings, and incident reports to evaluate supplier security levels.
    • Take corrective action when deficiencies are observed, such as revising SLAs or seeking alternative providers.

Tip:
Integrate supplier compliance reviews into your organization’s overall risk management framework for a holistic approach.

5. Assigning Responsibilities

Control 5.22 effectively requires clear accountability. Without clear ownership, critical tasks can fall through the cracks, jeopardizing both service delivery and information security.

5.1 Designating Individuals or Teams

Every supplier relationship should have a point of contact or a designated team responsible for oversight. 

  • Key Roles and Responsibilities:
    • Supplier Relationship Manager: Acts as the primary liaison between your organization and the supplier, ensuring smooth communication and alignment with contractual obligations.
    • Compliance Officer: Verifies that suppliers adhere to agreed security standards and regulatory requirements.
    • Technical Specialist: Assesses the technical aspects of supplier services, including security controls, system performance, and incident management.

Example:
In a small organization, a single individual might manage supplier relationships, while in a larger organization, a dedicated team could oversee high-priority or high-risk suppliers.

5.2 Ensuring the Necessary Skills and Resources

Managing supplier relationships in line with Control 5.22 requires equipping individuals or teams with the right skills, tools, and support.

  • Required Technical Skills:

    • Understanding of Information Security Standards: Familiarity with ISO 27001, including controls like 5.22, and other relevant standards like ISO/IEC 27036.
    • Risk Assessment Expertise: The ability to identify and evaluate risks associated with supplier services and changes.
    • Incident Management Knowledge: Experience in coordinating responses to security incidents, including root cause analysis and mitigation planning.

  • Access to Resources:

    • Monitoring Tools: Platforms for tracking supplier performance, such as SLA compliance dashboards and security event logging tools.
    • Audit Support: Tools and frameworks for conducting internal and external audits of supplier operations.
    • Training and Development: Regular training to keep teams updated on emerging threats, technologies, and best practices in supplier management.

Tip:
Conduct skills assessments for the assigned individuals or teams to identify gaps and provide targeted training where needed.

5.3 Collaborative Approach

While assigning responsibilities is critical, supplier management often involves collaboration across departments. For instance:

  • Procurement Teams: Ensure that supplier contracts and SLAs include clear security requirements.
  • IT and Security Teams: Provide technical support for evaluating supplier services and implementing monitoring tools.
  • Legal Teams: Address compliance issues and ensure contracts align with regulatory requirements.

Example:
In a collaborative setup, the IT team might flag performance issues with a supplier’s service, while the relationship manager engages with the supplier to address the problem, and the legal team updates the contract terms if necessary.

5.4 Accountability and Reporting

Assigning responsibilities also involves defining accountability. Each designated individual or team should have clear reporting lines and deliverables to ensure transparency and progress tracking.

  • Regular Reporting: Designate a schedule for reporting on supplier performance, incidents, and any changes affecting security.
  • Escalation Processes: Establish a clear process for escalating issues that require higher-level intervention.

Tip:
Use performance dashboards to provide senior management with a quick overview of supplier status and compliance levels.

6. Best Practices for Effective Monitoring and Review

You can create a system for monitoring and reviewing supplier services, ensuring alignment with your organization’s security and performance expectations.

6.1 Establishing Clear Performance Metrics

Metrics are the foundation of effective monitoring. Without clear, measurable benchmarks, it’s impossible to determine whether a supplier is meeting their obligations or identify areas for improvement.

  • Define Relevant KPIs: Focus on metrics that directly reflect supplier performance and security, such as:

    • Service uptime and availability.
    • Incident response times.
    • Adherence to security protocols (e.g., encryption standards, access controls).

  • Set Baselines and Targets: Ensure every metric has an established baseline and agreed-upon target. These should align with the terms of your contract or SLA.

  • Use Dashboards for Transparency: Leverage digital dashboards to track and visualize supplier performance in real-time. This not only makes it easier to identify issues but also fosters accountability.

Example in Action:
If your supplier commits to a 99.9% uptime in the SLA, set up automated monitoring to track this metric and generate alerts when performance falls below the target.

Tip:
Regularly review and update performance metrics to reflect evolving business needs or emerging risks.

6.2 Regular Audits and Assessments

Audits and assessments are essential for verifying that suppliers are complying with contractual terms and maintaining the agreed level of information security. Regular evaluations help you stay proactive and uncover issues before they escalate.

  • Internal and External Audits:

    • Conduct internal audits of supplier-related activities within your organization to ensure compliance with policies and procedures.
    • Request independent audit reports from suppliers, such as SOC 2 or ISO 27001 certifications, to gain external validation of their practices.

