Shared Assessments CTPRP Dumps

Threat modeling is a core element of the Microsoft Security Development Lifecycle (SDL) and a structured approach to identify, quantify, and address the security risks associated with an application12. Threat modeling helps to shape the application’s design, meet the security objectives, and reduce risk1. The best time to perform threat modeling analysis is before the application design and development activities begin, as this allows the application service provider to:

• Communicate about the security design of their systems1.
• Analyze the design for potential security issues using a proven methodology1.
• Suggest and manage mitigations for security issues1.
• Incorporate security requirements into the design2.
• Avoid costly rework or redesign later in the SDLC2.
• Identify the most critical and relevant threats to focus on2. References: 1: Microsoft Security Development Lifecycle Threat Modelling1 2: Threat Modeling Process | OWASP Foundation2

Shadow IT refers to the use of IT systems, services, or devices that are not authorized, approved, or supported by the official IT department. Shadow IT can pose significant risks to an organization’s data security, compliance, performance, and reputation. One of the main risks of shadow IT is that it often lacks governance and security oversight. This means that the shadow IT functions may not follow the established policies, standards, and best practices for IT management, such as data protection, access control, encryption, backup, patching, auditing, and reporting. This can expose the organization to various threats, such as data breaches, cyberattacks, malware infections, legal liabilities, regulatory fines, and reputational damage. Additionally, shadow IT can create operational inefficiencies, compatibility issues, duplication of efforts, and increased costs for the organization.

According to the web search results from the search_web tool, shadow IT is a common and growing phenomenon in many organizations, especially with the proliferation of cloud-based services and applications. Some of the articles suggest the following best practices for managing and mitigating shadow IT risks123:

• Performing SaaS assessments to proactively detect shadow IT
• Prioritizing user experience (UX) and providing support for integrating tools
• Streamlining user account and identity management
• Using operating systems and devices with which employees are comfortable
• Compromising and collaborating with users to minimize shadow IT risks
• Educating and training users on the security risks and consequences of shadow IT
• Establishing clear policies and guidelines for IT procurement and usage
• Creating a culture of trust and transparency between IT and business units

Therefore, the verified answer to the question is B. “Shadow IT" functions often lack governance and security oversight.

References:

• Shadow IT Explained: Risks & Opportunities - BMC Software
• Start reducing your organization’s Shadow IT risk in 3 steps
• What is shadow IT? - Article | SailPoint

The purpose of internal communications and information sharing using TPRM performance metrics is to inform and align the organization’s stakeholders on the status, progress, and outcomes of the TPRM program. This includes communicating the results of vendor assessments, the compliance level of the organization’s policies and procedures, and the periodic reporting to management and other relevant parties. However, documenting the corrective action plan between external parties is not an internal communication, but rather an external one. This is because the corrective action plan is a formal agreement between the organization and the vendor to address and resolve the issues identified in the assessment. Therefore, this statement is not an example of the purpose of internal communications and information sharing using TPRM performance metrics. References:

• 15 KPIs & Metrics to Measure the Success of Your TPRM Program
• Third-party risk management metrics: Best practices to enhance your program
• 3 Best Third-Party Risk Management Software Solutions (2024)

A BCP or IT DR plan is a set of procedures and actions that an organization takes to ensure the continuity and recovery of its critical business functions and IT systems in the event of a disruption. A BCP or IT DR plan typically covers the following aspects12:

• Identification and prioritization of critical business functions and IT systems
• Assessment and mitigation of risks and threats to the organization
• Allocation and mobilization of resources and personnel
• Communication and coordination with internal and external stakeholders
• Testing and updating of the plan

Among the four examples of a response to external environmental factors, protocols for social media channels and PR communication are the least likely to be managed directly within the BCP or IT DR plan. This is because social media and PR communication are not critical business functions or IT systems that need to be restored or maintained during a disruption. They are rather supplementary tools that can be used to inform and engage with the public, customers, partners, and media about the organization’s situation and actions3. Therefore, protocols for social media and PR communication are more likely to be part of a crisis communication plan, which is a separate but related document that outlines the strategies and tactics for communicating with various audiences during a crisis.

The other three examples are more likely to be managed directly within the BCP or IT DR plan, as they directly affect the organization’s ability to perform its critical business functions and IT systems. For instance, a response to a natural or man-made disruption would involve activating the BCP or IT DR plan, assessing the impact and extent of the damage, deploying backup and recovery solutions, and restoring normal operations as soon as possible. A response to a dependency on key employee or supplier issues would involve identifying and managing the single points of failure, implementing contingency plans, and ensuring the availability and redundancy of essential skills and resources. A response to a large scale illness or health outbreak would involve implementing health and safety measures, enabling remote work arrangements, and ensuring the resilience and continuity of the workforce. References:

• Business continuity vs. disaster recovery: Which plan is right … - IBM
• Business Continuity vs Disaster Recovery: What’s The Difference?
• Disaster recovery plan vs. business continuity plan: Is there a difference?
• [Crisis Communication Plan: A PR Blue Print by Sandra K. Clawson Freeo]
• [Disaster Recovery Planning (DRP) | Business Continuity Plan (BCP) | Disaster Recovery Journal]
• [Managing Third Party Risk in a Disrupted World]
• [Business Continuity Planning for a Pandemic]

Vendor classification or risk tiering is a process of categorizing vendors based on the level of security risk they introduce to an organization12. It is a key component of a third-party risk management (TPRM) program, as it helps to prioritize and allocate resources for vendor assessment, monitoring, and remediation12. The statement D is true, as it reflects the first step of vendor classification or risk tiering, which is to determine the inherent risk of each vendor relationship based on the nature, scope, and complexity of the product or service being outsourced3 . Inherent risk is the risk that exists before any controls or mitigating factors are applied3 . By calculating the inherent risk, an organization can assign each vendor to a risk tier that reflects the potential impact and likelihood of a security breach or incident involving the vendor3 .

The other statements are false, as they do not accurately describe the vendor classification or risk tiering process. The statement A is false, as vendor classification and risk tiers are not based on residual risk calculations, but on inherent risk calculations. Residual risk is the risk that remains after controls or mitigating factors are applied3 . Residual risk is used to evaluate the effectiveness of the controls and the need for further action, but not to classify or tier vendors3 . The statement B is false, as vendor classification and risk tiering should be used for all third party relationships, not only for critical ones. Vendor classification and risk tiering helps to identify and prioritize the critical vendors, but also to manage the low and medium risk vendors according to their respective risk profiles12. The statement C is false, as vendor classification and corresponding risk tiers do not utilize the same due diligence standards for controls evaluation based upon policy, but different ones. Due diligence standards are the criteria and methods used to assess the security posture and performance of vendors. Due diligence standards should vary according to the risk tier of the vendor, as higher risk vendors require more rigorous and frequent evaluation than lower risk vendors.

References:

• 1: What is Vendor Tiering? Optimize Your Vendor Risk Management | UpGuard Blog
• 2: Vendor Tiering Best Practices: Categorizing Vendor Risks | UpGuard Blog
• 3: Third-Party Risk Management (TPRM): A Complete Guide - BlueVoyant
• [4]: Supplemental Examination Procedures for Risk Management of Third-Party Relationships
• [5]: Third Party Risk Management: Why It’s Important And What Features To Look For - Expert Insights

A mobile device policy is a set of rules and guidelines that define how an organization’s employees and contractors can use and secure their mobile devices, such as laptops, smartphones, and tablets, to access the organization’s data and network1. A mobile device policy typically covers aspects such as device configuration, authentication, encryption, backup, remote wipe, malware protection, acceptable use, and incident response23.

A mutual NDA is a legal agreement that binds both parties to protect the confidentiality of the information they share with each other. A mutual NDA is usually signed before engaging in a business relationship with a third party, such as a vendor, partner, or customer. A mutual NDA is not directly related to the use and security of mobile devices, and therefore is less likely to be included in an organization’s mobile device policy. A mutual NDA may be part of a broader contract or agreement with a third party, but it is not specific to mobile devices.

The other options are more likely to be included in an organization’s mobile device policy, as they address the risks and responsibilities associated with mobile devices. For example:

• Language on restricting the use of the mobile device to only business purposes can help prevent unauthorized access, data leakage, and malware infection from personal or untrusted applications or websites2.
• Language detailing the user’s responsibility to not bypass security settings or monitoring applications can help ensure compliance with the organization’s security standards and policies, and enable the detection and prevention of potential incidents2.
• Language detailing specific actions that an organization may take in the event of an information security incident can help define the roles and responsibilities of the users and the organization, and the procedures for reporting, investigating, and resolving incidents involving mobile devices23.

References:

• 1: Mobile Device Policy1, Section 1. Introduction
• 2: Risk Management Guidelines for Mobile Devices2, Section Data Security
• 3: Guidelines for Managing the Security of Mobile Devices in the Enterprise3, Section 4. Recommendations for Mobile Device Security
• [4]: What is a Mutual NDA?, Section What is a Mutual NDA?
• [5]: Non-Disclosure Agreement (NDA) Definition, Section Understanding Non-Disclosure Agreements

 Questionnaires are one of the most common and effective tools for conducting third party risk assessments. They help organizations gather information about the security and compliance practices of their vendors and service providers, as well as identify any gaps or weaknesses that may pose a risk to the organization. However, not all questionnaires are created equal. Depending on the nature and scope of the third party relationship, different types and levels of questions may be required to adequately assess the risk. Therefore, it is important to configure the assessment questionnaires based on the risk rating and type of service being evaluated12.

The risk rating of a third party is determined by various factors, such as the criticality of the service they provide, the sensitivity of the data they handle, the regulatory requirements they must comply with, and the potential impact of a breach or disruption on the organization. The higher the risk rating, the more detailed and comprehensive the questionnaire should be. For example, a high-risk third party that processes personal or financial data may require a questionnaire that covers multiple domains of security and privacy, such as data protection, encryption, access control, incident response, and audit. A low-risk third party that provides a non-critical service or does not handle sensitive data may require a questionnaire that covers only the basic security controls, such as firewall, antivirus, and password policy12.

The type of service that a third party provides also influences the configuration of the questionnaire. Different services may have different security and compliance standards and best practices that need to be addressed. For example, a third party that provides cloud-based services may require a questionnaire that covers topics such as cloud security architecture, data residency, service level agreements, and disaster recovery. A third party that provides software development services may require a questionnaire that covers topics such as software development life cycle, code review, testing, and vulnerability management12.

By configuring the assessment questionnaires based on the risk rating and type of service being evaluated, organizations can ensure that they ask the right questions to the right third parties, and obtain relevant and meaningful information to support their risk management decisions. Therefore, the statement that assessment questionnaires should be configured based on the risk rating and type of service being evaluated is TRUE12. References: 1: How to Use SIG Questionnaires for Better Third-Party Risk Management 2: Third-party risk assessment questionnaires - KPMG India

  Performance risk, defined as the risk that a third party may not be able to meet its obligations due to inadequate systems or processes, accurately describes the situation. This type of risk involves concerns about the third party's ability to deliver services or products at the required performance level, potentially due to limitations in their technology infrastructure, operational procedures, or management practices. Identifying and managing performance risk is essential in Third-Party Risk Management (TPRM) to ensure that third-party vendors can reliably meet contractual and service-level agreements, thereby minimizing the impact on the organization's operations and service delivery.

References:

• TPRM guidelines, such as those from the Office of the Comptroller of the Currency (OCC) and the Federal Financial Institutions Examination Council (FFIEC), highlight the importance of assessing and managing performance risks associated with third-party relationships.
• The "Third-Party Risk Management Guide" by ISACA discusses various types of risks, including performance risk, associated with engaging third-party service providers, emphasizing the need for thorough due diligence and ongoing monitoring.

According to the Shared Assessments Certified Third Party Risk Professional (CTPRP) Study Guide, the third party risk assessor’s role is to evaluate the design and operating effectiveness of the third party’s controls based on an industry framework, such as ISO, NIST, COBIT, or COSO1. The assessor’s role is not to provide an opinion on the effectiveness of controls, but rather to report the results of the evaluation in a factual and objective manner2. The assessor’s role is also to conduct discovery with subject matter experts to understand the control environment, to conduct discovery and validate responses from the risk assessment questionnaire by testing or validating controls, and to review compliance artifacts and identify potential control gaps based on evaluation of the presence of control attributes1. These are all true statements that describe the assessor’s role when conducting a controls evaluation using an industry framework.

