history Last updated

Vendor assessment goes wrong in two directions: a 300-question form sent to a vendor selling a static website, or a rubber stamp for one processing customer records. Tier the assessment by data and access, and spend the effort where the exposure is.

When to use it

  • Before contracting any supplier that will hold company or customer data, connect to internal systems, or provide a service whose failure would be an incident.
  • On renewal, and whenever the vendor’s scope changes materially.
  • After a publicly disclosed breach at the vendor.

What it must answer

  • What data and access will this vendor have, and what happens if they are breached?
  • What assurance do they provide, and what did we actually verify rather than accept?
  • What do we require contractually?
  • What residual risk are we accepting, and who accepted it?

Template

Vendor Security Assessment: <Vendor> — <service>

FieldValue
Assessment date
Assessor
Business owner
Tier1 (critical) / 2 / 3 (low)
DecisionApprove / Approve with conditions / Reject

1. Service description

What they do for us, and what we could not do without them.

2. Data and access scope

Data categoryVolumeClassificationPersonal data?Purpose
Access grantedTypeJustification

3. Tiering

The criteria that put this vendor in its tier.

4. Assurance reviewed

EvidenceProvided?DateReviewed byNotes

5. Control assessment

DomainFindingRatingEvidence

6. Concentration and exit

Dependency, lock-in, exit plan, data return and deletion.

7. Contractual requirements

RequirementIn contract?Clause

8. Findings and conditions

#FindingSeverityRequired actionOwnerDue

9. Residual risk and decision

RiskRatingAccepted byDateReview date
  # Vendor Security Assessment: <Vendor> — <service>

| Field | Value |
|---|---|
| Assessment date | |
| Assessor | |
| Business owner | |
| Tier | 1 (critical) / 2 / 3 (low) |
| Decision | Approve / Approve with conditions / Reject |


## 1. Service description
What they do for us, and what we could not do without them.

## 2. Data and access scope
| Data category | Volume | Classification | Personal data? | Purpose |
|---|---|---|---|---|


| Access granted | Type | Justification |
|---|---|---|


## 3. Tiering
The criteria that put this vendor in its tier.

## 4. Assurance reviewed
| Evidence | Provided? | Date | Reviewed by | Notes |
|---|---|---|---|---|


## 5. Control assessment
| Domain | Finding | Rating | Evidence |
|---|---|---|---|


## 6. Concentration and exit
Dependency, lock-in, exit plan, data return and deletion.

## 7. Contractual requirements
| Requirement | In contract? | Clause |
|---|---|---|


## 8. Findings and conditions
| # | Finding | Severity | Required action | Owner | Due |
|---|---|---|---|---|---|


## 9. Residual risk and decision
| Risk | Rating | Accepted by | Date | Review date |
|---|---|---|---|---|
  

Worked example

Vendor Security Assessment: NorthPay — card payment processing

FieldValue
Assessment date2026-04-28
AssessorA. Berg (Security)
Business ownerM. Duarte (Finance)
Tier1 — critical
DecisionApprove with conditions

1. Service description

Processes all card payments for web and mobile. An outage stops revenue
immediately; a breach exposes cardholder data and triggers regulatory
notification. There is no manual fallback.

2. Data and access scope

Data categoryVolumeClassificationPersonal data?Purpose
Cardholder data (PAN, expiry)~2.1M transactions/yrRestrictedYesPayment authorisation
Customer name and billing address~2.1M/yrConfidentialYesFraud screening, AVS
Transaction metadata~2.1M/yrInternalIndirectlyReconciliation

Access granted: outbound API calls from our systems to theirs; a webhook
endpoint they call, restricted by mutual TLS and IP allow-list; no access to
our internal networks or data stores.

3. Tiering

Tier 1 on three independent criteria: processes restricted data at scale,
outage is immediately revenue-affecting, and there is no rapid alternative
provider.

