Managing TPRM Programs in Changing Risk Landscapes

Third-Party Risk Management is nuts & out of control. Somewhere along the way, TPRM turned into a bureaucratic sport where we measure effort instead of risk reduction. 300-question spreadsheets. Endless “follow-ups.” Security teams playing document collector. Most orgs are pretending to “manage” vendor risk when they’re really just manufacturing paperwork. You do NOT have the leverage to run your vendors’ security programs. You do NOT have the resources to deeply assess a bunch of SaaS providers. And you definitely do NOT need a Big 4 inspired monstrosity to manage practical risk. From a CISO perspective, here’s a simplified TPRM model that actually works for most of us... Step 1: Classify Every Vendor Into 3 Tiers ->High Vendor has external (remote) access into your environment (Small number & might be zero.) ->Medium Vendor stores, processes, or transmits your sensitive data or your customers’ sensitive data (PII, etc) ->Low Everyone else (This is most likely 50% + of your vendor base.) Step 2: Set Clear, Non Negotiable Expectations ->High & Medium Vendors -Must provide a recognized audit report (SOC 2, ISO 27001, etc.) -Must maintain it throughout the contract -If handling customer data, sign a DPA or equivalent ->High Vendors (with access to your environment) -Must agree to follow your security policies while operating in your environment -Least privilege. Logged access. No exceptions. ->Low Vendors -Ask for audit reports. -If they can provide one, awesome, they’re more attractive commercially. -If not, confirm they don’t handle sensitive data or have access, contractually limit what they can receive, control exposure by only sharing what’s necessary, document the low-risk classification, and move on...low risk should mean low friction, not a 300 question spreadsheet. Step 3: Shrink the Legal Theater Your security addendum should focus on what actually matters: -Ongoing audit reporting -Data retention -Incident notification -Flow-down requirements to sub-processors Not 14 pages of fantasy control over systems you don’t run. Here’s the part security teams don’t like admitting: You can't manage your vendors’ security programs. At best, you can: Choose mature partners. Contractually require transparency. Enforce boundaries where they touch your environment or your data. Everything else is illusion. When you simplify TPRM: -Procurement moves faster. -Business partners stop avoiding security. -Your team focuses on real risk. -And when you need political capital for something that actually matters, you have it. Mature CISOs know the difference between control and control theater. For most SMB companies, a disciplined 3-tier model & mandatory assurance for real risk exposure is adult supervision, and adult supervision scales. #ciso #vciso #TPRM #security

Questionnaire ≠ Risk Management Completing the questionnaire is not risk management. Even with increasing TPRM maturity, we still see teams treating vendor questionnaires like closure. A questionnaire is where one begins. We can argue that most vendors don’t lie. But they do misunderstand questions, describe aspiration as reality, or answer based on what they think are the ‘right’ responses. We regularly see “financially stable” vendors with clear red flags in public filings. A questionnaire captures what a vendor says, however, risk management is about verifying what’s true. When a vendor relationship is critical, compliance professionals must seek evidence instead of just relying on what the vendor has filled in - these could be: A) Evidence over declaration– looking for BCP test results and not just a checkbox or even policy B) Independent due diligence – SOC reports, financial ratings, regulatory filings, audits’ results C) Direct validation -site visits, financial analysis, operational reviews D) Ongoing monitoring - M&A, leadership churn, market stress, service expansion can all change the risk profile. Questionnaires still matter. They’re efficient for triage and low-risk vendors. But if critical decisions rely only on self-reported answers, a risk program is only acting till the time the illusion of control continues. The real question always is what residual risk an organization is comfortable with? #ThirdPartyRisk #TPRM #RiskManagement #VendorRisk #EnterpriseRisk Maneesha Garg Umme Haani