References:

• 1: Shared Assessments Certified Third Party Risk Professional (CTPRP) Study Guide, page 29
• 2: What is a Third-Party Risk Assessment? — RiskOptics

A secure SDLC is a framework that integrates security best practices and standards throughout the software development life cycle, from planning to deployment and maintenance. A secure SDLC aims to ensure that security is considered and implemented at every stage of the development process, not just as an afterthought or a compliance check. A secure SDLC can help organizations to achieve the following benefits12:

• Reduce the risk of security breaches and incidents by identifying and mitigating vulnerabilities early and continuously
• Improve the quality and reliability of software products by ensuring that they meet both the functional and the security requirements
• Save time and money by avoiding costly rework, remediation, and reputation damage caused by security flaws
• Enhance customer trust and satisfaction by delivering secure and compliant software solutions
• Foster a culture of security awareness and responsibility among developers, testers, and other stakeholders References:
• Secure SDLC | Secure Software Development Life Cycle | Snyk
• What is Secure Software Development Life Cycle (SSDLC )? - GeeksforGeeks

The concept of least privilege is a security principle that requires giving each user, service, and application only the permissions needed to perform their work and no more12. It is one of the most important concepts in network and system security, as it reduces the attack surface and the risk of unauthorized access, data breaches, and malware infections12. The statement B best describes this concept, as it implies that the vendor follows the principle of least privilege by granting people access to the minimum necessary to do their job. The other statements do not capture the essence of the concept, as they either describe other security practices (such as dual authorization and separation of duties) or limit the scope of the concept to a specific type of access (such as root and administrator access).

References:

• 1: 9 Ways to Prevent Third-Party Data Breaches in 2024 | UpGuard
• 2: Best Practice Guide to Implementing the Least Privilege Principle - Netwrix

Shadow IT is the use and management of any IT technologies, solutions, services, projects, and infrastructure without formal approval and support of internal IT departments. Shadow IT can pose significant security risks to the organization, such as data breaches, compliance violations, malware infections, or network disruptions. Therefore, assessing and mitigating the risk of shadow IT is an essential part of organizational security.

One of the most important factors when assessing the risk of shadow IT is whether the organization maintains adequate policies and procedures that communicate required controls for security functions. Policies and procedures are the documents that define the organization’s security objectives, standards, roles, responsibilities, and processes. They provide guidance and direction for the organization’s security activities, such as risk assessment, vendor management, incident response, data protection, access control, etc. They also establish the expectations and requirements for the organization’s employees, vendors, and other stakeholders regarding the use and management of IT resources.

By maintaining adequate policies and procedures that communicate required controls for security functions, the organization can:

• Educate and inform its employees about the security risks and implications of shadow IT, and the benefits and advantages of using authorized and supported IT resources.
• Establish and enforce clear and consistent rules and boundaries for the use and management of IT resources, and the consequences and penalties for violating them.
• Monitor and audit the compliance and performance of its employees, vendors, and other stakeholders regarding the use and management of IT resources, and identify and address any deviations or issues.
• Review and update its policies and procedures regularly, and communicate any changes or updates to its employees, vendors, and other stakeholders.

By doing so, the organization can reduce the likelihood and impact of shadow IT, and increase the visibility and accountability of its IT environment. The organization can also foster a culture of security awareness and responsibility among its employees, vendors, and other stakeholders, and encourage them to report and resolve any shadow IT incidents or problems.

The other factors, such as the organization’s security training and certification, staffing levels, and resources and investment, are also relevant for assessing the risk of shadow IT, but they are not as important as the organization’s policies and procedures. Security training and certification can help the organization’s security personnel to acquire and maintain the necessary skills and knowledge to deal with shadow IT, but they do not address the root causes or motivations of shadow IT. Staffing levels can affect the organization’s ability to detect and respond to shadow IT, but they do not prevent or deter shadow IT from occurring. Resources and investment can enable the organization to provide adequate and appropriate IT resources to its employees, vendors, and other stakeholders, but they do not guarantee the satisfaction or compliance of those parties. References:

• : Shadow IT Explained: Risks & Opportunities - BMC Software
• : What is Shadow IT? | IBM
• : Shadow IT: What Are the Risks and How Can You Mitigate Them? - Ekran System
• : Policies and Procedures - Shared Assessments

 TPRM program metrics are the indicators that measure the performance, effectiveness, and maturity of the TPRM program. They help to monitor and communicate the progress, achievements, and challenges of the TPRM program to various stakeholders, such as business units, executive management, risk committees, and board of directors. However, the level of reporting and the frequency of changes in TPRM program metrics vary depending on the stakeholder’s role, responsibility, and interest123:

• Business unit: This level of reporting is focused on the operational aspects of the TPRM program, such as the status of vendor assessments, remediation actions, issues, and incidents. The changes in TPRM program metrics at this level are frequent and granular, as they reflect the day-to-day activities and outcomes of the TPRM program.
• Executive management: This level of reporting is focused on the strategic aspects of the TPRM program, such as the alignment with the business objectives, the compliance with the regulatory requirements, the management of the key risks, and the optimization of the resources and costs. The changes in TPRM program metrics at this level are less frequent and more aggregated, as they reflect the overall direction and performance of the TPRM program.
• Risk committee: This level of reporting is focused on the oversight aspects of the TPRM program, such as the evaluation of the risk appetite, the review of the risk profile, the approval of the risk policies, and the escalation of the risk issues. The changes in TPRM program metrics at this level are occasional and more analytical, as they reflect the governance and assurance of the TPRM program.
• Board of Directors: This level of reporting is focused on the advisory aspects of the TPRM program, such as the endorsement of the risk strategy, the awareness of the risk trends, the guidance of the risk culture, and the support of the risk initiatives. The changes in TPRM program metrics at this level are rare and exceptional, as they reflect the high-level and long-term vision and value of the TPRM program.

Therefore, the correct answer is D. Board of Directors, as this is the level of reporting where changes in TPRM program metrics are rare and exceptional. References:

• 1: 15 KPIs & Metrics to Measure the Success of Your TPRM Program | UpGuard
• 2: Third-party risk management metrics: Best practices to enhance your … | Diligent
• 3: TPRM Metrics - Telling Your Risk Story - Shared Assessments | Shared Assessments

A Business Impact Analysis (BIA) is a process of determining the criticality of business activities and associated resource requirements to ensure operational resilience and continuity of operations during and after a business disruption1. A BIA is used to identify the potential impacts of disruptions on business processes, such as lost sales, delayed revenue, increased expenses, regulatory fines, or contractual penalties2. A BIA is not concerned with the probability or causes of disruptions, but rather with the effects and consequences of disruptions3. Therefore, a BIA typically does not include requiring vendor participation in testing, as this is a part of the business continuity and disaster recovery planning and implementation, not the impact analysis. Vendor participation in testing is important to validate the effectiveness and alignment of the vendor’s business continuity and disaster recovery plans with the organization’s objectives and expectations, but it is not a component of the BIA itself. References: 1: Using Business Impact Analysis to Inform Risk Prioritization and Response 2: Business Impact Analysis (BIA): Prepare for Anything [2024] • Asana 3: The Difference Between a Vendor’s BIA and Risk Analysis - Venminder : Best Practices Guidance for Third Party Risk

 Risk culture is the term used to describe the collective way that an organization thinks about, manages, and responds to risk. It is influenced by the organization’s values, beliefs, norms, and practices, as well as the external environment and stakeholders. Risk culture affects how employees perceive, communicate, and act on risk issues, and how they balance risk and reward in their decision making. A strong risk culture is one that supports the organization’s strategic objectives, fosters accountability and transparency, and promotes learning and improvement. A weak risk culture is one that undermines the organization’s risk management framework, creates silos and conflicts, and exposes the organization to excessive or unnecessary risks. References:

• Shared Assessments CTPRP Study Guide, page 13, section 2.1.1
• GARP Best Practices Guidance for Third Party Risk, page 5, section 2.1
• Organizational culture | Definition, Benefits and Challenges

One of the key elements of a robust information security policy is the definition and implementation of requirements for third party governance and oversight. This means that the vendor should have clear and consistent processes and procedures for managing and monitoring the information security risks and controls of their subcontractors, suppliers, or service providers. Third party governance and oversight should include the following aspects12:

• Establishing criteria and standards for selecting and evaluating third parties based on their information security capabilities and performance
• Conducting regular and comprehensive assessments and audits of third parties’ information security policies, practices, and incidents
• Ensuring contractual agreements and service level agreements (SLAs) with third parties include information security clauses and obligations
• Maintaining visibility and communication with third parties regarding their information security status and issues
• Implementing corrective actions and remediation plans for any identified information security gaps or weaknesses
• Terminating or suspending the relationship with third parties that fail to meet the information security expectations or requirements If a vendor’s response does not specify any requirements for third party governance and oversight, it should trigger further investigation of their information security policies. This indicates that the vendor may not have a comprehensive and effective approach to managing the information security risks and impacts of their extended network of partners. This could expose the vendor and their clients to potential data breaches, cyberattacks, compliance violations, or reputational damages. Therefore, the vendor should be asked to provide more details and evidence of how they ensure the information security of their third parties, and how they address any information security incidents or issues involving their third parties. References:
• 1: Third-Party Information Security Risk Management Policy - SecurityStudio
• 2: Ensuring Data Protection for Third Parties: Best Practices | UpGuard Blog

A network access policy is a set of rules and conditions that define how authorized users and devices can access the network resources and services of an organization. It typically includes the following elements12:

• Firewall settings: These are the rules that control the incoming and outgoing network traffic based on the source, destination, protocol, and port of the packets. Firewall settings help to protect the network from unauthorized or malicious access, and to enforce the network security policy of the organization.
• Unauthorized device detection: This is the process of identifying and preventing unauthorized devices from accessing the network. Unauthorized devices can pose a security risk to the network, as they may not comply with the security standards and policies of the organization, or they may be compromised by malware or hackers. Unauthorized device detection can be done by using various methods, such as network access control (NAC), network admission control (NAC), or 802.1X authentication.
• Remote access: This is the ability of authorized users to access the network resources and services of the organization from a remote location, such as a home office, a hotel, or a public hotspot. Remote access can be provided by using various technologies, such as virtual private networks (VPNs), remote desktop services (RDS), or remote access services (RAS). Remote access requires a secure and reliable connection, and it must comply with the network access policy of the organization.
• Website privacy consent banners: These are the messages that appear on websites to inform the visitors about the use of cookies and other tracking technologies, and to obtain their consent for such use. Website privacy consent banners are part of the website privacy policy, which is a legal document that discloses how the website collects, uses, and protects the personal data of the visitors. Website privacy consent banners are not related to the network access policy of the organization, as they do not affect how the users and devices can access the network resources and services of the organization.

Therefore, the correct answer is C. Website privacy consent banners, as they are typically not included within the scope of an organization’s network access policy. References:

• 1: Network Policy Server (NPS) | Microsoft Learn
• 2: Network Access Policy | University Policies

While whistleblower compliance issue reporting mechanisms are important for ensuring ethical conduct and accountability within an organization, they are not directly related to the security and privacy awareness of the service provider’s employees and contractors. The other topics are more relevant for assessing the service provider’s ability to protect the organization’s sensitive data and systems from external and internal threats, such as phishing, social engineering, unauthorized access, data breaches, etc. Therefore, B is the least important topic when evaluating a service provider’s Security and Privacy Awareness Program. References:

• Shared Assessments CTPRP Study Guide, page 43, section 4.2.3: Security and Privacy Awareness Program
• Third-Party Security: 8 Steps To Assessing Risks And Protecting Your Ecosystem, step 4: Evaluate the vendor’s security awareness and training program
• What Is Third-Party Risk Management, section: How to Implement a Third-Party Risk Management Program, bullet point: Security and privacy awareness training

External continuous monitoring solutions are tools or services that provide objective and timely data on the cybersecurity posture and performance of third-party vendors. They typically include components such as:

• Status updates on localized events based on geolocation, which can alert the organization to potential disruptions or incidents affecting the vendor’s operations or infrastructure in a specific region or country12.
• Alerts on legal and regulatory actions involving the vendor, which can indicate the vendor’s compliance status, reputation, or liability exposure13.
• Reports that identify changes in vendor financial viability, which can signal the vendor’s ability to sustain its business operations, invest in security, or honor its contractual obligations14.

However, metrics that track SLAs for performance management are not typically included in external continuous monitoring solutions, as they are more relevant for internal monitoring and reporting. SLAs are service level agreements that define the expected quality, availability, and reliability of the vendor’s services or products, as well as the penalties or remedies for non-compliance. SLAs are usually measured and reported by the vendor itself, or by a third-party auditor or assessor, based on the specific criteria and frequency agreed upon by the parties . Therefore, option C is the correct answer. References:

• Third Party Risk Management Framework, Module 5: Program Implementation, Section 5.2: Ongoing Monitoring, p. 32
• Bitsight Continuous Monitoring, Section: Uncover hidden risks
• Best-Practices Guidance for Third-Party Risk, Section: Monitor Third-Party Compliance with Regulations and Standards, p. 3
• Five Best Practices to Manage and Control Third-Party Risk, Section: Monitor Third-Party Financial Health, p. 4
• [Third Party Risk Management Framework], Module 4: Program Components, Section 4.3: Contracting, p. 24
• [A Better Way to Manage Third-Party Risk], Section: Establish clear service level agreements (SLAs) and key performance indicators (KPIs), p. 2

