LEADx Risk Management Program Policies and Procedures

Risk Management is the systematic process of identifying, analyzing, and responding to project risks. It includes maximizing the probability and consequences of positive events and minimizing the probability and consequences of adverse events to project objectives. A risk management plan defines how a project team will handle risks to achieve that goal.

A risk is an uncertain event or condition that, if it occurs, has a positive or negative effect on a project’s objectives. Risk is often a measure of the inability to achieve overall project objectives within defined project requirements and constraints and has three components: (1) the probability of occurrence, (2) the impact of the risk on the program, and (3) the time horizon during which the consequences will occur if the risk is not mitigated.

The risk score is a value calculated that is the product of the probability of occurrence and impact. You use the score to compare risks as part of the risk prioritization process. You will generate a matrix used to develop the risk score. The values range from 1 (very low exposure) to 50 (very high exposure). Although there are no specific breakpoints in the risk exposure ranking, those risks with an exposure value of less than 20 are generally considered low risks, those risks with an exposure value between 20 and 39 are generally considered moderate risks, and those risks with an exposure value between 40 and 50 are generally considered high risks.

Risk Classification Scheme

Risk Classification Description Additional Information
Level 1 Critical Vendors Vendors that provide products/services that support core business functions (i.e. loan processing).
Level 2 High Risk Vendors
Level 3 Medium Risk Vendors
Level 4 Low Risk Vendors

Assessment Types with Triggers

Assessment Types Description Assessment Criteria
Information Security Assesses the vendor's or third-party’s controls regarding the protection of data. The information security review may include understanding the access controls, network management, systems and application development, information security policies and procedures, physical and environmental security and other aspect of information security. The purpose is to ensure that the vendor has adequate controls in place to protect your company data from unauthorized access, use, disclosure, disruption, modification, inspection, recording or destruction. All vendors with a data classification of non-public, confidential, highly confidential, PII and/or PHI and that will need to leave the organization’s network. If the data will not be accessed outside the organization’s network, then only certain aspects of an information security may apply
Privacy Assesses the vendor's and third-party’s controls regarding the protection of sensitive data such as Personal Identifiable Information (PII) or Personal Health Information (PHI). Many institutions such as financial firms and healthcare companies are subject to specific regulations that require that they protect specific consumer information (i.e. SSN, bank account number, biometric identifiers). Regulations may include Gramm-Leach Bliley Act (GLBA) for financial institutions or Health Insurance Portability and Accountability (HIPAA) for health care companies. The purpose of a privacy risk assessment is to ensure that the vendor's controls are adequate to protect any PII or PHI and ensure compliance with regulations such as GLBA and/or HIPAA. Data Classification: PII of PHI
Financial Assesses the vendor’s and third-party’s financial health to ensure that the vendor is financially strong enough to stay in business and meet their contractual obligations to the organization. A financial risk assessment may include analyzing the vendor’s financial statements using fundamental analysis and assigning a residual risk score based on a residual risk scoring scheme. All vendors within the VRM program or utilize a risk-based approach (i.e tier 1, 2 and 3 vendors or only tier 1 and 2 vendors). The VRM program is responsible for establishing the criteria that determines whether a financial risk assessment is necessary.
Reputation Assesses whether the firm has a positive reputation. The purpose is to ensure that the vendor does not undermine your company's brand. A reputation risk assessment may include analyzing news events regarding a company and assigning a residual risk score. All vendors within the VRM program or utilize a risk-based approach (i.e tier 1, 2 and 3 vendors or only tier 1 and 2 vendors). The VRM program is responsible for establishing the criteria that determines whether a reputation risk assessment is necessary.
Compliance Assesses whether the vendor or third-party has adequate program to ensure compliance with applicable regulations and industry standards. It also ensures that the vendor does not have a past history of violating regulations and industry standards. A compliance risk assessment may include an Anti-Money Laundering/ OFAC scan. All vendors within the VRM program or utilize a risk-based approach (i.e tier 1, 2 and 3 vendors or only tier 1 and 2 vendors). The VRM program is responsible for establishing the criteria that determines whether a compliance risk assessment is necessary.
Business Continuity Assesses whether the vendor or third-party has adequate controls in place to ensure that an organization can continue to operate in case of serious incidents or disasters and is able to recover to an operational state within a specific time frame as required by contractually agreed-upon the Service Level Agreements (SLAs). For example, the contract may require the vendor or third-party to be operational within 24, 48, 72 or more hours after a business disruption. As a general rule, the lower the recovery time, the higher the criticality of the services involved. All vendors within the VRM program where they need to be fully operational within 24-72 hours after a business disruption. The VRM program along with the business continuity subject-matter expert/risk assessor are responsible for establishing the criteria that determines whether a business continuity assessment is necessary. A business continuity assessment may include determining if the vendor has a business continuity plan that is tested, updated, and reviewed at least annually by the appropriate parties.
Disaster Recovery Assesses whether the firm has adequate controls to recover key technological infrastructure in the event of a natural or other disaster (i.e. earthquake or nuclear bombing). Depending on your perspective, disaster recovery could be viewed as a subset of business continuity as a disaster could lead to a business disruption that affects the operations of an organization. There are many organizations where the business continuity and disaster recovery are combined into one assessment. All vendors within the VRM program where they need to be fully operational within 24-72 hours after a disaster where non-public information is involved. The VRM program along with the business continuity and/or disaster recovery subjectmatter expert/risk assessor are responsible for establishing the criteria that determines whether a disaster recovery assessment is necessary. A disaster recovery assessment may include determining if the vendor has a disaster recovery plan that is tested, updated, and reviewed at least annually by the appropriate parties.

 

 

 

 

 

Date Last Revised: 5/1/2020
Date Established: 5/1/2020
Revision History: