Third-Party Information Security Risk Management Policy

Purpose

LEADx utilizes third-party products and services to support our mission and goals. Third-party relationships carry inherent and residual risks that must be considered as part of our due care and diligence. The Third-Party Information Security Risk Management Policy contains the requirements for how LEADx will conduct our third-party information security due diligence.

Audience

This policy applies to all individuals who engage with a third-party on behalf of LEADx.

Definitions

The following definitions apply only to aid the understanding of the reader of this policy:

• Employee – defined as a person who is a part-time or full-time hourly or salaried employee who is performing work for LEADx as an employee, and not an independent contractor. Sometimes referred to as a “W2 employee”.
• Third-party or 3^rd-party – any person or organization who provides a service or product to LEADx and is not an employee.
• Information Resources – any system involved in the creation, use, management, storage, and/or destruction of LEADx information and the information itself.
• Inherent information security risk – the information security risk related to the nature of the 3^rd-party relationship without accounting for any protections or controls. Inherent risk is sometimes referred to as “impact” and is used to classify third-party relationships as an indicator of what additional due diligence may be warranted.
• Residual information security risk – the information security risk remaining once all applicable protections and controls are accounted for.

Policy

The policy is organized into three sections; general, physical, and technical according to the precaution or requirement specified.

Assessments

• Every 3^rd-party granted access to LEADx Information Resources must sign the LEADx Third-Party Non-Disclosure Agreement and Business Associate Agreement (if applicable).
• All 3^rd-party relationships must be evaluated for inherent information security risk prior to any interaction with LEADx Information Resources.
• Criteria for inherent risk classifications must be established; “High”, “Medium”, and “Low”.
• All 3^rd-party relationships must be re-evaluated for inherent information security risk bi-annually and any time there is a material change in how LEADx utilizes the third-party product or service.
• 3^rd-party relationships with significant inherent risk (classified as “High” or “Medium”) must be evaluated for residual risk using questionnaires, publicly available information, and/or technical tools.
• Residual information security risk assessments must account for administrative, physical, and technical controls.
• Residual information security risk thresholds must be established for 3^rd-party relationships with significant inherent risk (classified as “High” or “Medium”).
• 3^rd-party relationships that do not meet established residual information security risk thresholds:
  • Must be terminated,
  • Must be formally approved by executive management following an established waiver process, and/or;
  • Changed in a manner that reduces inherent and/or residual information security risk to meet LEADx established thresholds.
• 3^rd-party relationships concerning industry and/or regulatory requirements (i.e. PCI-DSS, HIPAA, etc.) must be reviewed on no less frequent than an annual basis.

Management

• 3^rd-party agreements and contracts must specify:
  • The LEADx information the vendor should have access to,
  • How LEADx information is to be protected by the 3^rd-party,
  • How LEADx information is to be transferred between LEADx and the 3^rd-party,
  • Acceptable methods for the return, destruction or disposal of LEADx information in the 3^rd-party’s possession at the end of the relationship/contract,
  • Minimum information security requirements,
  • Information security incident response and notification requirements,
  • Right for LEADx to audit 3^rd-party information security protections and controls.
• If the 3^rd-party subcontracts part of the information and communication technology service provided to LEADx, the 3^rd-party is required to ensure appropriate information security practices are followed throughout the supply chain,
• The 3^rd-party must only use LEADx Information Resources for the purpose of the business agreement and/or contract,
• Work outside of defined parameters in the contract must be approved in writing by the appropriate LEADx point of contact.
• 3^rd-party performance must be reviewed annually to ensure compliance with agreed upon contracts and/or service level agreements (SLAs). In the event of non-compliance with contracts or SLAs regular meetings will be conducted until performance requirements are met.
• The 3^rd-party’s major IT work activities must be entered into or captured in a log:
  • Made available to LEADx IT management upon request, and
  • Must include events such as personnel changes, password changes, project milestones, deliverables, and arrival and departure times.
• Any other LEADx information acquired by the 3^rd-party during the contract cannot be used for the 3^rd-party’s own purposes or divulged to others.
• 3^rd-party personnel must report all security incidents directly to the appropriate LEADx IT personnel.
• LEADx IT will provide a technical point of contact for the 3^rd-party. The point of contact will work with the 3^rd-party to ensure compliance with this policy.
• 3^rd-parties must provide LEADx a list of key personnel working on the contract when requested.
• 3^rd-parties must provide LEADx with notification of key staff changes within 24 hours of change.
• Upon departure of a 3^rd-party employee from a contract, for any reason, the 3^rd-party will ensure all sensitive information is collected and returned to LEADx or destroyed within 24 hours.
• Upon termination of contract, 3^rd-parties must be reminded of confidentiality and non-disclosure requirements.
• Upon termination of contract or at the request of LEADx, the 3^rd-party must surrender all LEADx badges, access cards, equipment and supplies immediately.
• Any equipment and/or supplies to be retained by the 3^rd-party must be documented by authorized LEADx IT management.

Waivers

Waivers from certain and specific policy provisions may be sought following the LEADx Waiver Process. There are no exceptions to any provisions noted in this policy until and unless a waiver has been granted.

Enforcement

This Third-Party Information Security Risk Management Policy supplements and compliments all other related information security policies, it does not supersede any such policy or vice versa. Where there are any perceived or unintended conflicts between LEADx policies, they must be brought to the attention of LEADx for immediate reconciliation.

Personnel found to have violated any provision of this policy may be subject to sanctions up to and including removal of access rights, termination of employment, termination of contract(s), and/or related civil or criminal penalties.