Hybrid cloud is the cloud deployment model that is primarily used for load balancing. Load balancing is the process of distributing workloads and network traffic across multiple servers or resources to optimize performance, reliability, and scalability1. Load balancing can help prevent overloading or underutilizing any single server or resource, as well as improve fault tolerance and availability. Hybrid cloud is a mix of two or more different deployment models, such as public cloud, private cloud, or community cloud2. Hybrid cloud allows organizations to leverage the benefits of both public and private clouds, such as cost efficiency, scalability, security, and control3. Hybrid cloud can also enable load balancing across different cloud environments, depending on the demand, cost, and performance requirements of each workload. For example, an organization can use a private cloud for sensitive or mission-critical applications that require high security and performance, and a public cloud for less sensitive or variable applications that require more scalability and flexibility. By using a hybrid cloud, the organization can balance the load between the private and public clouds, and optimize the resource utilization and cost efficiency of each cloud.

The other cloud deployment models are not primarily used for load balancing, although they may have some load balancing capabilities within their own environments. Public cloud is the infrastructure that is shared by multiple tenants and open to the public. Anyone can use the public cloud by subscribing to it. Public cloud offers high scalability, elasticity, and cost-effectiveness, but may have lower security, privacy, and control than private cloud2. Community cloud is the infrastructure that is shared by similar consumers who collaborate to set up a cloud for their exclusive use. For example, government organizations can form a cloud for their exclusive use. Community cloud offers some benefits of both public and private clouds, such as shared costs, common standards, and enhanced security, but may have lower scalability and flexibility than public cloud2. Private cloud is the infrastructure that is for the exclusive use of a single organization. The cloud may or may not be operated by the organization. Private cloud offers high security, privacy, and control, but may have lower scalability, elasticity, and cost-effectiveness than public cloud2. References:

• 1: What is Load Balancing? | How Load Balancing Works | F5
• 2: The NIST Definition of Cloud Computing
• 3: What is Hybrid Cloud? | IBM
• : Hybrid Cloud Load Balancing - Kemp Technologies
• : [Hybrid Cloud Load Balancing: What You Need to Know - CloudHealth by VMware]

Change management is the process of controlling and documenting any changes to the scope, objectives, requirements, deliverables, or resources of a project or a program. Change management ensures that the impact of any change is assessed and communicated to all stakeholders, and that the changes are implemented in a controlled and coordinated manner. Compliance artifacts are the documents, records, or reports that demonstrate the adherence to the change management process and the regulatory or industry standards.

A robust change management process should include the following attributes:

• Logging: This means that any change request or proposal is recorded in a change log or a change register, along with the details of the change initiator, the change description, the change category, the change priority, the change status, and the change history. Logging helps to track and monitor the progress and outcome of each change, and to provide an audit trail for compliance purposes.
• Approvals: This means that any change request or proposal is reviewed and approved by the appropriate authority or stakeholder, such as the project manager, the sponsor, the customer, the steering committee, or the regulatory body. Approvals help to ensure that the change is justified, feasible, aligned with the project or program objectives, and acceptable to the affected parties.
• Validation: This means that any change request or proposal is verified and tested to ensure that it meets the quality standards, the functional and non-functional requirements, and the expected benefits and outcomes. Validation helps to ensure that the change is implemented correctly, effectively, and efficiently, and that it does not introduce any errors, defects, or risks.
• Back-out and exception procedures: This means that any change request or proposal has a contingency plan or a rollback plan in case the change fails, causes problems, or is rejected. Back-out and exception procedures help to minimize the negative impact of the change, and to restore the original state or the baseline of the project or program. They also help to handle any deviations or issues that may arise during the change implementation or the change review.

References:

• CTPRP Job Guide
• An Agile Approach to Change Management
• CM Overview
• Management Artifacts and its Types
• Achieving Regulatory and Industry Standards Compliance with the Scaled Agile Framework
• 8 Steps for an Effective Change Management Process

In the context of Third-Party Risk Management (TPRM) requirements within the Software Development Life Cycle (SDLC), a process for data destruction and disposal is not typically considered a key component. The primary focus within SDLC in TPRM is on ensuring secure software development practices, which includes maintaining artifacts to prove that SDLC gates are executed, conducting software security testing, and having processes in place for fixing security defects. While data destruction and disposal are important security considerations, they are generally associated with data lifecycle management and information security management practices rather than being integral to the SDLC process itself.

References:

• Best practices in secure software development, as outlined in frameworks like the Secure Software Development Framework (SSDF) by NIST, emphasize the importance of secure coding, vulnerability testing, and remediation processes rather than data disposal practices.
• The "Software Security Framework (SSF)" by the Open Web Application Security Project (OWASP) provides guidance on integrating security practices into the SDLC, focusing on areas like threat modeling, secure coding, and security testing.

This statement is false because assessing risk impact does not require an analysis of prior events, frequency of occurrence, and external trends. These factors are relevant for assessing risk likelihood or probability, not impact. Risk impact is the potential consequence or damage that a risk event may cause to the organization or its stakeholders. Risk impact can be measured qualitatively (e.g., high, medium, low) or quantitatively (e.g., monetary value, percentage of revenue, number of customers affected). To assess risk impact, the organization needs to consider the nature and scope of the risk, the potential harm or loss, and the sensitivity or tolerance of the organization or its stakeholders to the risk. References:

• How to Manage and Measure Third-Party Risk, OneTrust Blog
• Third-party risk, Deloitte
• Assessing Risks in Third Parties, ERM - Enterprise Risk Management Initiative

TPRM compliance requirements are the rules and expectations that an organization must follow when engaging with third parties, such as vendors, suppliers, partners, or contractors. These requirements are derived from various sources, such as laws, regulations, standards, frameworks, contracts, policies, and best practices. However, relying solely on regulatory mandates to define and structure TPRM compliance requirements is a false statement, because123:

• Regulatory mandates are not the only source of TPRM compliance requirements. Organizations may also need to consider other factors, such as industry benchmarks, customer expectations, stakeholder interests, ethical principles, and social responsibility.
• Regulatory mandates are not always comprehensive, clear, or consistent. Organizations may face different or conflicting regulations across jurisdictions, sectors, or domains. Organizations may also need to interpret and apply the regulations to their specific context and risk profile, which may require additional guidance or expertise.
• Regulatory mandates are not always sufficient, effective, or efficient. Organizations may need to go beyond the minimum requirements of the regulations to achieve their business objectives, mitigate their risks, or enhance their performance. Organizations may also need to adopt more flexible, scalable, and innovative approaches to TPRM compliance, rather than following a rigid, one-size-fits-all, or check-the-box model.

