Maintaining a compliant third-party risk management (TPRM) program involves active collaboration between multiple stakeholders. Compliance isn’t just an objective but a shared responsibility throughout your organization, from senior management and the board of directors to the business lines and vendor owners. Vendors themselves also have a responsibility to comply with TPRM policies and regulations, so it’s crucial to develop a strategy that involves effective collaboration.
In this blog, you’ll learn some tips on collaborating with your vendors to achieve compliance in your TPRM program. You’ll also learn some next steps to take when a vendor is creating challenges in your compliance efforts.
How to Achieve Third-Party Risk Management Compliance Through Vendor Collaboration
TPRM program compliance involves more than just reacting to specific laws and regulations. It's about being proactive and considering internal policies, rules, and industry best practices that are designed to maintain effective TPRM programs. Below are some proactive strategies to collaborate with your vendor and achieve TPRM program compliance across multiple expectations and standards:
Set a culture of compliance – In order to effectively set expectations for your vendors' compliance, it’s advisable to first establish your organization's values and practices for your TPRM program. Organizations should communicate priorities internally to foster a culture of compliance that’s clearly understood and endorsed by all stakeholders. Once this culture has been established, it can be more effectively conveyed to your vendors, leading to smoother collaboration and program compliance.
Follow up on due diligence – Compliance issues are usually identified during the due diligence process as you collect and review the vendor's documentation. Follow up on any issues that were found and ask for clarification or more information as needed. In some cases, the vendor may have additional documentation that can verify its compliance with your expectations.
Negotiate a compliant contract – Make sure to include contract provisions that require both parties to comply with applicable laws and regulations. These provisions could relate to areas such as data protection, privacy, and breach notification requirements. Contract provisions could also outline any internal compliance requirements set by your organization, such as following your corporate policies or industry standards.
Communicate early and often – Don’t assume that your vendor is staying updated on changing regulatory expectations and industry standards. New state privacy laws continue to emerge, and cybersecurity standards are revised to address new vulnerabilities, so it's essential to frequently communicate your expectations to ensure the vendor is aware of relevant changes and is updating their processes as needed. This ongoing communication is key to building a collaborative partnership.
Work together on remediation – Just like compliance should involve vendor collaboration, so should remediation plans. Whenever there are issues with compliance, work with the vendor to develop a remediation plan that’s actionable, effective, and time bound. Vendors may be more responsive to requests for improvement if they collaborate on the remediation plan and can identify any roadblocks to success.
Addressing Challenges With Vendor Compliance
It’s not uncommon to face compliance challenges with vendors who might have different strategic goals and priorities. Some vendors may choose to do the bare minimum in compliance and only meet applicable laws and regulations. Here are some suggestions for handling a vendor that isn’t collaborative in your compliance efforts:
Talk with the vendor – First, sit down and have a conversation with the vendor about any issues to better understand their perspective. There may be a misunderstanding about a certain requirement, or they may not have the resources to meet your expectations. These conversations can help clarify your compliance goals and determine if you and the vendor can work toward an improvement plan.
Document issues and progress – Make sure to document any compliance issues and improvement plans, along with a time frame for remediation. It’s important to track any progress made on the compliance issue and regularly follow up with the vendor for updates until the issue is resolved.
Increase monitoring – In addition to documenting the compliance issue, you may need to increase your ongoing monitoring activities with the vendor. Depending on the issue, this may include more frequent reviews of the vendor’s financial health, business continuity risk, security testing, or negative news.
Move forward with the exit strategy – If the vendor isn’t following the requirements to an extent that’s too severe and beyond your risk tolerance, you may need to think about ending the relationship. Evaluate your plan for ending the relationship and start talking to the right people to make sure your organization can end the vendor relationship securely. Following through with your plan to end the relationship might take more time and resources, but it could be a worthwhile effort to keep your TPRM program in compliance.
Collaborating with your vendors through due diligence, careful contract negotiations, and remediation plans can be an effective strategy for TPRM program compliance. When you build a culture of compliance that extends to your vendors, your organization’s TPRM program can achieve many benefits, such as satisfying regulators and following your internal standards.
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