4. Assurance reviewed

EvidenceProvided?DateReviewed byNotes
PCI DSS Attestation of Compliance (Level 1)Yes2026-02-14A. BergValid; scope covers the services we use. Verified against the card scheme’s public registry rather than accepting the PDF
SOC 2 Type IIYes2026-01-31A. BergTwo exceptions noted by the auditor: delayed access revocation and one incomplete change record. Both remediated per management response
Penetration test summaryYes2025-11A. BergSummary only, no findings detail. Requested full report — refused; standard for this vendor
ISO 27001 certificateYes2026-03A. BergVerified with the certification body
Business continuity planPartial2026-04A. BergSummary only. RTO stated as 4 hours; last exercise date not disclosed
Sub-processor listYes2026-04DPO7 sub-processors, 2 outside the EEA with standard contractual clauses in place

5. Control assessment

DomainFindingRatingEvidence
Access controlMFA enforced; privileged access reviewed quarterlySatisfactorySOC 2
EncryptionTLS 1.2+ in transit, AES-256 at rest, HSM-backed keysSatisfactoryPCI AoC
Incident response24/7 team; contractual notification within 24h of confirmed breachSatisfactoryContract + SOC 2
Change managementOne incomplete change record in the SOC 2 periodMinor concernSOC 2 exception 2
Business continuityRTO 4h claimed; no exercise evidence providedConcernGap
Sub-processor managementNotification of new sub-processors, but only 30 days’ notice with no right to objectConcernContract review

6. Concentration and exit

Single provider for all card traffic. Exit would take an estimated 6–9 months
based on the incoming migration, which is itself a 9-month project. Contract
requires data return in a documented format within 30 days of termination and
deletion within 90, with certification of deletion. Mitigation: we retain our
own transaction ledger independently, so exit does not depend on their export.

7. Contractual requirements

RequirementIn contract?Clause
Breach notification within 24hYes11.3
Right to audit or receive annual SOC 2Yes (report, not audit right)12.1
Sub-processor notificationYes, 30 days8.4
Right to object to a sub-processorNo—
Data return and certified deletionYes15.2
Liability cap12 months’ fees18.1 — below our EUR 5M standard for Tier 1

8. Findings and conditions

#FindingSeverityRequired actionOwnerDue
1No right to object to new sub-processorsMediumNegotiate an objection right with termination for causeM. DuarteBefore signature
2Liability cap below policy for Tier 1MediumEscalate to Legal; accept or negotiateM. DuarteBefore signature
3No BCP exercise evidenceMediumRequest the most recent exercise report annually; treat non-provision as a finding at renewalA. BergAnnually
4Pen test detail not disclosedLowAccept — consistent with the market; the PCI AoC provides independent coverageA. Berg—

9. Residual risk and decision

RiskRatingAccepted byDateReview date
Concentration: no rapid alternative providerHighExecutive Committee2026-05-062027-05
Liability cap below policyMediumCFO2026-05-06At renewal
Unverified BCP capabilityMediumCISO2026-05-062027-04

Approved with conditions 1 and 2 resolved before signature. Condition 1 was
agreed by the vendor on 2026-05-02 (60 days’ notice with an objection right);
condition 2 was accepted as-is by the CFO, with the concentration risk recorded
in the register as R-2026-008.

  # Vendor Security Assessment: NorthPay — card payment processing

| Field | Value |
|---|---|
| Assessment date | 2026-04-28 |
| Assessor | A. Berg (Security) |
| Business owner | M. Duarte (Finance) |
| Tier | 1 — critical |
| Decision | Approve with conditions |


## 1. Service description
Processes all card payments for web and mobile. An outage stops revenue
immediately; a breach exposes cardholder data and triggers regulatory
notification. There is no manual fallback.

## 2. Data and access scope
| Data category | Volume | Classification | Personal data? | Purpose |
|---|---|---|---|---|
| Cardholder data (PAN, expiry) | ~2.1M transactions/yr | Restricted | Yes | Payment authorisation |
| Customer name and billing address | ~2.1M/yr | Confidential | Yes | Fraud screening, AVS |
| Transaction metadata | ~2.1M/yr | Internal | Indirectly | Reconciliation |


Access granted: outbound API calls from our systems to theirs; a webhook
endpoint they call, restricted by mutual TLS and IP allow-list; no access to
our internal networks or data stores.

## 3. Tiering
Tier 1 on three independent criteria: processes restricted data at scale,
outage is immediately revenue-affecting, and there is no rapid alternative
provider.

