Certified Information Security Manager (CISM)Information Security Risk ManagementMedium

An organization relies heavily on a third-party cloud provider for its critical data storage and processing. During a recent audit, it was discovered that the cloud provider's incident response plan does not explicitly address data breach notification requirements specific to the organization's industry (healthcare). Which of the following is the MOST critical action for the information security manager to take?

  1. ANegotiate an amendment to the Service Level Agreement (SLA) to include specific notification requirements.
  2. BIncrease internal monitoring of data stored with the cloud provider.
  3. CRequest a copy of the cloud provider's complete incident response plan for review.
  4. DDevelop an internal incident response plan for data breaches occurring at the cloud provider.
Show answer & explanation

Correct answer: A. Negotiate an amendment to the Service Level Agreement (SLA) to include specific notification requirements.

The core issue is a gap in the contractual agreement (SLA) that defines the responsibilities and obligations of the cloud provider regarding specific regulatory requirements. Negotiating an amendment ensures the provider is contractually bound to meet these critical notification requirements.

Why the other options are wrong

  • B. Increased monitoring is a reactive measure and doesn't solve the fundamental issue of the provider's contractual obligations.
  • C. Reviewing the plan is good, but it doesn't solve the contractual gap for specific industry requirements.
  • D. An internal plan is important but cannot enforce the third party's actions or legal obligations.

Third-Party Risk Management

The process of identifying, assessing, and mitigating risks associated with external vendors, suppliers, and partners.

  • Requires due diligence and continuous monitoring.
  • Contractual agreements (SLAs) are crucial.
  • Risks can include data breaches, service disruptions, and compliance failures.

Memory trick: When working with partners, treat their risks like yours; contractually bind them to your standards.

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