  • Frequency of Assessments:

    • Perform routine audits based on risk levels—high-risk suppliers may require quarterly audits, while low-risk suppliers can be reviewed annually.
    • Schedule ad hoc assessments in response to major incidents, changes in supplier services, or newly identified risks.

Example in Practice:
Your supplier provides a SOC 2 Type II audit report demonstrating compliance with security controls. Follow up by reviewing the report’s findings and asking for remediation plans for any identified weaknesses.

Tip:
Involve cross-functional teams—such as IT, legal, and compliance—in the audit process to ensure comprehensive evaluations.

6.3 Maintaining Open Communication Channels with Suppliers

Clear, consistent communication is the bedrock of strong supplier relationships. Open communication channels enable better collaboration, quicker issue resolution, and mutual understanding of expectations.

  • Establish Communication Protocols:

    • Define how and when suppliers should report incidents, changes, or updates.
    • Use structured formats, such as progress reports, meeting agendas, or incident summaries, to streamline discussions.

  • Regular Progress Meetings:

    • Schedule regular meetings (e.g., monthly or quarterly) to discuss supplier performance, address concerns, and review upcoming changes.
    • Use these sessions to align on long-term goals and identify opportunities for improvement.

  • Encourage Transparency:

    • Create an environment where suppliers feel comfortable sharing potential risks or challenges. Collaborative problem-solving benefits both parties.

Example:
During a routine meeting, your supplier informs you about planned updates to their security infrastructure. This transparency allows your organization to assess and prepare for any potential impacts.

Tip:
Document all communication with suppliers to maintain a record of discussions, decisions, and follow-ups.

7. Change Management in Supplier Services

Change carries potential risks to service delivery and information security.

7.1 Developing Processes to Manage Changes in Supplier Services

A structured change management process is essential for proactively addressing changes while minimizing disruptions and vulnerabilities.

  • Key Steps in Change Management:

    1. Change Notification: Require suppliers to notify your organization in advance of any planned changes that could affect service delivery or security. Include this requirement in contracts and SLAs.
    2. Risk Assessment: Evaluate the potential impact of the change on your organization. Identify new vulnerabilities, compliance risks, or operational challenges.
    3. Approval Process: Establish a formal process to review and approve significant changes. This ensures that your organization has control over modifications that might affect critical systems or data.
    4. Implementation Monitoring: Work closely with suppliers during the implementation phase to monitor the change’s execution and address any unforeseen issues.
    5. Post-Implementation Review: Once the change is implemented, review its outcomes to confirm that it meets expectations and doesn’t introduce new risks.

Example:
A supplier updates its encryption algorithms to align with the latest standards. Your organization conducts a risk assessment to ensure compatibility with existing systems and verifies the change through testing.

7.2 Ensuring Changes Do Not Adversely Affect Service Delivery or Information Security

While change often brings improvements, it can also lead to unintended consequences if not managed carefully. To protect service delivery and security, organizations must take a proactive and thorough approach.

  • Addressing Common Risks:

    • Service Disruptions: Changes to networks, infrastructure, or applications can cause downtime if not properly planned and tested.
    • Introduction of Vulnerabilities: New tools or software updates may unintentionally introduce security weaknesses.
    • Compliance Gaps: Regulatory requirements or contractual obligations may be overlooked during the change process.

  • Mitigation Strategies:

    • Testing and Validation: Before changes go live, require suppliers to perform rigorous testing to identify and resolve potential issues.
    • Contingency Planning: Ensure suppliers have fallback plans in place to revert changes in case of failure.
    • Documentation Updates: Confirm that all associated documentation, such as policies, procedures, and security configurations, is updated to reflect the change.

Example in Practice:
A supplier migrates its data storage to a new cloud provider. Your organization works with the supplier to verify that the new provider meets security and compliance standards before approving the migration.

7.3 Key Areas of Change to Monitor

Some types of changes are more likely to impact security and service delivery. Be particularly vigilant about:

  1. Enhancements to Existing Services: New features or capabilities added to existing offerings.
  2. Adoption of New Technologies: Changes to platforms, tools, or infrastructure.
  3. Updates to Policies and Procedures: Revisions to supplier security controls or operational practices.
  4. Subcontracting Arrangements: Introduction of new sub-suppliers or outsourcing agreements.
  5. Changes in Physical Facilities: Relocation of data centers or other critical infrastructure.

Tip:
Include these specific types of changes in your contracts and SLAs, requiring suppliers to notify and obtain approval before proceeding.