Third-party risk isn’t just a compliance checkbox is where real breaches happen. Most third-party breaches come from vendors you thought were secure. A mature Third-Party Risk Management (TPRM) program helps you manage what you don’t control. Imagine your HR team wants to onboard a new employee wellness platform. Here’s what happens in a mature organization: 1. Intake & Risk Tiering Before any demo happens: - Does it process health data? - What tools will it connect to? Result? Risk tier assigned immediately — low, medium, or high. 2. Security & Risk Assessment They pass the initial screen. Now we go deeper: - Vendor security questionnaire - SOC 2 review - Fourth-party discovery (who they rely on) Result?3 major red flags in data retention uncovered. 3. Contract & Control Alignment Before the contract is signed: - Add encryption requirements - Include right-to-audit clause - Mandate quarterly security reviews Result? A secure contract — not just a fast one. 4. Ongoing Monitoring After onboarding, the work doesn’t stop: - Track their security scores continuously - Monitor breach alerts and dark web activity - Set up annual reassessments Result? Caught a major acquisition event before it introduced new risk. 5. Offboarding Done Right When switching providers: - Verify full data deletion - Audit system access closure - Document lessons learned Result? No shadow access, no loose ends. Why this even matters? - 62% of breaches start with a third party (Ponemon) - Most companies are indirectly connected to 10,000+ fourth-party vendors - Manual reviews miss over 80% of vendor risk changes The 2025 TPRM Standard To stay ahead, organizations must: - Automate vendor screening at the intake stage - Integrate risk reviews into procurement workflows - Monitor vendors continuously — not once a year - Extend oversight to fourth parties - Keep audit-ready documentation at every stage TPRM is about saying “yes, but with safeguards.” #ThirdPartyRisk #VendorRisk #TPRM #GRC #RiskManagement

The biggest mistake a person in a key risk position can make? Acting like risk is a reporting function instead of a leadership function. I’ve seen this repeatedly across financial services, fintech, and large enterprises. A Chief Risk Officer. A Head of Third-Party Risk. A Director of Operational Risk. Technically strong. Deep regulatory knowledge. Well-structured frameworks. And yet the program fails. Why? Because risk was treated as a compliance checklist, not as a tone-setting force. Here’s the real mistake: Staying silent when leadership behavior contradicts stated values. When executives say: “We take resilience seriously.” But: - Critical vendors are onboarded under deadline pressure without proper due diligence - AI tools are deployed before risk review - Exceptions become permanent - Audit findings sit unresolved And the risk leader chooses not to challenge it. That silence becomes the real tone at the top. Not the policy. Not the code of conduct. Not the board slides. Behavior. Tone at the top is not a speech. It is what leaders tolerate. If a risk leader: - Softens language to avoid discomfort - Reframes serious issues as “minor observations” - Avoids escalation to preserve relationships - Prioritizes optics over exposure Then the organization learns one thing: Risk is negotiable. And once risk becomes negotiable, controls slowly erode. Research backs this up. Regulatory enforcement actions across the U.S., UK, and EU consistently point to: - Weak escalation culture - Lack of challenge - Risk functions overridden by commercial pressure - “Informal approvals” outside policy Rarely is the issuea lack of documentation. It is a lack of backbone. Especially in Third-Party Risk In TPRM, tone at the top determines: - Whether critical vendors are truly classified correctly - Whether business owners are held accountable - Whether joint BCP tests actually happen - Whether the AI vendor risk is assessed continuously If leadership treats vendor risk as procurement admin work, the program will remain shallow. If leadership treats vendor risk as enterprise exposure, the program becomes strategic. The uncomfortable truth A risk leader’s job is not to be popular. It is to: - Create constructive friction - Protect the institution from its own optimism - Escalate when needed - Document when overridden The biggest mistake in a key risk role is confusing diplomacy with silence. Strong tone at the top starts with a strong tone in the risk function. #RiskManagement #ToneAtTheTop #TPRM #OperationalResilience #3prm #Governance #ThirdPartyRisk #compliance #procurment #riskleadership

With layoffs, leadership changes, folks moving teams, it gets harder to know whose priorities matter, what direction is stable, and how long any decision will actually hold. As a program manager, you are right in the middle of that. You’re expected to drive outcomes across teams that don’t report to you, while the people who set direction might change. You feel like you are constantly re-establishing context, rebuilding trust, and explaining the program every few months. To keep sane, stay focused on the problem space and the business outcome. Leaders have different styles and priorities, but if you’re clear on what the program is solving and why it matters, and have established measurable success metrics, then you will then have a stable point of reference that remains consistent across leadership changes. Change is frustrating and inevitable. You have to accept that alignment in a matrix is temporary. It is not something you achieve once and move on. It is something you have to work to maintain. When leadership changes, automatically assume that context has to be rebuilt. Proactively reframe the program in terms that matter to the new leader and present it to get early feedback. This is how TPMs add value by buffering the impact to the teams while keeping things moving forward. When there is change, people gravitate toward whoever can make sense of what’s going on. A short one-pager that lays out goals, trade-offs, and risks is more useful than a status update. It will give new leaders a fast way to engage and give feedback. Program managers will have to make a judgement call around how much to absorb versus how much to push back. Not every new direction should be accepted at face value, but pushing back without context rarely works. You need to show you understand the new perspective, then explain the downstream impact of changing course. When you do that well, you are not seen as defensive/resistant, and instead viewed as someone protecting business outcomes. Accept that there will be rework and priorities will shift. Some decisions will get undone. You can’t measure your effectiveness purely by how much stays unchanged. A better yardstick is whether the program continues to move toward a meaningful outcome despite the churn. TPMs add value not just by driving execution, but providing continuity when the system itself keeps changing. If you are driving through change and finding it challenging, reach out for a mentoring 1on1. Talking through the situation with a seasoned leader who has weathered these situations and has lived experience will make a world of difference. 1on1:https://lnkd.in/gHgh8eCN #technicalprogrammanagement #projectmanagement #leadership

