TPM-02: Vendor Compliance Remediation

Control Description

Vendors that are determined to not be in compliance with the Company's security procedures are notified of their violation and are issued a remediation plan. Vendors that fail to remediate any compliance violations related to security are terminated.

Plain Meaning

This control requires organizations to have a formal process for handling vendor compliance violations. When vendors don't follow security procedures, they must be notified, given a plan to fix the issues, and terminated if they fail to comply.

Implementation

Compliance Management Process

Violation Identification

• Regular monitoring of vendor compliance with security procedures
• Clear criteria for identifying compliance violations
• Documentation of all identified violations
• Assessment of violation severity and impact
• Immediate notification when violations are discovered

Remediation Process

• Violation Notification: Formal notification to vendor of compliance issues
• Remediation Plan: Detailed plan with specific actions and timelines
• Progress Monitoring: Regular check-ins on remediation progress
• Verification: Confirmation that issues have been resolved
• Escalation: Process for escalating unresolved issues

Implementation Approach

Compliance Monitoring

• Regular Reviews: Quarterly reviews of vendor compliance
• Security Assessments: Periodic security assessments of vendors
• Performance Monitoring: Ongoing monitoring of vendor security performance
• Incident Tracking: Track security incidents involving vendors
• Documentation: Maintain records of all compliance activities

Simple Implementation Steps

1. Define Security Procedures: Document security requirements for vendors
2. Establish Monitoring: Set up processes to monitor vendor compliance
3. Create Notification Process: Develop formal violation notification procedures
4. Define Remediation Process: Create standardized remediation plan template
5. Set Termination Criteria: Define when vendor termination is required
6. Train Staff: Educate team on compliance management procedures

Remediation Plan Components

• Issue Description: Clear description of the compliance violation
• Required Actions: Specific steps vendor must take to remediate
• Timeline: Deadlines for completing remediation actions
• Success Criteria: How to verify remediation is complete
• Consequences: What happens if remediation fails

Key Success Factors

1. Clear Procedures: Well-defined compliance monitoring and remediation procedures
2. Timely Notification: Prompt notification of compliance violations
3. Effective Remediation: Comprehensive remediation plans with clear timelines
4. Consistent Enforcement: Consistent application of compliance requirements
5. Documentation: Complete records of all compliance activities

Common Pitfalls to Avoid

• Inconsistent Monitoring: Not regularly monitoring vendor compliance
• Vague Notifications: Unclear or incomplete violation notifications
• No Follow-up: Not tracking remediation progress
• Weak Enforcement: Not terminating vendors who fail to remediate

Related Controls

• TPM-01: Third-party communication protocols
• TPM-03: Annual third-party risk assessment
• TPM-04: Standard vendor agreements

Related Links

Vendor Management

• Vendor Risk Management
• Compliance Monitoring
• Vendor Security