7.4 Building a Resilient Change Management Framework

An effective change management framework aligns supplier changes with your organization’s goals, risk tolerance, and compliance requirements. Here’s how to build one:

  1. Clear Communication Channels: Maintain open lines of communication with suppliers to discuss upcoming changes and their implications.
  2. Regular Training: Ensure your teams understand the change management process and are equipped to evaluate supplier changes effectively.
  3. Collaboration Tools: Use tools like shared dashboards or project management platforms to track change requests, progress, and approvals.
  4. Continuous Improvement: Use lessons learned from previous changes to refine your processes and improve future outcomes.

8. Integration with Existing Practices

Aligning supplier monitoring and change management with existing policies and frameworks, you can create a cohesive system that strengthens your overall security posture while ensuring seamless operations.

8.1 Aligning Supplier Service Management with Overall Information Security Policies

Your organization’s information security policies serve as the foundation for all security-related activities, including supplier management. Integrating supplier service management into these policies ensures consistency, accountability, and alignment across the board.

  • Key Integration Points:
    1. Supplier Security Requirements: Ensure that the security requirements outlined in supplier agreements reflect your organization’s broader policies. This includes data encryption standards, access controls, and incident response protocols.
    2. Incident Management Alignment: Incorporate supplier-related incidents into your existing incident management framework. For example, if a supplier experiences a breach, your organization’s response should align with established protocols for containment, communication, and resolution.
    3. Training and Awareness: Include supplier management practices in your organization’s security training programs. This ensures that employees understand how supplier services fit into the larger security landscape.

Example in Practice:
If your organization requires multi-factor authentication (MFA) for all access points, ensure this policy extends to systems managed by suppliers. Regularly review supplier compliance with this requirement.

  • Tip:
    Regularly update your information security policies to incorporate lessons learned from supplier-related risks or incidents.

8.2 Incorporating Supplier Monitoring into the Organization’s Risk Management Framework

Effective supplier service management requires proactive risk identification, assessment, and mitigation. Integrating supplier monitoring into your risk management framework ensures that supplier-related risks are addressed systematically and prioritized alongside other organizational risks.

  • Steps to Incorporate Supplier Risks:
    1. Identify Supplier Risks: Add supplier-specific risks, such as service disruptions or security vulnerabilities, to your organization’s risk register.
    2. Assess Risk Levels: Evaluate the likelihood and impact of these risks. High-risk suppliers, such as those handling sensitive data or critical systems, should receive more frequent assessments and monitoring.
    3. Develop Mitigation Plans: For each identified risk, create a plan that includes preventive measures (e.g., audits, performance monitoring) and response strategies (e.g., backup suppliers, incident escalation processes).

Example:
A supplier providing cloud hosting services introduces a new subcontractor. Your risk management team evaluates the subcontractor’s security practices and adjusts monitoring efforts to address potential vulnerabilities.

  • Tip:
    Use a standardized risk assessment tool to evaluate suppliers consistently and ensure that all identified risks are logged and addressed.

8.3 Benefits of Integration

Aligning supplier service management with existing policies and frameworks delivers several key benefits:

  1. Consistency: Ensures that supplier-related activities align with your organization’s overall security and operational standards.
  2. Efficiency: Streamlines processes by leveraging existing frameworks, reducing duplication of effort.
  3. Visibility: Provides a clearer picture of how supplier risks interact with other organizational risks, enabling better decision-making.
  4. Resilience: Enhances your organization’s ability to adapt to changes or disruptions in the supply chain without compromising security.

8.4 Building a Unified Approach

To achieve seamless integration, consider these best practices:

  • Create a Centralized System: Use a unified platform or dashboard to track supplier performance, risk levels, and compliance status alongside internal security metrics.
  • Collaborate Across Departments: Engage procurement, IT, legal, and compliance teams to ensure that supplier management efforts align with organizational goals.
  • Set Clear Reporting Structures: Define how supplier-related updates, incidents, and risks should be reported within your organization and to senior leadership.

Example:
Your procurement team negotiates a new supplier contract. They collaborate with the IT and security teams to ensure the agreement includes requirements for compliance with your information security policies and risk management practices.

For a structured and effective approach to evaluating supplier risks, consider using tools like our Procurement Supplier Risk Assessment Template. This resource helps streamline the risk assessment process, ensuring all relevant factors are evaluated before entering into a supplier agreement.

9. Leveraging ISO/IEC 27036-3

Supplier relationships are complex and layered, often involving subcontractors, third-party providers, and intricate dependencies. To address these challenges effectively, ISO/IEC 27036-3 provides a comprehensive framework for managing information security in supplier relationships. 

9.1 What is ISO/IEC 27036-3?

ISO/IEC 27036-3 is part of the broader ISO/IEC 27036 standard series, which focuses on information security in supplier relationships. Specifically, Part 3 offers detailed guidance on:

  • Conducting risk assessments for supplier relationships.
  • Establishing and enforcing security requirements in supplier agreements.
  • Monitoring supplier compliance with security obligations.
  • Responding to and recovering from security incidents involving suppliers.