## 4. Assurance reviewed
| Evidence | Provided? | Date | Reviewed by | Notes |
|---|---|---|---|---|
| PCI DSS Attestation of Compliance (Level 1) | Yes | 2026-02-14 | A. Berg | Valid; scope covers the services we use. Verified against the card scheme's public registry rather than accepting the PDF |
| SOC 2 Type II | Yes | 2026-01-31 | A. Berg | Two exceptions noted by the auditor: delayed access revocation and one incomplete change record. Both remediated per management response |
| Penetration test summary | Yes | 2025-11 | A. Berg | Summary only, no findings detail. Requested full report — refused; standard for this vendor |
| ISO 27001 certificate | Yes | 2026-03 | A. Berg | Verified with the certification body |
| Business continuity plan | Partial | 2026-04 | A. Berg | Summary only. RTO stated as 4 hours; last exercise date not disclosed |
| Sub-processor list | Yes | 2026-04 | DPO | 7 sub-processors, 2 outside the EEA with standard contractual clauses in place |


## 5. Control assessment
| Domain | Finding | Rating | Evidence |
|---|---|---|---|
| Access control | MFA enforced; privileged access reviewed quarterly | Satisfactory | SOC 2 |
| Encryption | TLS 1.2+ in transit, AES-256 at rest, HSM-backed keys | Satisfactory | PCI AoC |
| Incident response | 24/7 team; contractual notification within 24h of confirmed breach | Satisfactory | Contract + SOC 2 |
| Change management | One incomplete change record in the SOC 2 period | Minor concern | SOC 2 exception 2 |
| Business continuity | RTO 4h claimed; no exercise evidence provided | Concern | Gap |
| Sub-processor management | Notification of new sub-processors, but only 30 days' notice with no right to object | Concern | Contract review |


## 6. Concentration and exit
Single provider for all card traffic. Exit would take an estimated 6–9 months
based on the incoming migration, which is itself a 9-month project. Contract
requires data return in a documented format within 30 days of termination and
deletion within 90, with certification of deletion. Mitigation: we retain our
own transaction ledger independently, so exit does not depend on their export.

## 7. Contractual requirements
| Requirement | In contract? | Clause |
|---|---|---|
| Breach notification within 24h | Yes | 11.3 |
| Right to audit or receive annual SOC 2 | Yes (report, not audit right) | 12.1 |
| Sub-processor notification | Yes, 30 days | 8.4 |
| Right to object to a sub-processor | No | — |
| Data return and certified deletion | Yes | 15.2 |
| Liability cap | 12 months' fees | 18.1 — below our EUR 5M standard for Tier 1 |


## 8. Findings and conditions
| # | Finding | Severity | Required action | Owner | Due |
|---|---|---|---|---|---|
| 1 | No right to object to new sub-processors | Medium | Negotiate an objection right with termination for cause | M. Duarte | Before signature |
| 2 | Liability cap below policy for Tier 1 | Medium | Escalate to Legal; accept or negotiate | M. Duarte | Before signature |
| 3 | No BCP exercise evidence | Medium | Request the most recent exercise report annually; treat non-provision as a finding at renewal | A. Berg | Annually |
| 4 | Pen test detail not disclosed | Low | Accept — consistent with the market; the PCI AoC provides independent coverage | A. Berg | — |


## 9. Residual risk and decision
| Risk | Rating | Accepted by | Date | Review date |
|---|---|---|---|---|
| Concentration: no rapid alternative provider | High | Executive Committee | 2026-05-06 | 2027-05 |
| Liability cap below policy | Medium | CFO | 2026-05-06 | At renewal |
| Unverified BCP capability | Medium | CISO | 2026-05-06 | 2027-04 |


Approved with conditions 1 and 2 resolved before signature. Condition 1 was
agreed by the vendor on 2026-05-02 (60 days' notice with an objection right);
condition 2 was accepted as-is by the CFO, with the concentration risk recorded
in the register as R-2026-008.
  

Common mistakes

  • The same questionnaire for every vendor. Tier by data and access. Effort spent on a low-tier vendor is effort not spent on the one holding cardholder data.
  • Accepting certificates without verification. A PDF is not evidence. Check the certification body’s or scheme’s registry, and check that the scope covers the service you are buying.
  • Ignoring the auditor’s exceptions in a SOC 2. The exceptions section is the most informative part of the report and is routinely skipped.
  • No exit assessment. Concentration risk is usually the largest exposure, and it is invisible if you only assess controls.
  • Findings without contract dates. A finding that is not resolved before signature will not be resolved after it.
  • Assessed once, never again. Vendors change scope, get acquired and get breached. Reassess at renewal and on material change.

Last updated 23 Aug 2026, 18:09 -0500. history