Therefore, the correct answer is B. Organizations rely on regulatory mandates to define and structure TPRM compliance requirements, as this is a false statement regarding the risk factors an organization may include when defining TPRM compliance requirements. References:

• 1: Understanding TPRM Compliance: A Comprehensive Guide | Prevalent
• 2: What Is Third-Party Risk Management (TPRM)? 2024 Guide | UpGuard
• 3: Third-Party Risk Management and ISO Requirements for 2022 | Reciprocity

Data anonymization is the process of removing or altering any information that can be used to identify an individual from a data set. This technique provides the strongest assurance that data does not identify an individual, as it makes it impossible or extremely difficult to link the data back to the original source. Data anonymization can be achieved by various methods, such as generalization, suppression, perturbation, or pseudonymization12. Data anonymization is often used for privacy protection, compliance with data protection regulations, and data sharing purposes3. References:

• 1: Data Security: Definition, Importance, and Types | Fortinet
• 2: Data Security Best Practices: Top 10 Data Protection Methods - Ekran System
• 3: Data anonymization - Wikipedia

An unrecoverable data loss event after restoring a system is indicative of a failure to meet the Recovery Point Objective (RPO). The RPO represents the maximum tolerable period in which data might be lost due to an incident and is a critical component of an organization's disaster recovery and business continuity planning. If data restoration efforts are unsuccessful and lead to unrecoverable data loss, it means that the organization's data backup and recovery processes were insufficient to meet the defined RPO, leading to a loss of data beyond the acceptable threshold. This situation underscores the importance of implementing effective data backup and recovery strategies that align with the organization's RPO to minimize data loss and ensure business continuity in the event of a disruption.

References:

• Business continuity and disaster recovery standards, such as ISO 22301 (Security and Resilience - Business Continuity Management Systems - Requirements), provide guidelines on establishing and managing RPOs as part of a comprehensive business continuity plan.
• The "Disaster Recovery Planning Guide" by the Disaster Recovery Journal (DRJ) offers insights into best practices for data backup and recovery, emphasizing the importance of aligning recovery strategies with defined RPOs to minimize the impact of data loss incidents.

The contract is not the only enforceable control to stipulate third party service provider obligations for DR/BCP, nor are both programs necessarily triggered by the pandemic. According to the Shared Assessments Program, third party risk management (TPRM) is a continuous process that requires ongoing monitoring and assessment of third parties’ performance, compliance, and resilience. Therefore, the contract should be complemented by other controls, such as due diligence, audits, reviews, and reporting, to ensure that third parties meet the organization’s expectations and standards for DR/BCP. Moreover, DR/BCP are not only relevant for pandemic scenarios, but also for other types of disasters, such as natural disasters, cyberattacks, power outages, or human errors. Therefore, the contract should reflect the organization’s risk appetite and tolerance for different types of disruptions and scenarios, and not be limited to pandemic-related events. 

Indemnification is a contractual obligation by which one party agrees to compensate another party for any losses or damages that may arise from a specified event or circumstance. Mutual indemnification means that both parties agree to indemnify each other for certain losses or damages, such as those caused by a breach of contract, negligence, or violation of law. Mutual indemnification can enable each party to share the amount of information security risk, as it can provide a mechanism for allocating the responsibility and liability for any security incidents or breaches that may affect either party or their customers. Mutual indemnification can also incentivize each party to maintain adequate security controls and practices, as well as to cooperate and communicate effectively in the event of a security incident or breach.

The other options are not contract clauses that enable each party to share the amount of information security risk, because:

• A. Limitation of liability is a contract clause that limits the amount or type of damages that one party can claim from another party in the event of a breach of contract or other legal action. Limitation of liability does not enable each party to share the amount of information security risk, as it can reduce or cap the liability of one party, but not necessarily distribute or balance the risk between both parties.
• B. Cyber insurance is a type of insurance policy that covers the costs and losses resulting from cyberattacks, data breaches, or other cyber incidents. Cyber insurance does not enable each party to share the amount of information security risk, as it can transfer or mitigate the risk to a third-party insurer, but not necessarily allocate or share the risk between both parties.
• C. Force majeure is a contract clause that excuses one or both parties from performing their contractual obligations in the event of an unforeseen or unavoidable event or circumstance that is beyond their control, such as a natural disaster, war, or pandemic. Force majeure does not enable each party to share the amount of information security risk, as it can suspend or terminate the contract in the event of a force majeure event, but not necessarily distribute or balance the risk between both parties.

References:

• Shared Assessments CTPRP Study Guide, page 62, section 5.2.2: Contractual Terms
• Third-Party Risk Management: Vendor Contract Terms and Conditions, section: Indemnification
• Cybersecurity risks from third party vendors: PwC, section: Contractual terms and conditions
• [Third-Party Risk Management: The 3rd Party Ecosystem: How to Manage the Risk While Keeping the Benefit], section: Contractual Terms and Conditions

 it is the most appropriate and compliant method of validating pre-employment screening attributes among the given options. Requesting evidence of the performance of pre-employment screening when permitted by law means that the organization respects the legal and regulatory boundaries of different jurisdictions and does not impose unnecessary or unlawful requirements on its third parties. It also ensures that the organization obtains relevant and reliable information about the third parties’ screening processes and outcomes, which can help assess their suitability and risk level.

The other options are incorrect because they are either inappropriate or ineffective methods of validating pre-employment screening attributes. Reviewing evidence of web search of social media sites (A) is inappropriate because it may violate the privacy and data protection rights of the third parties and their employees, as well as expose the organization to potential bias and discrimination claims. Providing and sampling complete personnel files to demonstrate unique screening results (B) is ineffective because it may not reflect the actual screening attributes of the third parties, as they may have different screening criteria, standards, and methods than the organization. Requiring evidence of drug testing © is inappropriate because it may not be relevant or necessary for the nature and scope of the third-party relationship, and it may also conflict with the laws and regulations of different jurisdictions that prohibit or limit such testing. References:

 According to the GDPR, personal data is any information relating to an identified or identifiable natural person (data subject). The GDPR does not consider the volume of data records as a relevant factor for classifying personal data, but rather the nature and context of the data. The GDPR requires data controllers and processors to apply appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing personal data, taking into account factors such as the state of the art, the costs of implementation, the nature, scope, context and purposes of processing, and the risks of varying likelihood and severity for the rights and freedoms of natural persons. Therefore, the volume of data records is not a decisive attribute for classifying personal data, but rather an indicator of the potential impact of a data breach or misuse.