🚀 I have had two meetings in South Africa this week, and both conversations echoed the same Third-Party Risk Management struggles. 💡 The scale is mind-blowing — lots of third parties — and the complexity even more so. Vendors are suffering from questionnaire fatigue, hit by duplicate assessments from every direction. Platforms are over-customized. Risk intelligence is powerful but fragmented across silos — cyber, financial, sanctions, sustainability — each in its own world. 🌍 The call is clear: organizations want a unified third-party risk intelligence layer, where data connects, signals correlate, and AI helps reveal what humans can’t. They’re also under pressure to align TPRM with operational resilience, tracing dependencies from the first party all the way to the fourth. 💬 What’s starting to work: ✨ Shifting to an entity baseline + delta model — pre-filled questionnaires, suppliers only confirm changes. ✨ Enforcing intake governance to prevent duplicate outreach. ✨ Building a canonical data model across tools and intelligence feeds — with LLMs summarizing, scoring, and surfacing risk. ✨ Moving from tool-led to principle-led programs — strategy first, configuration second. 🔥 The next two years will be defining. Those who simplify, normalize, and orchestrate AI-driven TPRM will thrive. Those who keep layering complexity will drown in their own data. If your TPRM feels like “more touch, less truth,” you’re not alone. __________________ 🪐 As an industry analyst, I map and monitor the ever-expanding GRC galaxy — now tracking 1,500+ solutions and the professional services orbiting them . . . For those navigating this universe: 🔭 Reach out to GRC 20/20 Research, LLC for guidance on GRC solutions & strategy 📡 Follow GRC Report for ongoing insights and market trends 🎙️ Tune into my podcasts → Risk Is Our Business Podcast & Hitchhiker's Guide to the GRC Technology Galaxy Podcast #TPRM #GRC #OperationalResilience #ThirdPartyRisk #RiskManagement #DataStrategy

Red Team Your TPRM: Stop Trusting, Start Testing We red team networks, apps, even employees. But when’s the last time you red teamed your third-party risk program? Here’s what that could look like: Step 1: Identify the Crown Jewels Pick 1–3 critical vendors: - What systems rely on them? - What data flows through them? - Who in your org is operationally dependent on them? Step 2: Simulate a Vendor Failure Create a scenario: - The vendor goes dark — total comms outage. - Their system is breached and down. - Their SLA isn’t honored. Now… let it play out internally. Step 3: Watch the Fallout - Do people know who to call? - Are internal teams aligned on who owns the response? - Can you pivot to an alternate vendor or workaround? - Can your business generate revenue without this vendor? - What data was exposed or at risk? Step 4: Score the Readiness Grade your internal response: - Speed: How long did it take to respond? - Clarity: Was there confusion or finger-pointing? - Resilience: Did the business grind to a halt? Step 5: Refactor Your Playbook This is where the real value is: - Adjust your contingency plans. - Build backup workflows. - Refine your vendor tiering criteria. - Add real-world failure drills to your TPRM lifecycle. Red teaming your vendor ecosystem shows you where your assumptions live. It turns static assessments into living, operational risk intelligence.

