As part of my GRC studies with Inegben Academy, I'm applying the OCEG Red Book framework to real-world challenges.
1. Third Party Risk Management TPRM
Why this topic? It's one of the hottest, most tangible, and highest-impact areas in modern GRC. It sits at the intersection of cybersecurity, compliance, operational resilience, and reputation. The OCEG "Red Book" (GRC Capability Model) addresses this under components like "Manage Risk" (PRC Module) and "Objectively Verify & Review" (VV Module) concerning vendor assurance.
2. GRC Work Environment Project: "Implementing a Risk-Based Tiered Approach to Vendor Due Diligence"
This isn't just a policy document; it's an operational project.
Project Objectives:
Categorize Vendors: Develop a methodology to tier all third parties (Tier 1 - Critical/High Risk, Tier 2 - Medium, Tier 3 - Low). Criteria include: data access, financial impact, integration with core systems, and regulatory alignment.
Define Due Diligence Controls: Map specific controls to each tier.
Tier 1 (Critical): Comprehensive security questionnaire (e.g., SIG Lite), SOC 2 Type II review, contractually mandated right-to-audit clauses, continuous monitoring (financial health, cyber threats).
Tier 2 (Medium): Standard security questionnaire, review of relevant certifications, annual reassessment.
Tier 3 (Low): Basic business verification and contract terms.
Develop a Workflow: Create a process in the GRC tool (or even SharePoint/Teams initially) for Procurement, IT, and Compliance to trigger and complete due diligence.
Establish Ongoing Monitoring: Define how vendors are monitored post-onboarding (e.g., news alerts for breaches, annual financial checks, certificate renewals).
Create Exit/Offboarding Procedures: Ensure data destruction and access revocation when contracts end.
Deliverables:
TPRM Policy Document.
Vendor Tiering Methodology & Questionnaire Library.
Process Workflow Diagram & RACI Matrix.
Management Dashboard (showing % of vendors by tier, % with completed diligence, high-risk vendors pending action).
3. Case Study: The SolarWinds Sunburst Cyberattack (2020)
This is a perfect, high-profile case study for TPRM failure.
What Happened: Russian state-sponsored hackers compromised the software build system of SolarWinds, a major IT management vendor. They inserted a backdoor ("Sunburst") into a legitimate software update. This update was then downloaded by ~18,000 SolarWinds customers, including the U.S. Departments of Treasury, Commerce, Homeland Security, and major tech firms like Microsoft and FireEye.
The TPRM Failure Link:
Over-Reliance on a Single Vendor: Many organizations treated SolarWinds as a trusted vendor without applying sufficient "critical vendor" scrutiny.
Lack of Deep Supply Chain Due Diligence: Due diligence often stops at the direct vendor. This attack exploited the "vendor's vendor" risk—the security of SolarWinds' own development environment.
Insufficient Continuous Monitoring: Few customers were monitoring SolarWinds for signs of a compromise in their development or update distribution systems.
Consequence: It wasn't a breach of their own systems directly, but a breach via a trusted third party, leading to catastrophic espionage.
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