The other factors listed in the question are more important attributes for classifying personal data, as they relate to the identification, protection, and rights of the data subjects. The data subject category that identifies the data owner refers to the type of natural person whose personal data is processed, such as customers, employees, patients, students, etc. This factor is important for determining the purpose and legal basis of processing, as well as the data subject’s rights and expectations1. The sensitivity level of specific data elements that could identify an individual refers to the degree of harm or discrimination that could result from the disclosure or misuse of such data, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, sex life or sexual orientation, or criminal convictions or offenses2. The GDPR imposes stricter rules and obligations for the processing of such special categories of personal data, as they pose a higher risk to the data subject’s fundamental rights and freedoms. The assignment of a confidentiality level that differentiates public or non-public information refers to the degree of access and disclosure that is permitted or required for the personal data, depending on the data subject’s consent, the legitimate interests of the data controller or processor, or the applicable laws and regulations1. The GDPR requires data controllers and processors to implement data protection by design and by default, meaning that they should only process the personal data that is necessary for the specific purpose and limit the access to those who need to know.

References:

• 4: 5 Types of Data Classification (With Examples) | Indeed.com
• 7: Special Categories of Personal Data - GDPR EU
• [8]: Data Classification for GDPR Explained [Full Breakdown] - DataGrail

Inherent risk refers to the level of risk that exists in the absence of any controls or mitigation measures. It represents the natural exposure to risk in operations, transactions, or activities without considering the effectiveness of any risk management practices. In the context of Third-Party Risk Management (TPRM), inherent risk assesses the potential for loss or adverse outcomes associated with a third-party relationship before any controls or risk treatments are applied. Understanding inherent risk is crucial for organizations to identify where controls are necessary and to prioritize risk management efforts based on the potential impact and likelihood of different risks. This concept is foundational in risk management frameworks and is used to guide the development and implementation of controls to reduce risk to an acceptable level, aligned with the organization's risk appetite and tolerance.

References:

• Risk management standards such as ISO 31000 (Risk Management - Guidelines) provide a framework for assessing and managing inherent risks, emphasizing the importance of understanding the baseline level of risk in decision-making processes.
• The "Third-Party Risk Management Guide" by ISACA outlines best practices for assessing inherent risks in third-party relationships, highlighting the need to evaluate the nature and scope of third-party engagements to determine the baseline risk exposure.

The primary objective of a third party risk assessment is to validate that the vendor/service provider has adequate controls in place based on the organization’s risk posture. A third party risk assessment (also known as supplier risk assessment) quantifies the risks associated with third-party vendors and suppliers that provide products or services to your organization1. This assessment is useful for analyzing both new and ongoing supplier relationships. The growing risk of supply chain attacks makes it critical to conduct thorough and regular risk assessments of your third parties. A third party risk assessment helps you identify, measure, and mitigate the potential risks that your third parties pose to your organization, such as data breaches, cyberattacks, compliance violations, operational disruptions, reputational damage, or financial losses. A third party risk assessment also helps you align your third party risk management (TPRM) program with your organization’s risk appetite, policies, standards, and procedures. A third party risk assessment typically involves the following steps1:

• Scoping: Define the scope of the assessment based on the type, nature, and criticality of the third party relationship. Determine the relevant risk domains, such as security, privacy, compliance, business continuity, etc.
• Data collection: Gather information from the third party using various methods, such as questionnaires, surveys, interviews, audits, tests, or evidence reviews.
• Analysis: Analyze the data collected and compare it with your organization’s risk criteria, benchmarks, and best practices. Identify any gaps, weaknesses, or issues in the third party’s controls, processes, or performance.
• Reporting: Document the findings and recommendations of the assessment in a clear and concise report. Communicate the results to the relevant stakeholders, such as senior management, business owners, or regulators.
• Remediation: Follow up with the third party to ensure that they implement the necessary actions to address the identified risks. Monitor and track the progress and effectiveness of the remediation plan.
• Review: Review and update the assessment periodically or whenever there are significant changes in the third party relationship, the risk environment, or the regulatory requirements.

The other statements are not the primary objective of a third party risk assessment, although they may be related or secondary objectives. Assessing the appropriateness of non-disclosure agreements regarding the organization’s systems/data is a legal objective that may be part of the contract negotiation or review process. Determining the scope of the business relationship is a strategic objective that may be part of the vendor selection or due diligence process. Evaluating the risk posture of all vendors/service providers in the vendor inventory is a holistic objective that may be part of the vendor risk management or governance process. References:

• 1: Third-Party Risk Assessment: A Practical Guide - BlueVoyant
• : What Is Third-Party Risk Management (TPRM)? 2024 Guide | UpGuard
• : What is Third-Party Risk Management? | Blog | OneTrust

An outsourcer’s vendor risk assessment process should include all the steps mentioned in options A, B, and C, as they are essential for ensuring a consistent, comprehensive, and effective evaluation of the vendor’s performance, compliance, and risk profile. However, option D is not a necessary or recommended part of the vendor risk assessment process, as it does not reflect the actual level of risk posed by the vendor, but rather the availability of resources within the outsourcer’s organization. Defining assessment frequency based on resource capacity could lead to under-assessing or over-assessing vendors, depending on the outsourcer’s workload, budget, and staff. This could result in missing critical issues, wasting time and money, or creating gaps in the vendor oversight program. Therefore, option D is the correct answer, as it is the only one that does not belong to the vendor risk assessment process. References: The following resources support the verified answer and explanation:

• Shared Assessments’ CTPRP Job Guide, page 10, section 2.1.1, states that “The frequency of assessments should be based on the risk tier of the third party, not on the availability of resources.”
• Guide to Vendor Risk Assessment, section “Step 3: Determine the Frequency of Vendor Risk Assessments”, explains that “The frequency of vendor risk assessments should be based on the level of risk each vendor poses to your organization, not on the availability of resources or convenience.”
• How to Conduct a Successful Vendor Risk Assessment in 9 Steps, section “Step 8: Determine the Frequency of Vendor Risk Assessments”, advises that “The frequency of vendor risk assessments should be based on the level of risk each vendor poses to your organization, not on the availability of resources or convenience.”

