Healthcare providers are aware that they need to manage third-party risk by drawing up, signing, and implementing a HIPAA compliant business associate agreement (BAA) with vendors. However, organizations of every industry should note that third-party vendors like suppliers can gravely jeopardize the data security of their organization, and of customers/clients as they form a critical part of business operations.
Understand the Kinds of Risk Involved
The issue is complicated as the risks pose compliance issues, strategic risk, threat to your organization’s reputation, have financial implications (fines for HIPAA violations can be very steep), and above all, could cause potential erosion of customer base as a fallout of a ransomware attack or breach. Note that regulatory authorities like the Consumer Finance Protection Bureau (CFPB) make not only their vendors and suppliers, but financial institutions (FIs) also liable for predatory behavior like deceptive selling. The risks increase proportionately with the complexity of the relationship with your third-party vendor.
Keep All Threat Vectors Secure
It is up to you to ensure you have a service-level agreement (SLA) in place with each of your business associates, vendors, and anyone else who might have access to sensitive data, or can log in to your servers. The SLA should clearly state the legal obligations regarding security, confidentiality, use, and ownership of every kind of data that might be accessed. It also requires that you have a comprehensive and enforceable security plan. This would entail drawing an inclusive list of the kinds of risks third parties could expose your organization to.
Do this: Identify all sensitive data, and where it is stored using an internal audit to set up protection to prevent a hacker getting through via third-parties, especially those who provide critical software. Keep a contingency plan ready in case your organization or third-party vendor gets hit by a ransomware attack or a breach to prevent all operations coming to a grinding halt.
Takeaways
- Third-party vendors like suppliers can gravely jeopardize the data security of their organization, and of customers/clients as they form a critical part of business operations.
- These data security risks pose compliance issues, strategic risk, and threats to your organization’s reputation, have financial implications, and could cause potential erosion of customer base as a fallout of a ransomware attack or breach.
- The risks increase proportionately with the complexity of the relationship with your third-party vendor.
- Keep a contingency plan ready in case your organization or third-party vendor gets hit by a ransomware attack or a breach.
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About the Author
Harini is one of the principal auditors for Frigg Business Solutions. She is an accomplished information security expert who led critical security initiatives that shielded multinational corporations from cyber-attacks, thwarted data breaches, and secured critical infrastructure.
Harini has successfully implemented the Health Information Trust Alliance – (HITRUST) common security framework and ensured 100% compliance in all these organizations. She is a Certified Risk Professional (CRiSP), Information Security Lead Auditor, HITRUST Implementor, HIPAA Compliance Expert, and Certified in Six Sigma (Black belt & Green belt).