Case Study: The Vanishing Risk Plan — Managing Contracts When the Rules Change Scenario: You’re Taylor, a project manager at a nonprofit leading a $2.5 million cross-sector initiative. The project is a partnership between a federal agency, two private companies, and your nonprofit to deliver sustainability training across three states. Contracts are signed, teams are aligned, and kickoff went smoothly. Then, surprise: The federal government releases a draft revision of Circular A-123—a key policy that used to require agencies to manage enterprise-wide risks through formal Enterprise Risk Management (ERM) programs. The new draft removes ERM requirements and folds risk back into internal controls. Your government partner pulls back on risk monitoring. The Chief Risk Officer is no longer involved. The once-regular risk reviews and cross-functional conversations disappear. Now, the contracts are your main defense—but they weren’t designed to carry that load alone. You discover: One vendor contract doesn’t include a backup if cybersecurity reviews get delayed. Your own organization’s contract lacks clear milestones for partner engagement. The original performance plan relied on shared risk assessments that are no longer happening. Your leadership team asks you to coordinate a plan to manage emerging risks, align with all partners, and keep the project moving forward under this new landscape. Discussion Questions: Rebuilding Trust and Alignment: How can Taylor re-engage partners now that the federal agency has pulled back from proactive risk leadership? Updating Contracts and Expectations: What steps should be taken to review and possibly update contracts or partner agreements to reflect the new reality? Preventing Silos and Surprises: Without ERM structures, what tools or routines can Taylor use to keep communication open and risks visible across all organizations? Planning Ahead Without a Net: How can Taylor anticipate future risks and plan proactively, especially when there’s no longer a centralized system guiding risk planning? Leading Through Policy Shifts: What leadership strategies can help a project manager stay flexible and effective when government rules change mid-project? Takeaway: Even when policy frameworks change, the need for clear communication, proactive planning, and shared accountability doesn’t. In fact, when risk management takes a backseat at the policy level, it’s often the project manager who has to take the wheel. #ProjectLeadership #ContractManagement #RiskManagement #CrossSectorProjects

What’s Reshaping Third-Party Risk Management? TPRM is no longer a box-ticking exercise—it's a strategic imperative. Here's how the landscape is evolving: ✅ AI is Reshaping TPRM: From predictive alerts to real-time dashboards, AI is now at the heart of how organizations detect, assess, and respond to third-party risks ✅ Beyond the Third Party: Organizations are now mapping fourth, fifth, and nth-party risks—recognizing that today’s vulnerabilities often hide deep in the supply chain. ✅ Operational Risk Takes the Lead: In 2025, 57% of organizations monitor operational risk as a priority—up from 40% in 2023. It’s now the #1 concern. ✅ Business Continuity Becomes a Dealbreaker: The weight of resilience in defining critical third parties rose from 14% to 23%. More companies are asking: Can our partners survive a disruption? ✅ Compliance Crackdowns Are Real: Escalation due to non-response jumped to 87%. Termination of non-compliant third parties nearly doubled to 29% The message is clear: The stakes are higher. The risks are deeper. And the tools are becoming smarter. #Ey #TPRM

Third-Party Risk Management (TPRM): It’s Not Optional — It’s Strategic In today’s interconnected economy, your business is only as secure, compliant, and resilient as your third parties. From IT vendors to legal advisors, cloud providers to supply chain partners — every third party carries inherent risk. That’s why organizations must go beyond contracts and build a mature, proactive Third-Party Risk Management (TPRM) program. ⸻ What Makes a TPRM Program Successful? 1. Clear Ownership & Governance Define roles across procurement, risk, compliance, and business units. Establish policies that cover onboarding to offboarding. 2. Robust Due Diligence & Risk Assessment Evaluate each vendor’s: • Financial health • Data security posture • Regulatory compliance • Operational resilience Use tiering models to scale your efforts. 3. Ongoing Monitoring Risk doesn’t stop after onboarding. Monitor vendor SLAs, incidents, performance, and compliance through periodic reviews. 4. Integrated Technology Leverage TPRM tools or platforms to: • Centralize vendor data • Automate workflows • Track documents & certifications • Generate real-time risk dashboards 5. Incident Response & Exit Planning Have contingency plans for vendor failure, breaches, or sudden exits. Continuity requires preparation. 6. Training & Awareness Educate internal stakeholders and third parties about: • Your risk appetite • Reporting channels • Expected behaviors ⸻ Remember: A third party is an extension of your business. Trust must be earned, verified, and continuously assessed. #TPRM #ThirdPartyRisk #VendorManagement #RiskGovernance #Compliance #DueDiligence #OperationalResilience #SupplyChainRisk #RiskManagement #CyberRisk #Governance #Procurement #SLAManagement