Due diligence is the process of evaluating the risks and opportunities associated with a potential or existing third-party vendor. Due diligence can vary in scope and depth depending on the level of risk that the vendor poses to the organization. Lower risk vendors are those that have minimal impact on the organization’s operations, reputation, or compliance, and that do not handle sensitive or confidential data or systems. For lower risk vendors, conducting due diligence may involve accepting the service provider’s self-assessment questionnaire responses as sufficient evidence of their capabilities, performance, and compliance. A self-assessment questionnaire is a tool that allows the vendor to provide information about their organization, services, processes, controls, and policies. The organization can use the questionnaire to verify the vendor’s identity, qualifications, references, and certifications, and to assess the vendor’s alignment with the organization’s standards and expectations. Accepting the vendor’s self-assessment questionnaire responses as the primary source of due diligence can save time and resources for the organization, and can also demonstrate trust and confidence in the vendor. However, the organization should also ensure that the questionnaire is comprehensive, relevant, and updated, and that the vendor’s responses are accurate, complete, and consistent. The organization should also reserve the right to request additional information or documentation from the vendor if needed, and to conduct periodic reviews or audits of the vendor’s performance and compliance.

The other options do not best describe conducting due diligence of a lower risk vendor, because they either involve more extensive or rigorous methods of due diligence, or they are not directly related to due diligence. Preparing reports to management regarding the status of third party risk management and remediation activities is an important part of monitoring and managing the vendor relationship, but it is not a due diligence activity per se. Reviewing a service provider’s self-assessment questionnaire and external audit report(s) is a more thorough way of conducting due diligence, but it may not be necessary or feasible for lower risk vendors, especially if the external audit report(s) are not readily available or relevant. Requesting and filing a service provider’s external audit report(s) for future reference is a good practice for maintaining documentation and evidence of due diligence, but it is not a due diligence activity itself.

References:

• Third Party Risk Management (TPRM) | Shared Assessments
• Vendor Due Diligence Strategy Guide and Checklist | Prevalent
• Vendor due diligence: a practical guide and checklist

 A regulation is a rule of order having the force of law, prescribed by a superior or competent authority, relating to the actions of those under the authority’s control. Regulations are issued by various government departments and agencies to carry out the intent of legislation enacted by the legislature of the applicable jurisdiction. Regulations also function to ensure uniform application of the law. A standard is a guideline established generally by private-sector bodies and that are available for use by any person or organization, private or government. The term includes what are commonly referred to as ‘industry standards’ as well as ‘consensus standards’. Standards are developed through a voluntary process of collaboration and consensus among stakeholders, such as manufacturers, consumers, regulators, and experts. Standards may reflect best practices, technical specifications, performance criteria, or quality requirements. Standards do not have the force of law unless they are adopted or referenced by a regulation. Therefore, a regulation must be adhered to by all companies subject to its requirements, but companies can voluntarily choose to follow standards that are relevant and beneficial to their operations, products, or services. References:

• The Difference Between Regulations and Standards
• Regulations vs Standards: Clearing Up the Confusion - AEM
• Standards vs. Regulations
• Certified Third Party Risk Professional (CTPRP) Study Guide

Controls evaluation is the process of verifying and validating the effectiveness of the controls implemented by the third party to mitigate the identified risks. It involves reviewing the evidence provided by the third party, such as policies, procedures, certifications, attestations, or test results, to determine if the controls are adequate, consistent, and compliant with the requirements and standards of the organization. Controls evaluation also involves analyzing the assessment results to identify any gaps, weaknesses, or issues in the third party’s controls, and reporting the findings and recommendations to the relevant stakeholders. Negotiating contract terms for the right to audit is not a component of controls evaluation, but rather a component of contract management. Contract management is the process of establishing, maintaining, and enforcing the contractual agreements between the organization and the third party. It involves defining the roles, responsibilities, expectations, and obligations of both parties, as well as the terms and conditions for service delivery, performance measurement, risk management, dispute resolution, and termination. Negotiating contract terms for the right to audit is a key aspect of contract management, as it allows the organization to monitor and verify the third party’s compliance with the contract and the applicable regulations and standards. It also enables the organization to conduct independent audits or assessments of the third party’s controls, processes, and performance, and to request remediation actions if necessary. References:

• 1: Shared Assessments, a leading provider of third party risk management solutions, offers a comprehensive guide for Certified Third Party Risk Professional (CTPRP) candidates, which covers the core concepts and best practices of third party risk management, including controls evaluation and contract management.
• 2: UpGuard, a platform for cybersecurity and third party risk management, provides a detailed overview of the best practices for third party risk assessment, which includes the steps and criteria for evaluating the controls of third parties.
• 3: Deloitte, a global professional services firm, offers an end-to-end managed service for third party risk management, which includes controls evaluation and contract management as key components of the service.

An organization’s Ethics and Code of Conduct Program is a set of policies, procedures, and practices that define the expected standards of behavior and ethical values for all employees and stakeholders. A key component of such a program is a disciplinary process that outlines the consequences and actions for violating the code of conduct or any other relevant policies. A disciplinary process helps to enforce the code of conduct, deter unethical behavior, and protect the organization’s reputation and integrity. A disciplinary process should include clear criteria for determining the severity and frequency of violations, the roles and responsibilities of the parties involved, the steps and timelines for investigation and resolution, and the range of sanctions and remedies available. A disciplinary process should also be fair, consistent, transparent, and respectful of the rights and dignity of the accused and the accuser. A disciplinary process may involve formal termination or change of status of the employee, depending on the nature and impact of the violation. Therefore, option B is a correct component of an organization’s Ethics and Code of Conduct Program.

The other options are not necessarily components of an Ethics and Code of Conduct Program, although they may be related or supportive of it. Option A, participation in the company’s annual privacy awareness program, is more likely to be a component of a Privacy Program, which is a specific area of ethics and compliance that deals with the protection and use of personal information. Option C, signing acknowledgement of Acceptable Use policy for use of company assets, is more likely to be a component of an Information Security Program, which is another specific area of ethics and compliance that deals with the safeguarding and management of data and systems. Option D, a process to conduct periodic access reviews of critical Human Resource files, is more likely to be a component of an Internal Control Program, which is a general area of ethics and compliance that deals with the design and implementation of controls to ensure the reliability and accuracy of financial and operational information. References:

• 1: Creating an Effective Code of Conduct (and Code Program) - Corporate Compliance Insights
• 2: Code of Conduct & Ethics (Examples and Best Practices) - Status.net
• 3: Why Have a Code of Conduct - Free Ethics & Compliance Toolkit
• 4: “Code of Ethics” and “Code of Conduct” - GeeksforGeeks
• 5: Six Tips on How to Implement a Strong Ethics Program - KnowledgeLeader