This standard is especially useful for organizations implementing ISO 27001 Control 5.22, as it expands on practical approaches to managing supplier services.

9.2 How ISO/IEC 27036-3 Supports Supplier Relationship Management

ISO/IEC 27036-3 provides actionable insights and methodologies to enhance your supplier management efforts. Here’s how it can help:

9.2.1 Risk Assessment for Supplier Relationships

Understanding and addressing risks is central to supplier management. ISO/IEC 27036-3 offers a structured approach to identifying, evaluating, and mitigating risks associated with supplier services.

  • Steps for Risk Assessment:
    1. Identify critical services or products provided by suppliers.
    2. Assess the security practices of suppliers and their subcontractors.
    3. Evaluate potential impacts of supplier disruptions, breaches, or failures.

Example:
If your organization relies on a supplier for payment processing, a risk assessment might reveal vulnerabilities in their encryption practices. This insight allows you to enforce stricter security requirements.

Tip:
Use a supplier risk matrix to prioritize risks based on their likelihood and impact, ensuring that high-risk suppliers receive greater attention.

9.2.2 Defining and Enforcing Security Requirements

ISO/IEC 27036-3 emphasizes the importance of setting clear, enforceable security requirements in supplier agreements. This ensures that suppliers align with your organization’s security standards.

  • Best Practices:
    • Specify security controls, such as data encryption, access management, and incident reporting, in contracts and SLAs.
    • Include clauses requiring suppliers to extend these controls to their subcontractors.
    • Mandate regular reporting on compliance with security requirements.

Example:
For a cloud provider, your agreement might include requirements for SOC 2 compliance, regular vulnerability assessments, and encryption of data at rest and in transit.

9.2.3 Monitoring Supplier Compliance

Ongoing monitoring is essential to ensure that suppliers continue to meet security and performance expectations. ISO/IEC 27036-3 provides guidelines for effective supplier oversight.

  • Key Monitoring Activities:
    • Review audit reports and service performance metrics.
    • Conduct periodic assessments to verify compliance with security requirements.
    • Use automated tools to track supplier activities, such as access logs or incident reports.

Pro Tip:
Establish KPIs for supplier compliance and include them in regular progress meetings to maintain accountability.

9.2.4 Incident Management and Recovery

When a supplier experiences a security incident, your organization’s ability to respond effectively depends on pre-established processes. ISO/IEC 27036-3 outlines how to prepare for and manage such events.

  • Steps for Incident Management:
    1. Define roles and responsibilities for incident response across your organization and the supplier.
    2. Require immediate notification of incidents that affect your data or services.
    3. Collaborate with the supplier to contain the incident, assess its impact, and implement corrective actions.

Example in Practice:
If a supplier’s system is compromised in a ransomware attack, their notification should trigger your organization’s incident response plan, including data backups, service continuity measures, and communication with stakeholders.

9.3 Leveraging ISO/IEC 27036-3 for Maximum Impact

To fully benefit from ISO/IEC 27036-3, integrate its guidance into your existing supplier management processes. Here’s how:

  1. Align with ISO 27001: Use ISO/IEC 27036-3 as a detailed supplement to ISO 27001 Control 5.22, providing actionable steps for implementation.
  2. Tailor to Your Needs: Customize the standard’s recommendations based on your organization’s size, industry, and specific supplier relationships.
  3. Educate Your Team: Train your procurement, IT, and security teams on the principles of ISO/IEC 27036-3 to ensure consistent application.

Tip:
Create a supplier management checklist based on ISO/IEC 27036-3 to guide your team through key activities, from risk assessment to incident management.

10. Conclusion

The role of suppliers in modern business operations is undeniable—they enable critical functions, provide essential services, and support organizational growth. However, with this reliance comes shared responsibility, particularly when it comes to information security. 

Here’s a quick recap of its significance and how it works:

  • Maintaining Security Standards: Regular monitoring ensures that suppliers comply with agreed-upon security and service-level requirements, reducing vulnerabilities and ensuring operational continuity.
  • Managing Changes Effectively: By tracking updates to supplier services, technologies, and policies, organizations can proactively address risks associated with modifications or new implementations.
  • Fostering Accountability: Clear communication, performance metrics, and regular audits hold suppliers accountable, strengthening trust and transparency.
  • Supporting Incident Response: Collaborating with suppliers during security incidents ensures a swift and coordinated response, minimizing potential damage.
  • Enhancing Resilience: Robust service continuity plans and proactive risk management create a stronger, more adaptable supply chain.