A Guide to Sharing Sensitive Data with Third Parties
Third-Party Data Sharing
Your vendors and partners are key to helping your organization keep pace with digital transformation, increase efficiencies, and stay one step ahead of the competition. But your organization’s vendor ecosystem is also a complex and interconnected supply chain. It’s likely you deal with dozens if not hundreds of vendors, many of whom handle sensitive data.
Sensitive data sharing is an unavoidable risk that must be managed. That’s because malicious attackers tend to look for the weakest link in an organization’s security posture – which often resides in its supply chain. As such, it’s critical that your company has full visibility into the cybersecurity health of each vendor’s entire network of digital assets, remote access points, and cloud providers.
As you develop and refine your third-party risk management program, consider the following do’s and don’ts for sharing sensitive data.
Sensitive Data Sharing: "To-Do" List
1. Understand the value of your data prior to allowing a third-party to access it.
Being able to differentiate data that is highly sensitive from data that is only moderately sensitive is an important step. To help you determine the sensitivity of your organization’s data, here are 5 Examples of Sensitive Data and How You Can Protect Each.
2. Only share the minimum information your vendors need.
If, for example, your vendor will be monitoring your HVAC system remotely, you must ensure they only have access to the part of your network that controls your HVAC and nothing more. The key is to limit your exposure as much as possible.
3. Tier your vendors based on how closely they work with sensitive data.
Instead of assessing all vendors in the same way, tier your vendors based on how closely they work with company data. Prioritize those in the top tier (such as payroll vendors and cloud service providers) instead of wasting resources on lower-tier vendors that don’t have sensitive data sharing agreements with your business.
4. Create security expectations for your vendors.
These expectations shouldn’t be casually mentioned at the beginning of a business relationship, but rather cemented into your vendor contracts. Make these expectations legally airtight so your mind—and the minds of those in upper management—can rest at ease. For instance, Bitsight for Third-Party Risk Management—which relies on the Bitsight Security Ratings platform—allows you to set clearly defined baselines for acceptable risk. If a vendor’s security rating dips below an established threshold, you can reach out to the vendor, share Bitsight’s findings, and collaborate to mitigate cyber risk.
5. Establish an incident response plan.
Develop a procedure that requires your third parties to notify you in the event of a cybersecurity incident. Typically, this is a written procedure that is referenced in the contract outlining who the third-party must contact if a security breach occurs and when that communication will happen. But instead of reacting to such an incident, you can also get one step ahead of cyber risk in your supply chain by continuously monitoring the security posture of your vendors with Bitsight for Third-Party Risk Management. If a cyber incident occurs or a vulnerability is discovered that could lead to a data breach, you’ll get instant alerts. This allows for faster intervention, quicker risk reduction, and greater peace of mind. Continuous monitoring also limits risk exposure that can arise between traditional security audits and assessments that only provide a point-in-time snapshot of a vendor’s security profile.
Sensitive Data Sharing: What to Avoid
1. Don’t create a generic expectation for security.
You’ve probably heard of companies that require their vendors to provide an “adequate” level of security. This is not a good practice, because “adequate” can be interpreted many ways. To decrease your organization’s chances of third-party security issues, be clear about your expectations. Ideally, you should cite an industry standard like ISO27001, NIST800-53, or the PCI data security standards.
You can also back up your expectations with security ratings. For example, Bitsight Security Ratings, which range from 250 to 900, can be used to baseline acceptable risk for your industry. Simply select your industry to learn the average security rating your organization (and its third parties) should strive to attain and continuously monitor and measure your vendors against that goal.
2. Don’t allow third parties to access your data without doing proper assessments.
Stop risk before it enters your supply chain. Complement your onboarding security questionnaires and assessments with Bitsight for Third-Party Risk Management. You’ll gain unparalleled visibility into a vendor’s historical and current cybersecurity performance so that you can determine if a vendor requires more diligent assessment during the onboarding process or more frequent audits during the contract term.
3. Don’t let everyone in the third-party organization—or your organization—have access to your data.
This is a simple, yet important concept. Your organization should establish which individuals at a vendor have access to your data. Consider putting controls in place to help guard entry to your data so it isn’t easily accessible. Privileged information should only be available for a select few individuals who need access for a very good reason.
4. Don’t allow third-party users to access your data using unapproved devices.
Establish ground rules and controls that ensure that anyone who has access to sensitive information must use their work-approved computers on approved networks.
5. Don’t provide vendors with more information about proprietary products than they need.
Let’s say your organization is designing a smartphone and you decide to work with a vendor who can supply you with specialized screens. That vendor does not need access to all your sensitive phone design information and data—they just need the specifications that will help them successfully create the phone screen.
As part of the discussion around sharing sensitive data with vendors, it's essential to address compliance and cross-border data sharing challenges:
Compliance with Data Protection Regulations
Organizations must ensure that vendor data-sharing practices comply with global regulations like GDPR and CCPA. Vendors handling personal data may be considered "data processors" under these laws, requiring specific safeguards, including robust data transfer mechanisms, clear data protection clauses in contracts, and vendor audits. Violations can lead to significant fines, so aligning with these regulatory frameworks is crucial.
Cross-Border Data Sharing
Sharing data with vendors across different jurisdictions presents additional complexities, especially regarding data sovereignty and privacy laws. Organizations need to assess how vendor locations impact their ability to comply with regional data regulations. Utilizing standard contractual clauses (SCCs) and conducting data protection impact assessments (DPIAs) can help mitigate risks associated with cross-border data transfers.
For more detailed guidance on GDPR compliance for vendor management, see this resource.
Better Evaluate Risk Across Your Vendor Lifecycle
Sensitive data sharing is fraught with risk, but by following these best practices your organization can ensure it has the appropriate checks and balances in place to minimize supply chain threats – using your existing resources. Plus, with the insights that Bitsight delivers, you can more effectively reveal, remediate, and monitor supply chain risk across your vendor lifecycle.
To help you get started, request your personalized and actionable Vendor Risk Overview Report and get the insight you need to make confident, data-driven decisions and prioritize efficient third-party risk reduction.
